Helena Culver Fraser - Page 2

                                        - 2 -                                         
                                        Additions to Tax                              
               Year      Deficiency     Sec. 6651(f)     Sec. 6654(a)                 
              1991      $11,376        $6,933              $34                       
               1992      15,885         9,727               553                       
               1993      23,398         17,549             981                        
               After concessions, the issues for decision are:  (1) Whether           
          petitioner failed to report wages from her employment, interest             
          income, and unemployment compensation, and (2) whether petitioner           
          is liable for additions to tax under section 6654(a)1 for her               
          failure to pay estimated taxes.  Respondent has conceded that               
          petitioner is not liable for the additions to tax under section             
          Procedural Background                                                       
               On August 19, 1996, respondent filed a Motion to Show Cause            
          pursuant to Rule 91(f) as to why facts and evidence set forth in            
          her proposed stipulation of facts should not be accepted as                 
          established.  On September 17, 1996, petitioner filed a response            
          to this Court's order to show cause.  After due consideration,              
          this Court ordered on September 20, 1996, that facts and evidence           
          set forth in respondent's proposed stipulation of facts were                
          deemed to be established for purposes of this case.                         
          Facts Deemed Admitted                                                       
               At the time the petition in this case was filed, petitioner            
          resided in Visalia, California.  During 1991 and 1992, petitioner           

               1 All section and subtitle references are to the Internal              
          Revenue Code in effect for the taxable years in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure, unless otherwise designated.                                     

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