FOWLER v. COMMISSIONER

Docket No. 6760-90.

98 T.C. 503 (1992)

ROBERT O. FOWLER, JR., AND PAULA E. FOWLER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 22, 1992.


Attorney(s) appearing for the Case

William H. Schmidt and Gary P. Brady, for petitioners.

Louise R. Forbes, for respondent.


OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1986 of $110,364 and an addition to tax under section 6661(a)1 of $27,591. Respondent having conceded the addition to tax, the issue for decision is whether petitioners may elect 10-year averaging of a lump-sum distribution received in 1986 without making such election for another lump-sum distribution received and rolled...

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