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YOUNGER v. COMMISSIONER

Docket No. 23856-90.

64 T.C.M. 90 (1992)

T.C. Memo. 1992-387.

William R. Younger and Lana M. Younger v. Commissioner.

United States Tax Court.

Filed July 13, 1992.

Attorney(s) appearing for the Case

Peter J. Towle, 507 Gay St., Knoxville, Tenn., for the petitioners. John R. Keenan, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1987 of $18,208. Respondent also determined that petitioners were subject to a 10-percent additional tax under section 72(t).1 The sole issue for decision is whether petitioners are entitled to utilize 10-year averaging to compute the tax on a lump-sum distribution received...

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