United States Tax Court July 24, 1995, Docket No. 28636-92 (Rodoni v. Commissioner)

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.