Henry Hardy - Page 2

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          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                  
          Procedure.                                                                  
               After concessions, the issues for decision are:  (1) Whether           
          petitioner had unreported income in 1988 and 1989; (2) whether              
          petitioner is liable for the addition to tax and penalty for                
          fraud in 1988 and 1989, respectively, or, in the alternative,               
          liable for the addition to tax and penalty for negligence; and              
          (3) whether the period of limitations for assessment is open for            
          1988 under section 6501(c)(1) or, in the alternative, open under            
          section 6501(e)(1)(A).                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Included among the stipulated exhibits is the transcript of                 
          petitioner's criminal trial.  At the time the petition was filed,           
          petitioner was incarcerated at the California Correctional                  
          Institution in Tehachipi, California.                                       
               Petitioner started a business known as the Stardust Modeling           
          Agency (Stardust) in 1987.  Petitioner opened a bank account for            
          Stardust, purchased furniture for Stardust, and signed the lease            
          for Stardust.  Petitioner operated Stardust from the end of 1987            
          into mid-1991.  The hours of operation of Stardust were Monday              
          through Saturday, 10 a.m. to 10 p.m.  During 1988 and 1989,                 




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