- 3 - 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 hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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