Wayne L. Patrick - Page 2

                                        - 2 -                                         

          Wayne's failure to include in gross income the distributions from           
          an individual retirement account (IRA).  Respondent determined              
          deficiencies and additions to tax as follows:                               
          Wayne L. Patrick--docket No. 26419-96:                                      
                                             Additions to Tax                         
                                             Sec.                Sec.                 
               Year      Deficiency          6651(a)(1)          6654                 
               1992      $221,831            $55,458        $9,679                    
               1993      11,647              2,912          488                       
               1994      9,248               2,312          476                       
          Brian J. Patrick--docket No. 26420-96:                                      
                                             Additions to Tax                         
                                             Sec.                Sec.                 
               Year      Deficiency          6651(a)(1)          6654                 
               1992      $53,128             $13,157        $2,294                    
               1993      5,701               1,425          239                       
               1994      7,421          1,855               382                       


          Petitioners separately petitioned the Court on December 10, 1996,           
          to redetermine respondent's determinations.  On October 7, 1997,            
          the cases were consolidated for trial, briefing, and opinion.               
               Following concessions, we must decide:                                 
               1.  Whether the money each petitioner received from Erie               
          Industries, Inc. Employees' Profit Sharing Plan (the Plan) is               
          includable in his gross income.  We hold that it is.                        
               2.  Whether the money Wayne received from his IRA is                   
          includable in his gross income for 1993 and 1994.  We hold it is.           







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011