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WOOD v. COMMISSIONER

Docket No. 20039-87.

93 T.C. 114 (1989)

WILLIAM WOOD AND LOIS WOOD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 31, 1989.

Attorney(s) appearing for the Case

Joseph G. Kinder, for the petitioners.

Michael P. Breton, for the respondent.

RUWE, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1983 in the amount of $12,143.92 and an addition to tax under section 66611 in the amount of $3,035.98. In his reply brief, respondent has waived the addition to tax under section 6661.

The issues for decision are: (1) Whether a portion of the lump-sum distribution received in 1983 from a profit-sharing fund is includable...

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