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THOMAS v. COMMISSIONER

Dkt. No. 14215-03.

91 T.C.M. 651 (2006)

T.C. Memo. 2006-3

Thomas and Sarah G. Ackerman v. Commissioner.

United States Tax Court.

January 4, 2006.

Attorney(s) appearing for the Case

Thomas and Sarah G. Ackerman, pro sese;

Donald M. Brachfeld, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Respondent determined a $68,494 deficiency in petitioners' 2001 Federal income tax. The issue for decision is whether petitioners are taxable on a $211,916 distribution from Mr. Ackerman's nonqualified deferred compensation plan. All section references are to the Internal Revenue Code in effect for the year at issue.

FINDINGS OF FACT

The parties have stipulated most of the relevant...

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