Alejandrina De Aycardi - Page 2

                                        - 2 -                                         
                                             Addition to Tax                          
                    Year      Deficiency     6651(a)(1)                               
                    1987      $17,835             $4,459                              
                    1988      21,529              5,382                               
                    1989      36,911              9,228                               

               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
               The issue for decision is whether certain income that                  
          petitioner received in 1988 and 1989 qualifies under section                
          871(h) as nontaxable interest on qualified "portfolio debt                  

                                  FINDINGS OF FACT                                    
               Many of the facts have been stipulated and are so found.  At           
          the time the petition was filed and during the years in issue,              
          petitioner resided in Ocana, Colombia.                                      
               From 1937 to 1941, petitioner attended college in the United           
          States and during those years petitioner obtained a U.S. Social             
          Security number.  In 1941, petitioner returned to Colombia.                 
          Since 1941, petitioner has resided in Colombia.                             
               In November of 1988, with assistance from a sister who                 
          resided in the United States, petitioner invested $1,015,489 in a           
          mutual fund with respect to which petitioner received U.S. source           
          interest and dividend income.                                               

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