J. Kelly and Martha L. Anderson - Page 1

                                 T.C. Memo. 2002-171                                  

                               UNITED STATES TAX COURT                                

              J. KELLY ANDERSON AND MARTHA L. ANDERSON, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10760-00.              Filed July 19, 2002.                 

               Joe K. Gordon, for petitioners.                                        
               Denise G. Dengler, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:   Petitioners petitioned the Court to                     
          redetermine respondent’s determination of a $63,949 deficiency in           
          their 1997 Federal income tax.  We must decide whether                      
          petitioners’ 1997 taxable income should include the $200,000                
          distribution that J. Kelly Anderson (Mr. Anderson) received from            
          his individual retirement account (IRA) and reported as                     

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