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POWELL v. COMMISSIONER

Docket Nos. 14217-91, 18163-91.

101 T.C. 489 (1993)

RODNEY L. POWELL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT FLORA B. POWELL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 29, 1993.

Attorney(s) appearing for the Case

Clyde R. Maxwell, for petitioner in docket No. 14217-91.

Roger A. Grad, for petitioner in docket No. 18163-91.

Willis B. Douglass, for respondent.

OPINION

TANNENWALD, Judge:

In these consolidated cases, respondent determined deficiencies of $20,623 in the Federal income tax of Rodney L. Powell (Rodney) for the taxable year 1984 and $16,237 in the Federal income tax of Flora B. Powell (Flora) for the taxable year 1985. The issue for decision is whether a distribution from a qualified pension plan of Rodney's employer is taxable in its entirety to Rodney or in part to Rodney and in part to Flora...

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