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Procedure. For the sake of convenience, all dollar amounts are
rounded to the nearest dollar.
FINDINGS OF FACT
Preliminary Facts
At the time the petitions were filed in these cases, each
petitioner resided in Harris County, Texas.
Petitioners were married to each other during the years at
issue but filed separate returns for those years.
Dr. Trowbridge is a physician, and Ms. Martin is a nurse and
administrative assistant who, during the years at issue, was
sometimes employed by Dr. Trowbridge’s professional corporation.
Both petitioners are calendar year taxpayers.
Respondent’s examination with respect to Dr. Trowbridge’s
1991, 1992, and 1993 taxable years commenced before 1998.
Respondent’s examinations with respect to Dr. Trowbridge’s 1994
and 1995 taxable years and Ms. Martin’s 1991 through 1995 taxable
years commenced after July 1998.
Dr. Trowbridge’s 1993, 1994, and 1995 Forms 1040
1993 Form 10402
On November 26, 1996, Dr. Trowbridge mailed to the Internal
Revenue Service (IRS) a Form 1040, U.S. Individual Income Tax
Return 1993 (Dr. Trowbridge’s 1993 Form 1040), which the IRS
2 As discussed infra, Dr. Trowbridge’s 1993 Form 1040 is
relevant to the determination of whether he is liable for the
sec. 6654 addition to tax with respect to his 1994 taxable year.
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