John P. Trowbridge, Life Center Houston Business Trust, John P. Trowbridge, Trustee, and Life Choices Business Trust, John P. Trowbridge, Trustee - Page 5

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          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.            





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