Maurice D. and Elinor Taylor - Page 9

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          Ford station wagon, both of which were financed. Also, petitioners          
          coowned a beach house in Annapolis, Maryland, which was sold in             
          1984 or 1985.                                                               
               Mrs. Taylor handled the family finances.  She maintained the           
          family checking account and paid the household expenses out of the          
          weekly $500 given to her by petitioner.                                     
               Petitioners' three children attended public schools in                 
          Baltimore County and were members of a local swim club.                     
          Occasionally, petitioners went on short family vacations to Ocean           
          City, Maryland.                                                             
               Petitioner did not purchase any jewelry, furs, or similar              
          luxury items for Mrs. Taylor during the years in issue.                     
          Filing of Federal Tax Returns                                               
               In January 1992, following petitioner's release from the               
          halfway house, petitioner and his accountant, Daniel Mules, met             
          with Revenue Officer Mario Scilipoti to discuss the filing of               
          delinquent returns for both the grocery/convenience store and               
          petitioners.  Petitioner informed Revenue Officer Scilipoti that he         
          believed the grocery/convenience store suffered losses during the           
          years in issue. Petitioner further informed Revenue Officer                 
          Scilipoti that although the records for the grocery/convenience             
          store were in disarray, he had some documents that he could use for         
          filing the returns. Petitioner also informed Revenue Officer                

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