- 2 -
1. Held: R’s motion for default judgment is
granted.
2. Held, further, R is not barred by the statute
of limitations on assessment with respect to Dr.
Trowbridge’s 1996 taxable year.
3. Held, further, there is an additional
deficiency in tax with respect to Dr. Trowbridge for
1996 based on gross business receipts of $1,632,140 for
that year.
4. Held, further, Dr. Trowbridge is liable for
additions to tax under secs. 6651(a)(1) and 6654,
I.R.C., with respect to his 1996 and 1997 taxable
years.
5. Held, further, Dr. Trowbridge is liable for a
penalty under sec. 6673, I.R.C., in the amount of
$25,000.
John Parks Trowbridge, pro se.
M. Kathryn Bellis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated October 20,
2000 (the notice of deficiency), respondent determined
deficiencies in, and additions to, Federal income tax with
respect to petitioner John P. Trowbridge (Dr. Trowbridge) as
follows:1
1 Respondent also asserted additions to tax under sec.
6651(a)(2) in amounts to be determined. We interpret
respondent’s posttrial brief as conceding those additions to tax
in the event we find that the 1996 and 1997 Forms 1040 received
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011