DUPREE, Senior District Judge:
In this appeal from the United States Tax Court the taxpayer, Deborah Edwards, challenges the court's ruling that she was not eligible for ten-year forward averaging pursuant to Internal Revenue Code of 1954, Section 402(e)(1), with respect to the lump sum distribution to her of the proceeds of certain pension and profit-sharing plans when they were terminated by her employer. Finding no error in the ruling, we affirm.
I.
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