Daniel J. Ford - Page 2

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and the accompanying exhibits are                      
          incorporated herein by this reference.                                      
               At the time of the filing of the petition, petitioner                  
          resided in Columbia, Maryland.  Petitioner filed Federal income             
          tax returns for 1990, 1991, 1994, 1995, 1996, 1997, 1998, and               
          2002.  Because insufficient taxes were withheld or paid with                
          respect to those returns, respondent assessed the following                 
          income tax liabilities:1                                                    


               1Petitioner does not dispute the underlying liabilities that           
          are the subject of the instant proceeding.  Those liabilities               
          were set forth in respondent’s Form 4340, Certificate of                    
          Assessments and Payments, for each of the taxable years in issue.           
          Respondent appears to have computed these liabilities by                    
          subtracting petitioner’s payments, withholding, and excess FICA             
          from the sum of petitioner’s income tax, estimated tax penalty,             
          late filing penalty, failure to pay penalty, interest, and                  
          fees/collection costs.  We note that respondent’s trial                     
          memorandum reported the liability for petitioner’s 1996 taxable             
          year as $6,648 rather than $6,448.  The record demonstrates that            
          additional interest, penalties, and additions to tax accumulated            
          subsequent to the initial assessments.  As of June 2, 2004,                 
          respondent determined that petitioner owed aggregate interest               
          of $56,540 and penalties/additions to tax of $13,754.57.                    

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