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EDWARDS v. COMMISSIONER

Docket No. 34900-87.

57 T.C.M. 1217 (1989)

T.C. Memo. 1989-409

Roy G. Edwards and Deborah S. Edwards v. Commissioner.

United States Tax Court.

Filed August 9, 1989.

Attorney(s) appearing for the Case

Matthew E. Bates, 125 S. Elm St., Greensboro, N.C., for the petitioners. Ross A. Rowley, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

By statutory notice dated August 3, 1987, respondent determined a deficiency in petitioners' 1984 Federal income tax in the amount of $7,171. The issue is whether lump-sum distributions from qualified pension and profit-sharing plans received by petitioner Deborah Edwards1 are eligible for 10-year forward averaging pursuant to section 402(e)(1).2

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