- 23 -
part of Dr. Trowbridge), we conclude that Dr. Trowbridge is
liable for 25-percent additions to tax under section 6651(a)(1)
with respect to his 1996 and 1997 taxable years.19
Respondent also produced evidence that Dr. Trowbridge did
not make any timely payments in respect of his 1996 and 1997
income taxes and did not claim any tax credits for those years.
Accordingly, the 25-percent additions to tax for which Dr.
Trowbridge is liable under section 6651(a)(1) apply to the full
amount of tax required to be shown on his respective 1996 and
1997 returns.20 See sec. 6651(b)(1).
2. Respondent’s Section 6654 Determinations21
In addition to introducing at trial Dr. Trowbridge’s
(invalid) initial 1996 and 1997 Forms 1040, respondent submitted
19 We note that, in computing the amount of the 1997
addition to tax, respondent incorrectly applied a rate of 22.5
percent rather than 25 percent. See supra note 1.
20 The amount of tax required to be shown on Dr.
Trowbridge’s 1996 return is equal to the initial 1996 deficiency
($146,847) plus the additional 1996 deficiency, the latter amount
to be determined under Rule 155 in accordance with part IV of
this report. The amount of tax required to be shown on Dr.
Trowbridge’s 1997 return is equal to the 1997 deficiency
($211,508).
21 Respondent applied the provisions of sec. 6654 without
regard to the amounts shown as tax on the revised 1996 and 1997
Forms 1040 attached by Dr. Trowbridge to the 1996 and 1997 Forms
1040X submitted by him to the IRS in January 2000. Petitioners
did not assign error to that aspect of respondent’s
determinations. We shall not, therefore, decide whether the
revised 1996 and 1997 Forms 1040 are valid returns or otherwise
take them into account for purposes of determining the
application of sec. 6654.
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