Michael London - Page 30

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                  It is determined that you realized additional                       
                  income [for 1985] in the amount of $213,120.00                      
                  because the comparison of all known expenditures                    
                  with all known receipts, as shown on Exhibit A                      
                  attached hereto, has established an understate-                     
                  ment of income.  Since you failed to include                        
                  such additional income on your income tax return,                   
                  taxable income is increased in the amount of                        

             Based thereon, respondent computed increases in tax of                   
             $148,421 and $105,160 for 1983 and 1985, respectively.                   
             Respondent also determined with respect to 1983 and 1985                 
             that petitioners are liable for the additions to tax for                 
             fraud under section 6653(b)(1) and (2), and the addition                 
             to tax for substantial understatement of liability under                 
             section 6661.                                                            
             Admissibility of Mr. London's Deposition in the Wrongful                 
             Levy Suit                                                                
                  At trial, Mrs. London called her husband to testify as              
             a witness.  In response to each of the questions put to him              
             by Mrs. London's attorney and by the Court, Mr. London                   
             invoked his Fifth Amendment privilege against self-                      
             incrimination and refused to answer the question.  Counsel               
             for Mrs. London then offered into evidence the deposition                
             of Mr. London taken during the wrongful levy suit,                       

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