Jorge Zamora-Quezada - Page 2

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                                     Additions to Tax                                
          Year      Deficiency         Sec. 6651(a)    Sec. 6654                      
          1988      $56,124              $13,966        $3,590                        
          1989      33,575                8,394         2,270                         
          1990        40,531               10,133         2,667                       
          1991       100,185               25,046         2,589                       
          1992        77,245               19,288         3,365                       
               Following petitioner's concession that he is liable for the            
          deficiencies determined by respondent, we must decide whether he is         
          liable for the additions to tax as well.  We hold he is.  Unless            
          otherwise noted, section references are to the Internal Revenue             
          Code in effect for the years in issue.  Rule references are to the          
          Tax Court Rules of Practice and Procedure.                                  
               Petitioner resided in Guadalajara, Jalisco, Mexico, when he            
          petitioned the Court.                                                       
               Petitioner was in the United States on a student visa for              
          approximately the 5-year period prior to 1988.  During this period,         
          he performed personal services in the United States as an employee,         
          and Federal taxes were withheld from the corresponding paychecks            
          that he received.  His visa expired in 1988, and he continued to            
          work and live in the United States from 1988 through 1992 without           
          official residency status.                                                  
               Petitioner earned income in the United States during each of           
          the years from 1988 through 1992 performing services as a physician         
          on an independent contractor basis.  He worked in various medical           
          facilities, most of which were located in or near Boston,                   
          Massachusetts.  Many of these facilities issued petitioner a Form           

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