Memorandum Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for 1977 and 1978 in the respective amounts of $380 and $309.52. The issue for decision is whether petitioners, in applying the income averaging provisions to determine their liabilities for 1977 and 1978, were required to compute "base period income" for each of the years prior to 1977 by increasing taxable income for those years in the amount...
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