Gary Benton Logsdon and Karen Ruth Logsdon - Page 2

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          references are to the Tax Court Rules of Practice and Procedure.            
          After concessions, the principal issue for decision is whether              
          the lump-sum credit from the Civil Service Retirement System                
          (CSRS) is includable in petitioners' gross income pursuant to               
          sections 72(e) and 402(a).  If the lump-sum credit is taxable,              
          the subsidiary issue for decision is whether a portion of any               
          deemed deposit or deemed redeposit in respect of that lump-sum              
          credit is includable in petitioners' gross income pursuant to               
          section 72(b) rather than pursuant to section 72(e).                        
               All of the facts have been stipulated pursuant to Rule 122.            
          The stipulated facts and the attached exhibit are incorporated in           
          our findings by this reference.  At the time the petition was               
          filed, petitioners resided in Portland, Oregon.  Petitioners'               
          1991 joint Federal income tax return (1991 return) was prepared             
          and filed on the cash receipts and disbursements method.                    
               During 1991, Gary B. Logsdon retired from the Federal                  
          Government and received a lump-sum payment in the amount of                 
          $62,873.  On their 1991 return, petitioners reported $11,808 of             
          the above amount on lines 17a (Total pensions) and 17b (Taxable             
          amount).  No other entry or reference was made by petitioners on            
          their 1991 return for the $51,065 balance of the lump-sum                   
          payment.  Respondent determined that petitioners were required to           
          include the lump-sum payment in their gross income in 1991.                 

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