Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $12,066 in petitioner's Federal income tax for the calendar year 1978. The sole question before us is the proper treatment of a lump-sum payment of annuity arrearages received by petitioner from the United States Department of the Navy as the widow of her deceased husband.
All of the facts have been stipulated and are found accordingly.
Petitioner was a resident of...