MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated January 27, 1995, respondent determined deficiencies of $190,189 and $45,127 in petitioners' Federal income tax liabilities for 1989 and 1990, respectively. The only question for decision is whether certain pension plan distributions that petitioner Lawrence L. Kelter received in 1989 and 1990 are includable in gross income. Unless otherwise noted, all section references...
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