Eddie Lee Williams - Page 3

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          joint Federal income tax returns with his wife for the years                
          1986, 1987, and 1988, reporting gross income of $1,637, $6,798,             
          and $2,068, respectively.  The gross income reported on these               
          returns consisted solely of wages earned by petitioner’s wife.              
          Petitioner’s return for 1988 reflected zero income tax liability.           
               In February 1991, petitioner and several codefendants were             
          indicted under Federal law on 27 counts of drug offenses and                
          money laundering.  In June 1991, petitioner was convicted on 17             
          counts of the indictment and received a 30-year sentence of                 
          imprisonment.  Petitioner’s conviction reflects that, during 1989           
          and through April 1990, petitioner managed a continuing criminal            
          enterprise involving cocaine distribution, and that he received             
          and spent the proceeds of that enterprise.  Petitioner kept no              
          records of his income or expenses with respect to his purchase              
          and sale of cocaine during the years in issue.                              
               Petitioner did not file Federal income tax returns for                 
          taxable years 1989 and 1990.  After petitioner was convicted, he            
          was issued a notice of jeopardy assessment followed by a                    
          statutory notice of deficiency for 1989 and 1990.  In the notice            
          of deficiency, respondent determined petitioner’s tax liabilities           
          and deficiencies, based upon a filing status of married filing              
          separately, as follows:                                                     

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