Estate of James R. Tobias, Deceased, V. Pauline Tobias, Executrix, and Verna P. Tobias, Surviving Spouse - Page 3




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             Pennsylvania, at the time the instant petition was filed on              
             her behalf.  The decedent and his wife filed joint Federal               
             income tax returns for each of the years in issue in their               
             case, 1991 and 1993.  In the notice of deficiency issued                 
             to them, respondent determined income tax deficiencies of                
             $10,587 and $5,674, respectively.                                        
                  The second brother, Mr. Darwin R. Tobias, Sr., and his              
             wife, Ms. Shirley I. Tobias, filed joint Federal income tax              
             returns for each of the years in issue in their case, 1990,              
             1991, and 1993.  In the notice of deficiency issued to                   
             them, respondent determined income tax deficiencies of                   
             $12,371, $9,841, and $6,055, respectively.  Darwin and his               
             wife resided in Halifax, Pennsylvania, when the instant                  
             petition was filed on their behalf.                                      
                  Circa 1960, James and Darwin orally agreed to operate               
             an animal farm business as partners, but they never reduced              
             their agreement to writing.  Their agreement was general                 
             and did not include specific terms regarding how they would              
             operate the business.  For example, they never agreed to a               
             specific division of labor.  Over the years James spent                  
             a disproportionately greater amount of time and effort                   
             developing and expanding the business than his brother,                  
             Darwin.  Each of the brothers had independent means of                   
             earning a living, and neither received a salary for his                  






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