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ESTATE OF GARDON v. COMMISSIONER

Docket No. 5557-65.

47 T.C. 462 (1967)

ESTATE OF HARRY A. GORDON, DECEASED, RUTH E. GORDON, EXECUTRIX, AND RUTH E. GORDON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 31, 1967.

Attorney(s) appearing for the Case

Myron E. Anderson, for the petitioners.

Gary C. Randall, for the respondent.

OPINION

FAY, Judge:

Respondent asserted deficiencies in Federal income tax of Harry A. Gordon and Ruth E. Gordon in the amount of $3,291.38 for the taxable year 1962.1

The issues for decision are (1) whether petitioners are entitled in 1962 to the special income-averaging provisions afforded taxpayers under sections 1305 or 1306 of the Internal Revenue Code of 1954 and (2) in the event petitioners are entitled...

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