Lawrence Robert Clifton-Bligh - Page 2

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          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
               After concessions,1 the issue for decision is whether                  
          petitioner is entitled to deductions and/or losses in amounts               
          greater than those allowed by respondent for the years in issue.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The deemed admissions, the stipulation of facts, and the attached           
          exhibits are incorporated herein by this reference.  At the time            
          he filed the petition, petitioner resided in Pound Ridge, New               
               During the years in issue, petitioner was a senior executive           
          of a merchant bank in Australia, president of a New York                    
          investment company, and an underwriter with Lloyd’s of London               

               1  Petitioner admitted and stipulated the income amounts               
          determined by respondent in the notice of deficiency.  See Rule             
          91.  The only variation is that the notice of deficiency                    
          determined petitioner realized pension income of $8,300 from                
          Fidelity and $22,410 from Smith Barney in 1994, whereas                     
          petitioner admitted, and petitioner and respondent stipulated,              
          petitioner realized this income in 1992.  Accordingly, a Rule 155           
          computation will be necessary.                                              
               Petitioner is deemed to have admitted that he is liable for            
          the additions to tax pursuant to secs. 6651(a)(1) and 6654 for              
          the years in issue.  Rule 91(f).                                            

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