T.C. Memo. 1998-30 UNITED STATES TAX COURT WAYNE L. PATRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent BRIAN J. PATRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 26419-96, 26420-96. Filed January 26, 1998. Joseph Falcone and Brian H. Rolfe, for petitioners. Mark L. Hulse and Laurence D. Ziegler, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: On October 4, 1996, respondent issued separate notices of deficiency to Brian J. Patrick (Brian) and Wayne L. Patrick (Wayne) based on their failure to include in gross income the distributions from a qualified profit-sharing plan and onPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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