BARRETT v. COMMISSIONER

Docket No. 12914-90.

64 T.C.M. 1080 (1992)

T.C. Memo. 1992-611

John H. Barrett and Mary E. Barrett v. Commissioner.

United States Tax Court.

Filed October 14, 1992.


Attorney(s) appearing for the Case

John H. Barrett and Mary E. Barrett, pro se. David A. Breen, for the respondent.


Memorandum Opinion

RAUM, Judge:

The Commissioner determined a deficiency in income tax of $14,496 against petitioners for the tax year 1985. Petitioner John H. Barrett received a lump-sum distribution from a profit-sharing plan in 1985 and rolled over a portion of that distribution into his individual retirement account ("IRA"). The principal issue for decision is whether petitioners are precluded by section 402...

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