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Petitioners object to the default motions principally on the
ground that each had withdrawn his or her petition (by the
motions to dismiss, which we had denied).
We have no doubt that petitioners had knowledge of the call
of these cases on December 3, 2001, and the recall of the cases
on December 4 and 7, 2001. We assume that petitioners failed to
answer those calls because they no longer wished to continue
their cases in this Court; that is the position taken by them in
the motions to dismiss (which we denied). We shall, therefore,
hold each of them in default. We shall enter a decision against
each petitioner that includes the full amount of the deficiencies
in tax and additions to tax that are the subject of the default
motions. That is appropriate since respondent had denied all
material allegations of fact set forth in the petitions in
support of the assignments of error and none of petitioners’
filings has otherwise convinced us that respondent in any way
erred in determining the deficiencies in tax and additions to tax
that are the subject of the default motions.
II. Remaining Additions to Tax
A. Introduction
Respondent proceeded to trial on the issues of the additions
to tax determined against Dr. Trowbridge for the years 1994 and
1995 and the additions to tax determined against Ms. Martin for
the years 1991 through 1995 (collectively, the remaining
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