Lawrence L. and Kathleen J. Kelter - Page 1

                                         T.C. Memo. 1996-405                                              

                                      UNITED STATES TAX COURT                                             

                     LAWRENCE L. AND KATHLEEN J. KELTER, Petitioners v.                                   
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 6209-95.                 Filed September 3, 1996.                            

                        P sustained work-related injuries to his hands.                                   
                  For that reason, the pension plan of which P was a                                      
                  member distributed to P 100 percent of his accrued plan                                 
                  benefit.  R determined a deficiency in income tax based                                 
                  on Ps' failure to include that distribution in gross                                    
                  income.  Ps argue that the distributions are excludable                                 
                  from gross income under sec. 105(c), I.R.C.                                             
                        Held:  The distributions are not excludable from                                  
                  gross income under sec. 105(c), I.R.C., because the                                     
                  amount of the distribution was not computed with                                        
                  reference to the nature of the injuries sustained by P.                                 

                  John F. Daniels III, for petitioners.                                                   
                  Katherine Holmes Ankeny, for respondent.                                                

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