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.
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