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payments that she received from ABC during each of the years 1983
and 1984. Ms. Drummond directed employees of ABC not to issue a
Form 1099 to her for either 1983 or 1984.
Ms. Drummond received $4,669 in interest income during 1984.
She also received during that year $33 in capital gain income
through SFR Three, Ltd.
At all relevant times, Ms. Drummond was fully aware of the
requirement to report income. She also was fully aware of the
requirement to file a tax return (return).
Ms. Drummond, who married Mr. Drummond on December 31, 1984,
filed a return for 1983 around August 19, 1985, in which she
reported $18,000 in wages, but did not report the additional
funds totaling $52,277.08 that she received from ABC during that
year. Ms. Drummond did not file a return for 1984, and conse-
quently she did not report any of the funds totaling $39,553.22
that she received from ABC during that year. Nor did she report
the $4,669 in interest income and $33 in capital gain income that
she received during 1984. Except for a credit in the amount of
$506 that Ms. Drummond requested in her 1983 return be applied to
her 1984 estimated tax, Ms. Drummond made no estimated tax
payments with respect to her taxable year 1984.
During respondent's civil examination of Ms. Drummond's
taxable years 1983 and 1984, Ms. Drummond presented respondent's
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