Virginia L. Dimon - Page 3

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          Other facts have been deemed admitted pursuant to Rule 90(c).               
               At the time they filed the respective petitions in these               
          cases, Ms. Dimon and Mr. Dimon, who were married throughout the             
          entire taxable year 1996, resided in Irvine, California.                    
               Neither Ms. Dimon nor Mr. Dimon filed a tax return (return)            
          for taxable year 1996.  On January 10, 2002, petitioners provided           
          to respondent an original, signed Form 1040, U.S. Individual                
          Income Tax Return, for 1996 (unfiled Form 1040).  Petitioners               
          included Schedule C, Profit or Loss From Business (Schedule C),             
          in that unfiled Form 1040.  In Schedule C of the unfiled Form               
          1040 for 1996, petitioners indicated that during 1996 Mr. Dimon             
          was the proprietor of an executive recruiting business.  Schedule           
          C of the unfiled Form 1040 for 1996 showed gross receipts of                
          $127,970 and claimed expenses of $57,064.                                   
               Neither Ms. Dimon nor Mr. Dimon made any estimated or other            
          tax payments for 1996 except for $94 which was withheld from Ms.            
          Dimon’s wages.                                                              
               During 1996, Mr. Dimon received $127,970 in nonemployee                

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