Robert D. Mueller - Page 3

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            references are to the Tax Court Rules of Practice and Procedure.                           
            Dollar amounts are rounded to the nearest dollar.                                          
                                         FINDINGS OF FACT                                              
                  Petitioner resided in Chicago, Illinois, when he petitioned                          
            the Court. Petitioner did not file Federal income tax returns for                          
            any of the taxable years 1986 through 1995.  During these years                            
            petitioner earned the bulk of his income by working as a computer                          
            programmer/consultant for various companies and hospitals.                                 
            Petitioner also had small amounts of interest and capital gain                             
            income in 1987.                                                                            
                  Petitioner made no estimated tax payments to the Internal                            
            Revenue Service with respect to any of the years in issue.                                 
            However, petitioner had the following amounts withheld from his                            
                                    Year        Withholding                                            
                                    1987        $1,986                                                 
                                    1993        1,295                                                  
                                    1994        5,283                                                  
                                    1995        5,413                                                  
                  Petitioner is homosexual.  In 1989, petitioner began a                               
            relationship with another man whom petitioner describes as his                             
            roommate and partner.  From 1989 through 1995 petitioner and his                           
            partner resided together and shared assets and income.                                     
            Petitioner was not married (to his partner or anyone else) as of                           
            December 31 for any of the taxable years 1986 through 1995.  In                            
            the notice of deficiency mailed to petitioner, respondent                                  

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