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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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Last modified: May 25, 2011