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Sabrina L. Trowbridge (Ms. Martin1)
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1991 $6,197 $105 --
1992 8,740 1,198 $190
1993 74,612 18,653 3,126
1994 102,588 25,647 5,323
1995 111,266 27,679 6,000
Respondent has moved that petitioners be held in default
with respect to the deficiencies in tax determined against them
for all years and that Dr. Trowbridge be held in default with
respect to the additions to tax determined against him for 1991,
1992, and 1993. In addition, respondent has moved for partial
summary judgment in his favor with respect to the additions to
tax determined against Dr. Trowbridge for 1994 and 1995 and the
additions to tax determined against Ms. Martin for all years.
Respondent has also asked the Court to impose a penalty on each
petitioner under section 6673(a)(1) in the amount of $25,000.
For the reasons that follow, we shall grant respondent’s motions
for default judgment, sustain (with minor adjustments) the
additions to tax that are the subject of his motions for partial
summary judgment, and impose penalties under section 6673(a)(1).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
1 During the years at issue, Ms. Martin was married to Dr.
Trowbridge and was known as Sabrina L. Trowbridge. She is now
known as Sabrina Martin, and we shall refer to her as Ms. Martin
for all purposes in this report.
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Last modified: May 25, 2011