Mahendra K. Tandon - Page 3

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               (7) whether petitioner is entitled to a dependency exemption           
          for Anupam Tandon (Anupam) in 1986;                                         
               (8) whether petitioner is liable for additional self-                  
          employment tax in 1986 and 1987;                                            
               (9) whether petitioner is liable for the additions to tax              
          for fraud for 1985, 1986, 1987, and 1988 to the extent there is             
          any unreported medical practice and/or rental income;                       
               (10) whether petitioner is liable for the additions to tax             
          for negligence for 1986, 1987, and 1988; and                                
               (11) whether petitioner is liable for the additions to tax             
          for a substantial understatement for 1985, 1986, 1987, and 1988.            
               Finally, if we decide that petitioner did not fraudulently             
          fail to report income in 1985, 1986, 1987, and 1988, we must                
          decide whether the periods of limitations for assessing taxes for           
          these years have expired.                                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in               
          Mayfield Heights, Ohio, at the time he filed his petition.                  
          Petitioner prepared his own tax returns for the years in issue.2            
               Petitioner has three children--Manoj, Harsh, and Parag.                
          During the years in issue, Manoj was a teenager.  Guru Prasad               


               2  Unless otherwise indicated, all descriptions refer to the           
          1985, 1986, 1987, and 1988 tax years.                                       



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