David E. Christensen - Page 2

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               The issues to be decided are:  (1) Whether petitioner failed           
          to report $78,491 in 1997 as income for Federal income tax                  
          purposes; (2) whether petitioner failed to substantiate his                 
          claimed Schedule C, Profit or Loss From Business, expenses for              
          1998, 1999, 2000, and 2001; (3) whether petitioner is liable for            
          additions to tax under section 6651(a)(1) for all years at issue;           
          and (4) whether petitioner is liable for accuracy-related                   
          penalties under section 6662 for 1998, 1999, 2000, and 2001.1               
                                  FINDINGS OF FACT                                    
               Petitioner resided in Glendora, California, at the time the            
          petitions were filed.                                                       
               During the years at issue, petitioner was employed by                  
          various companies as a systems engineer.  The work he performed             
          as a systems engineer was done out of his home.  In addition, he            
          started his own company in 1998 called Connect4Less.  In this               
          capacity, he repaired computers, programmed computers, and                  
          developed Web sites for individuals.  Petitioner also operated              
          Connect4Less out of his home.                                               
               Petitioner did not file a Federal income tax return for                
          1997.  He did not make estimated tax payments for 1997.                     
          Petitioner did not file his 1998, 1999, 2000, and 2001 Federal              

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code, as amended.  All Rule references are             
          to the Tax Court Rules of Practice and Procedure, unless                    
          otherwise indicated.  Amounts are rounded to the nearest dollar.            

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