John Parks Trowbridge - Page 3

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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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