Richard A. Cole, M.D. Inc. - Page 9

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          determined that petitioner had unreported receipts of $338,317              
          for fiscal year 1987 and $259,951 for fiscal year 1988, had                 
          unreported interest income of $990 for fiscal year 1987 and                 
          $5,189 for fiscal year 1988, and was not entitled to carry                  
          forward a net operating loss of $2,341 to fiscal year 1988, and             
          that petitioner was liable for additions to tax for fraud and               
          substantial understatement for fiscal years 1987 and 1988.                  
          E.   The Stipulation of Facts                                               
               On January 20, 1998, respondent, pursuant to Rule 91(f),               
          moved to compel stipulation and attached a proposed stipulation             
          of facts and related exhibits.  On February 10, 1998,                       
          petitioner's response was filed.  In it, petitioner alleged that            
          respondent's proposed stipulation was based on records that were            
          obtained from an illegal search and seizure from its office and             
          objected to these records' being used in this case.  On February            
          12, 1998, we overruled petitioner's objection and ordered                   
          petitioner to supplement its response and respond substantively             
          to the order to show cause.  Petitioner did not do so.  On March            
          4, 1998, we ordered that the facts and evidence stated in                   
          respondent's proposed stipulation of facts be deemed established            
          for purposes of this case.                                                  
               Dr. Cole testified for petitioner.                                     

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