Memorandum Opinion
SHIELDS, Judge:
In a deficiency notice dated April 17, 1989, respondent determined a deficiency in petitioners Federal income tax for 1985 in the amount of $18,379. The only issue is whether an election to contribute to an individual retirement account part of a lump-sum distribution from a qualified plan may be revoked by petitioners in order to entitle them to report the entire distribution as income under the 10-year averaging method...
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