Wayne L. Patrick - Page 6

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                    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).                




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