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GORDON v. COMMISSIONER

Docket No. 20256-85.

88 T.C. 630 (1987)

GEORGE H. GORDON AND SUZANNE GORDON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 17, 1987.

Attorney(s) appearing for the Case

Steven L. Sablowsky, for the petitioners.

Raymond N. McCabe, for the respondent.

OPINION

NIMS, Judge:

Respondent determined a deficiency in petitioners' 1980 Federal income tax in the amount of $19,626. After a concession by petitioners the only issue remaining for decision is whether petitioners may exclude, under section 105(c),1 a $102,098 lump-sum distribution to petitioner George H. Gordon (sometimes herein called petitioner or Gordon) from the United Baking Co. Profit-Sharing Plan and Trust....

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