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stock investments. On November 28, 1999, respondent prepared a
substitute for return for petitioner for that year. On March 27,
2000, petitioner mailed Form 1040, U.S. Individual Income Tax
Return, for taxable year 1996 to the Internal Revenue Service
Center in Cincinnati, Ohio. Respondent received that return on
March 31, 2000. In the return that petitioner filed for 1996,
petitioner reported total income on page 1, line 22, in the
amount of $2,295,370 and adjusted gross income on page 1, line
31, in the amount of $2,290,890. Prior to the application of
$4,376 of prepayment withholding credits and $587,491.31 of
estimated tax payment credits, petitioner has a deficiency in tax
for taxable year 1996 in the amount of $632,750. After applica-
tion of those prepayment credits, petitioner underpaid his tax
for taxable year 1996 in the amount of $40,882.69.
Petitioner filed a return for 1997 around mid-April 2000.
As of October 23, 2000, the date of the trial in this case,
petitioner had not filed his returns for 1998 and 1999.
Petitioner, without any assistance from anyone, prepared the
returns for his taxable years 1993 through 1997 that he filed
with respondent in 2000. Petitioner fully understands that he is
required to file timely a return and to pay timely the tax that
is due with respect to any such return.
Throughout the period 1983 to the time of the trial in this
case, petitioner timely made estimated tax payments that he
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