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Petitioner and Mrs. Driggers completed a second loan
application in an attempt to refinance their home mortgage in
1992 (the 1992 Application). On the 1992 Application, petitioner
and Mrs. Driggers listed their combined monthly income as $9,438,
which translates to $113,256 annually. With this application,
petitioner and Mrs. Driggers submitted what they purported to be
their 1990 Federal income tax return. On this purported return,
petitioner and his wife claimed to have earned $97,882 in wages
during 1990. A Form W-2 was included with this purported return
listing petitioner's wages from his employer, PCG, as $70,902.08
for 1990. Also submitted with the 1992 Application was a
purported copy of petitioner's and Mrs. Driggers' 1991 Federal
income tax return. This purported return lists petitioner's and
Mrs. Driggers' income as $99,604 for 1991. A Form W-2 was also
included with this purported return listing petitioner's 1991
wages from PCG as $76,960.11. These purported returns and Forms
W-2 were never filed with the Internal Revenue Service.
Respondent's reliance on petitioner's income figures listed
in these loan applications is supported by additional evidence.
Income From First Coast Engineers, Inc.
Petitioner and Howard Young incorporated FCE on April 4,
1984. FCE was engaged in the construction business as a general
contractor from its incorporation until sometime in 1990.
Petitioner was a 50-percent shareholder of FCE and its vice
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