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received on December 3, 1996. On page 2 of Dr. Trowbridge’s 1993
Form 1040, he reported tax of $92,494 but stated: “SEE ATTACHED
DISCLAIMER STATEMENT-–ADMITTED TAX LIABILITY IS ZERO”. The
attached disclaimer statement (the 1993 disclaimer) reads in part
as follows:
The assessment and payment of income taxes is voluntary
* * * John respectfully declines to volunteer
concerning assessment and payment of any tax balance
due on the return or any redetermination of said tax.
Be it known that we, separately and together,
therefore, deny tax liability and do not admit that the
stated amount of tax on return, as calculated solely by
reference to provided tables, is due and collectible.
The tax return read as a whole shows no amount as being
the tax and shows the tax to be zero and zero is the
starting point in determining a deficiency or any other
action involving this return. * * *
John has provided payment in the amount of $1,000 as a
voluntary contribution.
The 1993 disclaimer is signed by Dr. Trowbridge and “Acknowledged
in full agreement” by Ms. Martin.
Respondent determined a deficiency in Dr. Trowbridge’s tax
for 1993 of $83,478.
1994 Form 1040
On January 16, 1997, Dr. Trowbridge mailed to the IRS a Form
1040, U.S. Individual Income Tax Return 1994 (Dr. Trowbridge’s
1994 Form 1040), which the IRS received on January 21, 1997. On
page 2 of Dr. Trowbridge’s 1994 Form 1040, he reported tax of
$170,144 but stated: “SEE ATTACHED DISCLAIMER STATEMENT-–ADMITTED
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