PER CURIAM:
The appellants in this case represent the estate of Charlotte B. Stevning, who originally brought suit requesting a refund of $6,909 for the 1975 tax year. Ms. Stevning's claim was based on her calculation of tax under the income averaging provisions of the Internal Revenue Code, I.R.C. §§ 1301-1305. Her contention was that Treasury Regulation § 1.1302-2(b) (1966), which states that base period income may not be less than zero, impermissibly...
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