Ella Freidus - Page 4




                                        - 4 -                                          

               Prior to her marriage to Mr. Freidus, petitioner regularly              
          filed Federal income tax returns.  While petitioner was aware of             
          her duty to file income tax returns and the consequences arising             
          for failing to file, she did not file Federal income tax returns             
          for her 1987, 1988, 1989, and 1990 taxable years.  Petitioner was            
          also aware of her right to request extensions to file her tax                
          returns, but did not request extensions to file her returns.  The            
          last return petitioner filed was for the 1980 taxable year.                  
          Petitioner also knew of her obligation to make estimated tax                 
          payments, but failed to do so for the 1987, 1988, 1989, and 1990             
          taxable years.                                                               
               Petitioner believed that a 1990 return, if prepared, would              
          indicate that she owed taxes.  Petitioner also believed that she             
          would owe taxes for 1987 had a return been prepared.                         
               During the years in issue, petitioner's income consisted of             
          the following:                                                               
                    Horse Show                                                         
          Year        Income       Interest        Capital Gains   Rents               
          1987      $246,614       $15,027         $195,631       $154,833             
          1988      104,166        15,427          903,018        127,943              
          1989      197,287        1,991           380,114        27,802               
          1990      133,578        7,489           3,179,663      9,184                
               Petitioner made the following purchases at Christie's                   
          auctions:                                                                    









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