Jerry V. Rice - Page 2

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                               Additions to Tax and Penalties                         
                                Sec.         Sec.        Sec.                         
                      Year  6653(b)(1)(A)  6653(b)(1)    6663                         
                      1987     $7,324         --         --                           
                      1988      --           $8,127      --                           
                      1989      --            --       $13,576                        
               After concessions by the parties, the issues remaining for             
          decision are whether this Court has jurisdiction over this case             
          and whether petitioner fraudulently underpaid his Federal income            
          tax for 1989.  Unless otherwise indicated, all section references           
          are to the Internal Revenue Code in effect for the years in                 
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.                                                     
                                  FINDINGS OF FACT                                    
               This case was submitted fully stipulated, and the facts set            
          forth in the stipulation are incorporated in our findings by this           
          reference.  Jerry V. Rice (petitioner) resided in Albuquerque,              
          New Mexico, at the time the petition in this case was filed.                
          During 1989, petitioner was employed as a certified public                  
          accountant (C.P.A.) with two companies, Jerry V. Rice C.P.A.,               
          P.C. (Jerry Rice, P.C.), and its successor, Rice and Associates             
          C.P.A., P.C. (Rice and Associates).  Petitioner was the sole                
          shareholder in both companies and was responsible in each for               
          keeping records and paying payroll taxes.  Accordingly,                     
          petitioner knew that neither Jerry Rice, P.C., nor Rice and                 

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