John P. Trowbridge, Life Center Houston Business Trust, John P. Trowbridge, Trustee, and Life Choices Business Trust, John P. Trowbridge, Trustee - Page 20

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          Accordingly, we find that there is an additional deficiency in              
          tax with respect to Dr. Trowbridge for 1996 based on gross                  
          business receipts of $1,632,140 for that year.                              
          V.  Additions to Tax                                                        
               A.  Statutory Provisions                                               
                    1.  Section 6651(a)(1)                                            
               Section 6651(a)(1) provides for an addition to tax in the              
          event a taxpayer fails to file a timely return (determined with             
          regard to any extension of time for filing), unless it is shown             
          that such failure is due to reasonable cause and not due to                 
          willful neglect.  The amount of the addition is equal to 5                  
          percent of the amount required to be shown as tax on the                    
          delinquent return for each month or fraction thereof during                 
          which the return remains delinquent, up to a maximum addition of            
          25 percent for returns more than 4 months delinquent.  For these            
          purposes, the amount required to be shown as tax on the return is           
          reduced by any timely payments of the tax16 and any credits which           
          may be claimed on the return.  Sec. 6651(b)(1).                             
                    2.  Section 6654                                                  
               Section 6654 provides for an addition to tax (in the form of           
          an interest charge) in the event of an underpayment of a required           
          installment of individual estimated tax.  As relevant to this               


               16  In general, payment of income tax is due on the due date           
          of the corresponding return, determined without regard to any               
          filing extensions.  Sec. 6151(a).                                           




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