Memorandum Opinion
RAUM, Judge.
The Commissioner determined a deficiency in petitioners' 1987 income tax in the amount of $10,213. At the time the petition in this case was filed, petitioners, husband and wife, resided in Deer Park, Texas. This case was submitted on the basis of a stipulation of facts and exhibits. The principal issue for decision is whether petitioners timely elected to treat a distribution received from a retirement plan in 1987 as having...
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