Hugh Powell Arvin - Page 4

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          Designs, Inc., during tax years 1997 and 1998.  Additionally,               
          respondent obtained copies of Forms W-2 issued by the                       
          International, Inc., which show that petitioner was paid $5,478,            
          $18,965, and $23,812 for tax years 1998, 1999, and 2000,                    
          respectively.  According to Forms 1099-G, Statement for                     
          Recipients of Certain Government Payments, petitioner also                  
          received unemployment compensation from the Commonwealth of                 
          Massachusetts during the 1998, 1999, and 2000 tax years of                  
          $1,212, $3,257, and $521, respectively.                                     
               On or about August 1, 1998, petitioner submitted to                    
          respondent a Form 1040, U.S. Individual Income Tax Return, for              
          1997.  Petitioner did not attach any Forms W-2 to the Form 1040.            
          Petitioner entered zeros on all lines of the income portion of              
          his Form 1040, specifically including those lines that report               
          wages, dividends, total income, and adjusted gross income.  He              
          also indicated that his taxable income and tax were zero.                   
          Petitioner claimed a refund of $1,886, the full amount of Federal           
          income tax that had been withheld from his wages by his                     
               Petitioner submitted to respondent a Form 1040 for 1998.               
          Petitioner did not attach to the return Forms W-2 or 1099-G.                
          Petitioner entered zeros on all lines of the income portion of              

               1The actual amount withheld by petitioner's employers was              

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