Albert C. Johnson - Page 3

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          feed for each of the years in issue; (b) a 1990 trip to Belgium;            
          and (c) depreciation for a barn for each of the years in issue; and         
          (3) whether petitioner is liable for the section 6651(f) fraudulent         
          failure to file addition to tax, or in the alternative the section          
          6651(a)(1) failure to file addition to tax, for each of the years           
          in issue.1                                                                  
               All section references are to the Internal Revenue Code as in          
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedures.  Some of the facts have         
          been stipulated, and the stipulated facts are incorporated in our           
          findings by this reference.                                                 
                                  General Findings                                    
               At the time the petition was filed, petitioner resided in              
          Tennessee.  During the years in issue, petitioner was married to            
          Juanita Johnson; she resided much of the time in Panama City,               
          Florida.  Petitioner did not file Federal income tax returns for            
          any of the years in issue.                                                  
               For convenience and clarity, we have combined our remaining            
          findings of fact and opinion with respect to each issue.                    

               1    Petitioner concedes that should we conclude that the              
          sec. 6651(f) addition to tax is not applicable, then the sec.               
          6651(a)(1) addition to tax would be applicable to any finally               
          determined deficiency.                                                      

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