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TEBON v. COMMISSIONER

Docket No. 4924-69.

55 T.C. 410 (1970)

FABIAN TEBON, JR., AND ALICE TEBON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 3, 1970.

Attorney(s) appearing for the Case

Robert E. Nelson, for the petitioners.

John L. Pedrick, for the respondent.

OPINION

FAY, Judge:

Respondent has determined a deficiency of $224.07 in the income taxes of petitioners for the taxable year 1967. The sole question presented is whether in computing "averagable income" within the meaning of sections 1301 through 13051 base period income may be less than zero.

The facts of this case have been fully stipulated. The stipulation of facts and exhibits attached thereto are incorporated...

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