Charles H. Little III - Page 4

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          lots are not sold.  The entire park constitutes an economic unit.           
          Thus, if an investor is interested in purchasing a park, or if              
          the owner of an existing park desires to sell, real estate agents           
          such as petitioner typically would be used because of their                 
          experience in this segment of real estate.  Petitioner did not              
          own, develop, or manage such parks.  He was simply an agent in              
          what appears to be a niche in the field of real estate.                     
               A notice of deficiency was issued to petitioner for the year           
          2002.  At the time the notice of deficiency was issued, on June             
          8, 2004, petitioner had not filed a Federal income tax return for           
          the year 2002 (the year at issue).  Petitioner acknowledged that,           
          for several years during the 1990s, he had filed protester                  
          Federal income tax returns.  During these years, he was following           
          the advice of a lady who apparently specialized in filing                   
          protester returns and in handling correspondence received by her            
          clients (including petitioner) from the IRS regarding such                  
          returns.  Some of the returns filed by petitioner were “zero”               
          returns, on which each line on the return was filled in with a              
               Petitioner and his wife were also “devastated”, as he                  
          explained, over the loss of their daughter, who died unexpectedly           
          and for no known reason in 1994.  The daughter was not married              
          and had two young girls.  Prior to her death, she had placed one            
          of the girls for adoption, and, at her death, petitioner and his            

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