Memorandum Opinion
JACOBS, Judge:
Respondent determined a deficiency in petitioner's 1987 Federal income tax in the amount of $46,206. The deficiency is attributable to respondent's determination that distributions made to petitioner from his former employer's profit sharing plan did not constitute a lump-sum distribution within the purview of section 1124 of the Tax Reform Act of 1986 (TRA), Pub. L. 99-514, 100 Stat. 2085, 2475-2476, and hence did not qualify...
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