Patricia Barranco - Page 8




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          reported taxable income and adjusted gross income as indicated              
          below, omitting certain amounts of gross income as a result of              
          Dr. Barranco’s tax evasion scheme and thereby giving rise to                
          additional tax due, as also indicated below:4                               
                                       Adjusted                                      
                           Taxable      Gross     Gross                               
                           Income       Income    Income         Additional           
               Tax Year    Reported     Reported    Omitted       Tax Due             
               1983        $5,678       *         $805,819       $303,565             
               1984        78,722       *         553,518        189,632              
               1985        32,678       *         643,356        257,847              
               1986        47,709       *         521,829        185,239              
               1987        8,293          $63,407 600,934        180,925              
               1988        6,932         49,881   467,012        106,855              
               1989        84,965         124,968 625,858        138,487              
               1990        100,375        146,371          593,846123,920              
               1991        –--           57,027   602,499        153,317              
               1992         248,397        290,978   464,142      53,938              
                           613,749        732,632*5,878,813       1,693,725           
               * For 1983-1986, there is no evidence in the record from which the adjusted
               gross income reported by petitioner and Dr. Barranco can be determined.
               Petitioner neither reviewed these joint income tax returns             
          nor questioned Dr. Barranco about any entries on them.                      
          V.  Dr. Barranco’s Guilty Plea and Incarceration                            
               In May 1995, Dr. Barranco pleaded guilty to conspiring to              
          defraud the Internal Revenue Service and evade taxes with respect           
          to his medical practice corporation for the years 1983 through              
          1992 and to willfully evading taxes on omitted taxable income in            
          excess of $1 million for the years 1987 through 1992.                       

               4 As far as the record reveals, on the Barrancos’ originally           
          filed individual income tax returns for the years at issue, Dr.             
          Barranco’s medical practice earnings were reported, apparently              
          incorrectly, on Schedule C, Profit or Loss From Business.  These            
          amounts of reported Schedule C earnings were apparently net of              
          the fraudulent deductions claimed on the corporate returns for              
          Dr. Barranco’s medical practice corporation.                                





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