Theodore A. Pride - Page 2

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          that the Internal Revenue Service (IRS) collected moneys from               
          third parties who had assets belonging to his professional                  
          corporation and that excess collections were or should have been            
          applied to his personal tax liabilities.  Unless otherwise                  
          indicated, all section references are to the Internal Revenue               
          Code in effect for the years in issue.                                      
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Philadelphia, Pennsylvania, at the time               
          that he filed his petition.                                                 
               On or about November 7, 1989, petitioner stipulated to a               
          decision in this Court for his taxable years 1978 through 1983 as           
                    ORDERED and DECIDED:  That there are deficiencies                 
               in income tax due from the petitioner for the taxable                  
               years 1978, 1979, 1980, 1981 and 1982 in the amounts of                
               $978.00, $535.00, $6,323.00, $4,775.00 and $4,592.00,                  
               The decision also provided that there was an addition to tax           
          due from petitioner for 1981 under section 6651(a)(1) in the                
          amount of $1,411.  As of the time that the notice of lien                   
          involved in this case was filed, the deficiencies for 1978 and              
          1979 had been paid.  The balances due from petitioner for 1980,             
          1981, and 1982 were $15,853.85, $14,267.46, and $9,422.95,                  

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