HALL v. COMMISSIONER

Docket No. 17928-89.

61 T.C.M. 2236 (1991)

T.C. Memo. 1991-133

Franklin O. Hall and Syble L. Hall v. Commissioner.

United States Tax Court.

Filed March 25, 1991.


Attorney(s) appearing for the Case

Thomas R. Buckner, 1755 Kirby Pkwy., Memphis, Tenn., for the petitioners. Amy Dyar Seals, for the respondent.


Memorandum Opinion

SHIELDS, Judge:

In a deficiency notice dated April 17, 1989, respondent determined a deficiency in petitioners Federal income tax for 1985 in the amount of $18,379. The only issue is whether an election to contribute to an individual retirement account part of a lump-sum distribution from a qualified plan may be revoked by petitioners in order to entitle them to report the entire distribution as income under the 10-year averaging method...

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