Lee G. Gale - Page 4




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               (7) Whether petitioner failed to report various items of               
          income on his 1992, 1993, and 1994 individual income tax returns.           
          We hold that he did, although in lesser amounts than determined             
          by respondent.                                                              
               (8) Whether petitioner is liable for additions to tax and              
          accuracy-related penalties under sections 6651(a)(1) and 6662(a),           
          respectively.  We hold that he is liable for both, although in              
          lesser amounts than determined by respondent.                               
               Respondent’s additional adjustments to petitioner’s                    
          exemptions, itemized deductions, self-employment taxes, and                 
          taxable Social Security benefits are computational and will be              
          resolved by our holdings on the foregoing issues.                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, first through third supplemental                  
          stipulations of facts, associated exhibits, and oral stipulations           
          are incorporated by this reference.  Petitioner resided in                  
          Newport Beach, California, at the times he filed the petitions in           
          these cases, which have been consolidated for the purposes of               
          trial, briefing, and opinion.                                               
          Petitioner’s Business and Estate Planning Activities                        
               Over the years, petitioner engaged in several business                 
          activities, including cement hauling, retail gasoline sales,                
          residential real estate rentals, and truck and equipment rentals.           






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