- 18 - valid return. It follows that respondent is not barred by the statute of limitations on assessment with respect to Dr. Trowbridge’s 1996 taxable year.14 See, e.g., Jarvis v. Commissioner, 78 T.C. 646, 655 (1982). IV. Additional 1996 Deficiency In the notice of deficiency, respondent determined that the medical practice generated gross receipts of $1,062,676 in 1996. Respondent based that determination on an analysis of the deposit activity with respect to the two bank accounts styled “John Parks Trowbridge MD” and the Life Center bank account (collectively, the medical practice bank accounts). Respondent subsequently received daily cash analysis reports and daily practice summaries with respect to the medical practice for 1996 as the result of the enforcement of a summons issued to Dr. Trowbridge. Those reports, introduced into evidence at trial, show that the medical practice generated gross receipts of $1,632,140 in 1996.15 14 Even if the revised 1996 Form 1040 that Dr. Trowbridge submitted in January 2000 constitutes a valid return (an issue respondent does not explicitly address and we do not decide), respondent issued the notice of deficiency on Oct. 20, 2000, well within the 3-year period of limitations on assessment for 1996 that would have commenced on the date of such filing. See secs. 6503(a), 6213(a) (issuance of a valid notice of deficiency suspends the running of the period of limitations on assessment during the pendency of any ensuing proceedings originating in this Court). 15 We have adjusted respondent’s computation of 1996 medical practice gross receipts ($1,632,423) downward by $283 to reflect a patient refund recorded on the cash analysis report for (continued...)Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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