Howard and Linda Levine - Page 3

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          petitioner sold insurance and alarm systems.  Petitioner does not           
          have a college degree.  During these same years, petitioner also            
          performed bookkeeping and tax return preparation services for his           
          own clients.                                                                
               On April 23, 1990, petitioner applied for an automobile                
          loan.  On the loan application, petitioner indicated that his               
          annual income was $120,000.                                                 
               During 1990 through 1993, petitioner did not maintain books            
          and records relating to any of his income-producing activities.             
               During 1975 through 1989, Mrs. Levine worked part-time in a            
          department store.                                                           
               For years prior to 1988, petitioners timely filed their                
          Federal income tax returns.                                                 
               For 1990 through 1993, petitioners did not timely file with            
          respondent their Federal income tax returns that were due, nor              
          did petitioners make any payments of estimated Federal income               
               In January of 1994, petitioner was contacted by respondent’s           
          revenue agent about petitioners’ unfiled 1988 through 1992                  
          Federal income tax returns.3                                                

          3  Respondent’s revenue agent who talked to petitioner in January           
          of 1994 testified herein that during that conversation petitioner           
          falsely stated that he already had filed his 1988 through 1992              
          Federal income tax returns.  Petitioner contends that the                   
          testimony of respondent’s revenue agent should be stricken and              
          excluded from the evidence herein.                                          

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