Mahendra K. Tandon - Page 8

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          computerized deposit analysis listing all of the third-party                
          payors who paid petitioner for medical services, the amounts                
          paid, and the bank account the payment was deposited into.  Mr.             
          Dever subtracted out of his deposit analysis amounts that were              
          not for medical services.  Mr. Dever determined that the amount             
          of petitioner's medical practice income deposited into the                  
          various bank accounts was greater than the amount reported on               
          petitioner's 1985, 1986, 1987, and 1988 individual and Superior's           
          1988 corporate tax returns.                                                 
          Petitioner's Criminal Tax Convictions                                       
               In United States v. Tandon, 111 F.3d 482 (6th Cir. 1997),              
          the U.S. Court of Appeals for the Sixth Circuit affirmed                    
          petitioner's conviction for wilfully filing false individual                
          income tax returns for 1986, 1987, and 1988 in violation of                 
          section 7206(1) and for wilfully assisting in the preparation and           
          presentation of a false corporate income tax return for Superior            
          for 1988 in violation of section 7206(2).                                   
          Unreported Income                                                           
               Every individual liable for tax is required to maintain                
          books and records sufficient to establish the amount of his or              
          her gross income.  Sec. 6001; DiLeo v. Commissioner, 96 T.C. 858,           
          867 (1991), affd. 959 F.2d 16 (2d Cir. 1992).  Where a taxpayer             
          fails to maintain or produce adequate books and records, the                
          Commissioner is authorized to compute the taxpayer's taxable                

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