Memorandum Opinion
KÖRNER, Judge:
For the calendar year 1984, respondent determined a deficiency in petitioners' income tax of $21,668.87. The sole issue presented for the Court to decide is whether, under the facts of this case, petitioners are entitled to average, over a ten-year period, the lump-sum distributions made to them in 1984 from the Louisville Valve and Fitting Company Profit Sharing Plan and Trust, in accordance with section 402(e) of...
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