Charles Jerome Posnanski - Page 3

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          including the years in issue.  Petitioner was active in the day-            
          to-day operations of the Bank and had access to all the computer            
          programs utilized by the Bank.  During the years in issue,                  
          petitioner and his former wife, Lois Posnanski, maintained two              
          personal, interest-bearing bank accounts at the Bank.  For each             
          of the years in issue, petitioner accrued and was paid interest             
          income on these personal accounts in the following amounts:                 
                              Year              Amount                                
                              1989           $12,334.79                               
                              1990           11,116.45                                
                              1991           10,999.62                                
                              1992                9,320.28                            
                              1993                7,493.44                            
               Toward the end of each year in issue, petitioner accessed              
          the computer programs at the Bank and deleted information that              
          would cause his interest income to be included on the computer              
          disk sent to respondent for purposes of reporting interest paid.            
          Petitioner further caused Forms 1099-INT, Interest Income, not to           
          be filed with respondent reporting the actual interest income               
          earned on his personal account and other accounts for each year             
          in issue.  On his tax returns for the years in issue, petitioner            
          reported the following amounts of interest income:                          
                              Year                 Amount                             
                              1989                $785.00                             
                              1990                35.00                               
                              1991                118.14                              
                              1992                31.76                               
                              1993                65.62                               
          Petitioner signed tax returns for each of the years in issue with           

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