Memorandum Opinion
IRWIN, Judge:
Respondent determined a deficiency of $1,725 in petitioners' Federal income tax for 1977. The sole issue for our decision is whether for purposes of income averaging petitioners are required to adjust their negative taxable income figures for their 4 base period years to zero in accordance with section 1.1302-2(b)(1), Income Tax Regs., prior to addition of the zero bracket amount.
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