Memorandum Findings of Fact and Opinion
CLAPP, J.:
Respondent determined a deficiency of $12,432 in petitioner's 1986 Federal income tax. The issue for decision is whether petitioner is entitled to use the 10-year averaging method under section 402 on an amount received by him in 1986. We hold that he is not.
All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules...
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