John P. Trowbridge, Life Center Houston Business Trust, John P. Trowbridge, Trustee, and Life Choices Business Trust, John P. Trowbridge, Trustee - Page 23

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          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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