Memorandum Opinion
KÖRNER, Judge:
For the calendar year 1985, respondent determined a deficiency in the income tax of petitioners in the amount of $15,225. The only issue which we must decide is whether a distribution in 1985 to petitioner Reed H. Johnston (hereinafter petitioner) from a profit-sharing plan in which he was a participant should be taxable as capital gain or as ordinary income. Some of the facts were stipulated, and such stipulation,...
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