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 on
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