Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $22,438 in petitioners' Federal income taxes for 1989. The deficiency resulted from respondent's disallowance of use of the 10-year averaging method applied to petitioner William L. Meyers' (petitioner) distribution from a pension plan that was not qualified at the time of the distribution. Unless otherwise indicated, all section references are to the Internal Revenue...
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