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RODONI v. COMMISSIONER

Docket No. 28636-92.

105 T.C. 29 (1995)

MARIO RODONI AND DONNA RODONI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 24, 1995.

Attorney(s) appearing for the Case

John C. Suttle, James F. Fotenos, and Mark M. Tucker (specially recognized), for petitioners.

William D. Reese and Emily Kingston, for respondent.

RUWE, Judge:

Respondent determined a deficiency of $146,544 in petitioners' 1988 Federal income tax. After concessions, the issues for decision are: (1) Whether the lump-sum distribution from a qualified profit sharing plan to petitioner Mario Rodoni (Mr. Rodoni) and its subsequent transfer into the individual retirement accounts of petitioner Donna Rodoni (Mrs. Rodoni) qualify as a tax-free rollover under section 402...

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