Leo and Alla Goldberg - Page 3

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          the years in issue, and all Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            
               After concessions by the parties, the issues remaining for             
          decision are:                                                               
               For 1988, whether the statute of limitations bars assessment           
          and, if not, whether petitioners had unreported income from                 
          various real estate transactions, unemployment compensation, and            
          unexplained bank deposits and whether they are entitled to                  
          deductions relating to their taxi business.                                 
               For 1990 and 1991, whether petitioners had various items of            
          unreported income and whether they are entitled to deductions               
          relating to a vehicle resale business and a business school.                
               For all years, whether petitioners are liable for the                  
          additions to tax and penalties determined by respondent.                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioners, Leo Goldberg (petitioner) and Alla Goldberg                    
          (Mrs. Goldberg), were married and resided in Orange County,                 
          California, at the time they filed their petition.                          
               Petitioner immigrated to the United States from the Soviet             
          Union in 1977.  Petitioner received a degree in engineering from            
          Moscow University, and he earned an M.B.A. from Pepperdine                  
          University in December 1987.  Petitioner has been involved, at              
          least to some extent, with real estate since 1986.  He became               




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