Memorandum Opinion
NIMS, Chief Judge:
Respondent determined a deficiency of $7,376.78 in petitioners' Federal income tax for the taxable year 1986. The issue for decision is whether petitioners are entitled to elect 10-year averaging pursuant to section 402(e) with respect to a cash distribution received following the termination of a qualified profit-sharing plan. (Section references are to sections of the Internal Revenue...
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