Peter Wood - Page 3

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               (4) Is petitioner liable for an addition to tax under                  
          section 6651(a)(1) for each of the years at issue?  We hold that            
          he is.                                                                      
               (5) Is petitioner liable for an addition to tax under                  
          section 6654(a) for each of the years at issue?  We hold that he            
          is.                                                                         
                                  FINDINGS OF FACT                                    
               Most of the facts have been deemed established pursuant to             
          Rule 90(c) and pursuant to the Court’s Order under Rule 91(f)               
          dated May 8, 2003.                                                          
               At the time he filed the petition in this case, petitioner’s           
          mailing address was in Excelsior, Minnesota.                                
               Beginning in 1990 and continuing throughout each of the                
          years at issue, petitioner operated a sole proprietorship under             
          the name Native Skies.  (We shall refer to petitioner’s sole                
          proprietorship Native Skies as petitioner’s sole proprietorship.)           
          At all relevant times, including during each of the years at                
          issue, petitioner’s sole proprietorship was engaged in the                  
          business of selling jewelry and certain other items, such as                
          rugs.                                                                       
               On April 6, 1994, the Secretary of State of Minnesota                  
          (Secretary of State) issued a certificate of incorporation to a             
          corporation identified in that certificate as “Native Skies Inc.”           
          During the years at issue, Native Skies, Inc., was inactive.                






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