Eddie Lee Williams - Page 2

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          adopts the opinion of the Special Trial Judge, as set forth                 
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               DINAN, Special Trial Judge:  For the taxable years 1989 and            
          1990, respondent determined deficiencies in petitioner’s Federal            
          income taxes of $37,806 and $2,579, section 6651(a)(1) additions            
          to tax of $9,452 and $516, and section 6654(a) additions to tax             
          of $2,557 and $170.                                                         
               The issues for decision are:  (1) Whether petitioner                   
          received unreported income from cocaine sales in the amounts                
          determined by respondent and, if so, whether this income is                 
          subject to Federal income taxation, and (2) whether petitioner is           
          liable for the additions to tax for failure to file timely                  
          returns and for failure to make estimated income tax payments.              
               Some of the facts have been deemed stipulated pursuant to              
          Rule 91(f) and are so found.  These stipulations of fact and the            
          attached exhibits are incorporated herein by this reference.  On            
          the date the petition was filed in this case petitioner resided             
          in the Federal Correctional Institution at El Reno, Oklahoma.               
               During the years in issue, petitioner resided in Ardmore,              
          Oklahoma and was married to Sherry L. Williams.  Petitioner filed           

          Rule references are to the Tax Court Rules of Practice and                  

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Last modified: May 25, 2011