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MERRITT v. COMMISSIONER

Docket No. 28142-90.

64 T.C.M. 397 (1992)

T.C. Memo. 1992-443.

Thomas S. Merritt and Barbara H. Merritt v. Commissioner.

United States Tax Court.

Filed August 5, 1992.

Attorney(s) appearing for the Case

Stephen M. Feldman and Marc L. Prey, 33533 W. Twelve Mile Rd., Farmington Hills, Mich., for the petitioners. Eric M. Nemeth and Stewart Todd Hittinger, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge.

Respondent determined that petitioners had a $22,814.77 income tax deficiency for 1987.

In 1987 petitioners received lump-sum distributions, as a result of Thomas S. Merritt's 1986 retirement, from his profit-sharing plan, pension plan, and employee stock option plan. Petitioners timely rolled over the pension plan and stock option plan distributions. They elected 10-year averaging for the profit...

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