John Parks Trowbridge - Page 22

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               Based on the foregoing, we conclude that respondent                    
          established a prima facie case that the determination of 25-                
          percent additions to tax under section 6651(a)(1) with respect to           
          Dr. Trowbridge for the years 1994 and 1995, and with respect to             
          Ms. Martin for the years 1991-95, is appropriate, thereby                   
          satisfying section 7491(c).  In the absence of any evidence                 
          refuting that prima facie case (such as reasonable cause or lack            
          of willful neglect on the part of either petitioner), we conclude           
          that petitioners are liable for such additions to tax.  Except as           
          noted below,12 we also accept respondent’s computation of the               
          amounts of those additions as set forth in the notices of                   
                    3.  Respondent’s Section 6654 Determinations                      
               As relevant to his section 6654 determinations, respondent             
          introduced into evidence Dr. Trowbridge’s invalid return for 1993           
          in addition to the evidence of invalid and nonexistent returns              
          discussed above in the context of his section 6651(a)(1)                    
          determinations.  Respondent also produced evidence that, aside              

          property State).  Respondent also properly credited Ms. Martin              
          with her earned income credit for 1995.  See sec. 6651(b)(1).               
               12  Respondent inexplicably based his 1992 sec. 6651(a)(1)             
          computation for Ms. Martin on tax of $8,764 rather than the                 
          $8,740 amount of tax that appears elsewhere in the notice of                
          deficiency issued to her.  The correct amount of such addition              
          shall be the subject of a Rule 155 computation.                             

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