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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.
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