John Parks Trowbridge - Page 14

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          trial, petitioners failed to appear.  Counsel for respondent                
          appeared and announced ready for trial.  The deputy trial clerk             
          reported that he had left messages for both petitioners as to the           
          date and time of the trial.  Respondent moved to dismiss for                
          default in both cases and the Court set those motions for a                 
          hearing on Friday, December 7, 2001.  The Court instructed                  
          respondent’s counsel to arrange personal service of the                     
          petitioners, to inform them of the hearing.  The Court heard one            
          witness in support of respondent’s case.                                    
               On Friday, December 7, 2001, the cases were recalled from              
          the calendar for a hearing on respondent’s motions to dismiss for           
          default.  Petitioners failed to appear.  Counsel for respondent             
          appeared and announced ready for the hearing.  Internal Revenue             
          Agent Marilyn MacIness testified that she had served each                   
          petitioner personally with notice of the hearing.  The Court took           
          respondent’s motions to dismiss for default under advisement.               


                                       OPINION                                        
          I.  Motions To Dismiss for Default                                          
               Respondent has moved (1) that Dr. Trowbridge be held in                
          default with respect to, and that a decision be entered in                  
          respondent’s favor in the full amount of, the deficiencies in tax           
          determined by respondent against Dr. Trowbridge for the years               
          1991 through 1995 and the additions to tax determined by                    






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