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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
determinations.
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.
Background
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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