OPINION.
DRENNEN, Judge:
Respondent determined a deficiency in petitioners' income taxes for the calendar year 1955 in the amount of $4,177.35. The sole issue for decision is whether a lump-sum distribution of $18,949.75 received by Thomas E. Judkins, petitioner, in August of 1955 from the qualified retirement plan of the Waterman Steamship Corporation, his former employer, should be taxed as a long-term capital gain or as ordinary income.
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