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Respondent also determined that if petitioner was not liable
for fraud, he was liable for additions to tax and penalties for
negligence under section 6653(a)(1) for 1988, penalties for
negligence under section 6662 for 1989 and 1990, an addition to
tax for substantial understatement under section 6661 for 1988
and additions to tax for failure to timely file under section
6651(a)(1) for 1988 and 1990.
After concessions, the issues for decision are:
(1) Whether, as respondent contends, petitioner had
unreported income of $55,100 in 1988, $114,385 in 1989, and
$23,966 in 1990. We hold that he did.
(2) Whether petitioner is liable for fraud for 1988, 1989,
and 1990. We hold that he is.1
Section references are to the Internal Revenue Code in
effect in the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
A. Petitioner
Petitioner is a single individual who lived in New Mexico
when he filed his petition.
1 We need not consider respondent's alternative
determinations.
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