Hugh Wilkinson and Evelyn Wilkinson - Page 7

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          for 1988 and $150,058 for 1989.  On petitioners' 1988 Federal                
          income tax return, they reported a $1,105 short-term capital loss            
          to be carried over to 1989, $5,000 of estimated tax payments, and            
          $11 of tax withheld.  On their 1989 Federal income tax return,               
          petitioners deducted a $1,208 short-term capital loss carryover              
          from 19881 and reported $8,000 of estimated tax payments and $3              
          of tax withheld.  Both petitioners signed the returns.  Mrs.                 
          Wilkinson claims that she did not read the returns before signing            
          them but concedes that she could have read the returns before she            
          signed them.                                                                 
               Petitioners have a history of filing delinquent tax returns             
          and paying late any tax that is due with respect thereto.                    
          Petitioners filed their 1985 return in December 1986 and paid the            
          balance of the tax in April 1987.  Petitioners filed their 1986              
          return in July 1988, paying the balance of the tax due in January            
          1989.  Petitioners filed their 1987 return in July 1990, paying              
          the balance of the tax due in April 1991.                                    
          3.  Dr. Wilkinson's Criminal Plea                                            
               On or about March 31, 1995, a "Misdemeanor Information" was             
          filed against Dr. Wilkinson, charging him with violating                     
          section 7203 by willfully failing to file timely Federal income              
          tax returns for 1988 through 1990.  On November 1, 1995,                     
          Dr. Wilkinson pled guilty to violating section 7203 for 1988.                

               1  This discrepancy accounts for the $29 deficiency in the              
          1989 tax year.                                                               




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