- 5 - Procedure. For the sake of convenience, all dollar amounts are rounded to the nearest dollar. FINDINGS OF FACT Dr. Trowbridge and Life Center Dr. Trowbridge is a physician who has been practicing medicine since at least 1978. At the time the petition was filed in this case, Dr. Trowbridge resided in Harris County, Texas. Dr. Trowbridge is a calendar year taxpayer. Life Center is a business trust4 created by Dr. Trowbridge and a colleague on or around December 6, 1996, pursuant to a document styled “Contract and Declaration of Trust for Life Center Houston” (the trust agreement). The trust agreement purports to effect the transfer by Dr. Trowbridge of unspecified property to Life Center in exchange for trust certificates evidencing beneficial ownership of Life Center. Although the trust agreement does not identify any trustees by name, Dr. Trowbridge held himself out as the trustee of Life Center. Before the close of 1996, Dr. Trowbridge obtained an employer identification number for Life Center and opened a bank account in Life Center’s name (the Life Center bank account). 4 For purposes of this report, we assume (without deciding) that Life Center is a legally recognized entity under Texas law.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