Memorandum Opinion
COHEN, Judge:
Respondent determined a deficiency of $224,645.43 in petitioner's Federal income tax for 1983. The sole issue for decision is whether all, or any part, of distributions by a pension plan and a defined benefit plan represent deferred compensation taxable under section 402(a), or whether the payments constitute distributions from an employer accident and health plan excludable under section 105(c). Unless otherwise indicated...
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