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with respect to each of petitioner’s taxable years 1987 and 1990.
We hold that, except for respondent’s concession with respect to
petitioner’s taxable year 1987, respondent did.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found with
one exception stated herein.
Petitioner resided in Palos Verdes Estates, California, at
the time he filed the petition in this case.
On August 15, 1985, April 15, 1986, and October 11, 1988,
respectively, petitioner filed Forms 1040, U.S. Individual Income
Tax Return (Form 1040), for his taxable years 1984 (1984 return),
1985 (1985 return), and 1986 (1986 return). As reflected in Form
4340, Certificate of Assessments, Payments, and Other Specified
Matters (Form 4340), with respect to each of petitioner’s taxable
years 1984 and 1985 and in respondent’s complete statement of
petitioner’s account with respect to his taxable year 1986
(respondent’s statement of petitioner’s account with respect to
his taxable year 1986),1 respondent assessed on various dates the
following amounts of Federal income tax (tax), additions to tax,
and interest:
1We attach hereto as Appendix A, Appendix B, and Appendix C,
respectively, and incorporate herein by this reference, the
information reflected in Form 4340 with respect to each of
petitioner’s taxable years 1984 and 1985 and respondent’s state-
ment of petitioner’s account with respect to his taxable year
1986.
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