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                  Prior to trial, the parties stipulated to reduced tax               
             deficiencies and additions to tax for 1988 and 1989.  The                
             revised deficiencies and additions to tax for those years                
             are as follows:                                                          
                                                Revised                               
                            Revised        Additions to Tax                           
                  Year        Deficiency        Sec. 6651(a)(1)                       
                  1988      $79,268             $19,817                               
                  1989      77,687              19,422                                
             With respect to 1990, the parties stipulated that there was              
             an overassessment of tax of $11,472 and an overassessment                
             of the addition to tax of $2,868.                                        
                  Set out below is a summary to the adjustments made by               
             respondent in the notice of deficiency and the adjustments               
             agreed to by the parties:                                                
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