Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioner's Federal income tax for the taxable year 1971 in the amount of $22,357.62. The sole issue presented for our decision is whether a lumpsum distribution to petitioner from a qualified employees' trust was made on account of his "separation from the service" so that the amount of such distribution is long-term capital gain within the meaning of section...
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