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GUILZON v. COMMISSIONER

Docket No. 23402-90.

97 T.C. 237 (1991)

EDWARD J. GUILZON AND CAROLYN J. GUILZON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 6, 1991.

Attorney(s) appearing for the Case

Kenneth B. Kramer, Thomas J. O'Rourke, and Virginia J. Townsend, for the petitioners.

Susan J. Rascoe, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax of $8,258 for taxable year 1987.

The principal issue is whether a lump-sum payment received by petitioner, Edward J. Guilzon, from the Civil Service Retirement System (CSRS) fund pursuant to 5 U.S.C. sec. 8343(a) (1987) is taxable under section 72(e).1 The subsidiary issue is whether, if the lump-sum payment is taxable...

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