Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for 1982 in the amount of $188. The sole issue is whether amounts withheld from petitioners' salary in 1982 and contributed to a pension plan were "picked up" within the meaning of section 414(h)(2).
Findings of Fact
Some of the facts have been stipulated and are so found. The stipulation...
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