Ronald A. Mason - Page 2




                                        - 2 -                                         
                             Additions to Tax                                         
           Year  Deficiency  Sec. 6651(a)(1)  Sec. 6651(a)(2) Sec. 6654(a)            
           1996  $2,175,165    $356,574.15      $396,193.50     $21,719.58            
               The only issue remaining for decision is whether petitioner            
          is liable for the additions to tax under section 6651(a)(1) and             
          (2) for 1996.  We hold that he is.                                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioner resided in Hartford City, Indiana (Hartford), at            
          the time the petition was filed.                                            
               Petitioner attended Purdue University from which he received           
          a B.S. degree in agricultural economics in 1967.  While enrolled            
          at Purdue University, petitioner took courses in economics,                 
          business management, and accounting.                                        
               After graduating from college, petitioner worked for approx-           
          imately 7-� years as a salesperson for College Life Insurance               
          Company (College Life) in Indianapolis, Indiana.                            
               While working for College Life, petitioner acquired and                
          operated an A&W drive-in restaurant.  Around 1975, petitioner               
          resigned from College Life and worked in the restaurant business            
          on a full-time basis.  He has remained in the restaurant business           
          to at least the date of the trial in this case.                             
               In 1981, petitioner opened a restaurant in Hartford, known             
          as Richard’s restaurant, which was part of a chain of restaurants           
          known by the same name.  Shortly thereafter, in 1983, petitioner            






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