Wale O. Osijo - Page 3

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          liable for additions to tax under section 6651(a)(1) for all                
          years before the Court.  The issues for decision pertain to                 
          whether respondent was correct in making the above                          
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and the attached exhibits are              
          included herein by this reference.  Petitioner resided in Fresno,           
          California, at the time he filed his petition.                              
               Petitioner graduated from Western Kentucky University in               
          1986.  Soon after, he moved to the Fresno area and worked for a             
          restaurant as an assistant manager.  In 1987, petitioner moved to           
          Oakland, California, to study in a master’s in business                     
          administration program with a concentration in taxation at Golden           
          Gate University.                                                            
               To support himself through school, petitioner worked several           
          part-time jobs, including working as a security guard at an                 
          Oakland housing complex.  On October 7, 1988, while petitioner              
          was on night shift with 2 other security guards at the housing              
          complex, assailants entered the security office with high-powered           
          rifles and began shooting.  One guard was killed and one escaped.           
          Petitioner was shot 15 times in the abdominal area and was taken            
          to the Alameda County Hospital.                                             

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