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CLARK v. COMMISSIONER

Docket No. 7588-92.

101 T.C. 215 (1993)

KATHERINE L. CLARK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 14, 1993.

Attorney(s) appearing for the Case

C. Page Hamrick III, for petitioner.

Robin L. Herrell, for respondent.

OPINION

RAUM, Judge:

The Commissioner determined a deficiency in income tax of $1,494 against petitioner for the year 1988. The principal issue for decision is whether a distribution received by petitioner during 1988 was a lump sum distribution as defined in section 402(e)(4)(A),1 and thus whether petitioner was entitled under section 402(e)(1) to use the 10-year averaging method in calculating the tax on the distribution...

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