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REINHARDT v. COMMISSIONER

Docket No. 14506-83.

85 T.C. 511 (1985)

JULES REINHARDT AND MARILYN D. REINHARDT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 30, 1985.

Attorney(s) appearing for the Case

Gregory K. Wise, for the petitioners.

Timothy S. Murphy, for the respondent.

OPINION

PARKER, Judge:

Respondent determined a deficiency in petitioners' 1979 Federal income tax in the amount of $43,671. The issue for decision is whether petitioners properly reported a distribution from qualified profit-sharing and pension plans under the 10-year averaging method provided by section 402(e)(1).1 Resolution of this issue depends on whether petitioner Jules Reinhardt's change of employment status from...

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