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RILEY v. COMMISSIONER

Docket No. 6711-74.

66 T.C. 141 (1976)

NORMAN O. RILEY AND LOUISE RILEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 22, 1976.

Attorney(s) appearing for the Case

Edward S. Miller, for the petitioners.

Lawrence G. Becker, for the respondent.

OPINION

DAWSON, Chief Judge:

Respondent determined a deficiency of $2,056 in petitioners' Federal income tax for the year 1971. The only issue for decision is whether petitioners may utilize the income averaging provisions of sections 1301 through 1305 of the Code,1 in determining their minimum tax for tax preferences imposed by section 56.

The case was submitted under Rule 122, Tax Court Rules of Practice and...

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