D was a teacher for the State of California, and during her tenure as a teacher she made contributions to and accumulated interest in a pension fund. In 1986, D withdrew all of her contributions and accumulated interest from her pension account and paid the appropriate Federal income tax on the amount withdrawn. In 1991 D returned to teaching and redeposited $149,553.01 into her account. D retired again on July 1, 2004. In 2004 D attained the age of 60. D's monthly annuity benefit was $1,524.46, which monthly benefit would continue for D's lifetime. In 2008 D received a gross distribution of $19,100 of which the taxable amount was $13,311. D did not report any of the $19,100 gross distribution in gross income. P filed a notice of deficiency. D filed a petition for redetermination. P filed a motion for summary judgment.

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