The distribution to the petitioners was on account of the express terms of the amended plan, which terms were determined solely according to the earlier agreement with the union. See Ford E. Wilkins, 54 T.C. 362 (1970); Whiteman Stewart, 53 T.C. 344 (1969). There is no evidence before us to support petitioners' assertion that the distribution was made ‘in anticipation of, and because of’ the subsequent substitution of Youngstown Sheet & Tube Co. for Van Huffel Tube Corp. as petitioners' employer.