Gregory A. Maslow and Marina Maslow - Page 3

          to timely file their 1992 income tax return under section                   
          6651(a)(1)?  We hold petitioners are liable for both the penalty            
          and the addition to tax.                                                    
               All section references are to the Internal Revenue Code for            
          the year under consideration.  All Rule references are to the Tax           
          Court Rules of Practice and Procedure.  All dollar amounts are              
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.  For convenience, we present a background         
          section and combine our findings of fact with our opinion under             
          separate issue headings.                                                    
               Petitioners, husband and wife, resided in Randallstown,                
          Maryland, at the time they filed their petition.  Gregory A. Maslow         
          (petitioner) emigrated to the United States from Russia in 1974.            
          He and Marina met (in 1986) and married (in 1988) in the United             
               During 1992, the year under consideration, petitioner was a            
          general agent for several life and health insurance companies.  In          
          addition, during 1992 he started a business (known as East-West             
          International) which was to engage in the export of goods to                
               Petitioners did not file Federal income tax returns for 1988           
          through 1992 until they were contacted by one of respondent's               

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