(petitioner owned various businesses that provided tax return preparation services and leased cars and household items; petitioner also owned farmland that was sharecropped by local farmer on which petitioner also attempted to raise catfish in pond; due to medical condition, petitioner unable to keep up with various businesses and petitioner's wife took over financial and business duties, but made numerous errors; professional tax preparer prepared returns based on faulty information supplied by petitioner's wife; upon audit, IRS determined substantial underpayment of tax for numerous years and asserted fraud penalties; court determined that petitioner reasonably relied on wife to keep accurate books and did not willfully attempt to conceal income and fraudulent intent not present; IRS not entitled to extended statute of limitations under I.R.C. Sec. 6501(c)(1) when fraud involved; determinations and adjustments for tax years at issue time-barred).