Theodore Langworthy, Jr. - Page 2

                                        - 2 -                                         
                         Additions to Tax                   Penalty                   
               Sec.          Sec.            Sec.       Sec.      Sec.                
          Year    Deficiency   6653(b)   6653(b)(1)(A)   6653(b)(1)(B)   6661      6663
          1987 $32,177        -    $24,133            1          $8,044               
               -                                                                      
          1988 26,326    $19,745        -         -         6,582     -               
          1989 27,199         -         -         -         -      $20,399            
          1990 11,624         -         -         -         -        8,718            
          150 percent of the interest due on the deficiency.                          
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After concessions, the issues to be decided are as follows:            
               (1)  Whether the assessment and collection of taxes,                   
          additions to tax, and penalties for 1987, 1988, and 1990 are                
          barred by the period of limitations pursuant to section 6501(a)             
          or are allowed under either (a) the fraud exception to the                  
          general period of limitations provided in section 6501(c)(1) or             
          (b) the extended 6-year period of limitations provided in section           
          6501(e)(1)(A); and                                                          
               (2)  if assessment and collection are not barred for 1987,             
          1988, and 1990, then, for each of those years and for 1989 we               
          must decide whether:                                                        
                    (a)  and, if so, to what extent, petitioner omitted               

          1(...continued)                                                             
          increased deficiencies, the issues relating to such increased               
          deficiencies appear to have been tried by consent.  Rule                    
          41(b)(1).  We, however, do not address the increased deficiencies           
          because the decision we reach below results in deficiencies less            
          than those determined by respondent in the notice of deficiency.            




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