Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
For taxable year 1987, respondent determined a deficiency in petitioners' Federal income tax in the amount of $12,669.
The issues for our consideration for taxable year 1987 are:
(1) Whether a single payment in the amount of $62,664.27 received by petitioner Eugene Kirkland from his retirement plan constitutes taxable income. We hold that it does.
(2) Whether petitioners are entitled...
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