- 6 - 09/30/92 3,000 10/31/92 2,000 12/31/92 5,300 Total 1207,300 1 Respondent's notice of deficiency incorrectly identifies the total amount of the transfers as $205,300, and respondent's deficiency determination is based on that figure. Respondent does not seek an increase in the deficiency determination. Most, if not all, of the notes were prepared after the corresponding transfers, and the notes dated September 30, October 31, and December 31, 1992, were not signed. Brian did not report any income with respect to these transfers. In 1992 and 1993, Wayne received $624,000 and $17,000, respectively, from the Plan.5 The following promissory notes were prepared to evidence the transfers of the underlying amounts: Date on Note Amount of Note 01/31/92 $190,000 02/28/92 15,000 03/31/92 66,000 04/30/92 75,000 05/31/92 115,000 06/30/92 10,000 07/31/92 73,000 08/31/92 35,000 10/31/92 35,000 12/31/92 10,000 Total 624,000 02/28/93 17,000 5 At that time, Wayne had not attained either retirement age under the Plan or the age of 59-1/2. See sec. 72(t)(2).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