- 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).
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Last modified: May 25, 2011