§66633

o report interest income of $3,069 in 1990, $3,153 in 1991, and $8,784 in 1992; (3) whether petitioner is entitled to claim a loss of $31,000 in 1991 from the sale of one of his farms; (4) whether petitioner had farm expenses in amounts greater than allowed by respondent;2 (5) whether petitioner is liable for additions to tax for fraud pursuant to section 66633 for each of the years in issue; and (6) whether the assessments for 1990, 1991, and 1992 are barred by the statute of limitations.

Whether petitioner is liable for the fraud penalty under section 66633 for 1995, 1998, and 1999.