Alan Michael Newman - Page 3

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               During 1991, petitioner was employed by Appraisal Tech and             
          the San Jose Mercury News.  Petitioner received $2,296 and $7,875           
          of wages and nonemployee compensation, respectively, from                   
          Appraisal Tech.  Petitioner received nonemployee compensation of            
          $1,987 from the San Jose Mercury News.                                      
               During 1993, petitioner was employed by Kushner & Robertson            
          and received wages of $22,927.                                              
               In addition, respondent increased petitioner's income using            
          amounts determined from statistical data compiled by the Bureau             
          of Labor Statistics.  In calculating petitioner's income based on           
          Bureau of Labor Statistics' data, respondent selected 10 tables             
          which he believed were representative of petitioner's age, race,            
          family/earning composition, and geographics.  These 10 tables               
          totaled income of $278,512, which respondent divided by 10 to get           
          a base income of $27,851 for taxable year 1988.  Respondent                 
          increased the 1988 base year amount for inflation to determine              
          the 1990, 1991, and 1993 Bureau of Labor Statistics income                  
          amounts for petitioner of $30,969, $31,929, and $33,840,                    

               1    Respondent introduced at trial the revenue agent's                
          workpapers showing how the Bureau of Labor Statistics tables were           
          used.  Petitioner objected because he was not shown the                     
          workpapers prior to their introduction at trial.  Because                   
          respondent did not show the workpapers to petitioner 15 days                
          before trial, as required by the standing pretrial order, the               
          workpapers were received only to show how the amount in the                 
          statutory notice of deficiency was calculated, not for the truth            

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