William W. Howard - Page 2

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               On November 14, 1995, respondent issued a notice of                    
          deficiency to petitioner determining deficiencies in, and                   
          additions to, his Federal income taxes for 1987 and 1988.  The              
          deficiencies were attributable to respondent's determination that           
          petitioner, an attorney, had embezzled funds from the Estate of             
          Zelda Willey Putman and had failed to report such amounts as                
               On November 21, 1995, petitioner commenced a case in this              
          Court by filing a petition for redetermination, which was                   
          assigned docket No. 24572-95.  Petitioner contested respondent’s            
          determinations in the notice of deficiency on the ground that the           
          funds that he received from the Putman estate were loans.  The              
          case was tried to the Court in the spring of 1997.  Following the           
          filing of briefs by the parties, the Court issued a memorandum              
          opinion (Howard v. Commissioner, T.C. Memo. 1997-473) on October            
          16, 1997, essentially sustaining respondent's determinations.2              
          Thereafter, on January 21, 1998, the Court entered decision                 
          against petitioner.  Petitioner did not file any posttrial                  
          motions, see Rules 161 and 162, nor did he file a notice of                 
          appeal.  Accordingly, the Court’s decision became final on April            
          21, 1998.  See secs. 7481(a)(1), 7483.                                      

               2  Respondent conceded that petitioner’s embezzlement income           
          for 1988 was slightly less than the amount determined in the                
          notice of deficiency.                                                       

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