Memorandum Findings of Fact and Opinion
COHEN, Judge.
Respondent determined a deficiency of $10,546 in petitioners' Federal income taxes for 1989. The deficiency resulted from respondent's determination that petitioners had received distribution of a taxable annuity in the amount of $57,010. In an Amendment to Answer, respondent alleged, among other things, that petitioners' distribution was received from a plan that was a tax-sheltered annuity under section...
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