John P. Trowbridge, Life Center Houston Business Trust, John P. Trowbridge, Trustee, and Life Choices Business Trust, John P. Trowbridge, Trustee - Page 27

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         the disclaimers attached to his initial 1996 and 1997 Forms 1040,            
         the payment of income taxes is voluntary.  E.g., Woods v.                    
         Commissioner, 91 T.C. 88, 90 (1988).  Whatever legitimate                    
         arguments may underlie his assignments of error, Dr. Trowbridge              
         has emphasized frivolous arguments and, for that reason alone,               
         deserves to have a section 6673(a)(1) penalty imposed against                
         him.                                                                         
              We are also convinced by Dr. Trowbridge’s conduct that he               
         both instituted and maintained these proceedings for delay, which            
         is a separate basis for imposing a section 6673(a)(1) penalty.               
         We struck substantial portions of the petition.  His discovery               
         requests ran to hundreds of pages, and we granted respondent’s               
         motion for a protective order with respect thereto.                          
         Notwithstanding his active, indeed forceful, prosecution of this             
         case initially, Dr. Trowbridge abruptly changed course 2 weeks               
         before trial.  At that point, he attempted to withdraw the                   
         petition, asserting a jurisdictional challenge premised on his               
         disavowal of any commercial relationship with, and any enjoyment             
         of benefits from, the United States.  He refused to appear for               
         trial, despite notice thereof.  We interpret Dr. Trowbridge’s                
         actions in prosecuting (and not prosecuting) this case as                    
         evidence of his intent to delay these proceedings.                           
              There is a contemporaneous case in this Court involving Dr.             
         Trowbridge and his 1991-95 taxable years which involves conduct              






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