- 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