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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...)
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