§49801

The issues for decision after concessions are: (1) whether petitioner is liable for excise tax under section 49801 for 2003 on 1Unless otherwise indicated, all section, chapter, subchapter, part, and (continued...) - 3 - a reversion received from an employee pension plan, and (2) ifwe find that petitioner is not liable for excise tax under section 4980, whetherpetitioner is entitled to an overpayment credit or refund.