T.C. Memo. 2003-165 UNITED STATES TAX COURT JOHN P. TROWBRIDGE, LIFE CENTER HOUSTON BUSINESS TRUST, JOHN P. TROWBRIDGE, TRUSTEE, AND LIFE CHOICES BUSINESS TRUST, JOHN P. TROWBRIDGE, TRUSTEE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 750-01. Filed June 4, 2003. R determined deficiencies in, and additions to, tax with respect to P John P. Trowbridge (Dr. Trowbridge) for 1996 and 1997. As a protective measure, R also determined deficiencies in, and additions to, tax with respect to P Life Center Houston Business Trust (Life Center) for 1996 and 1997 and P Life Choices Business Trust (Life Choices) for 1997. Ps filed a petition for redetermination but failed to appear at trial. R moved for default judgment against Dr. Trowbridge with respect to deficiencies in tax for 1996 and 1997 in the amounts of $146,847 and $211,508, respectively. R proceeded to trial on the issues of (1) an additional deficiency in tax (first raised in R’s amendment to answer) with respect to Dr. Trowbridge for 1996 based on additional gross business receipts for that year, and (2) the additions to tax asserted against Dr. Trowbridge for 1996 and 1997.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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