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HACKNEY v. COMMISSIONER

Docket No. 7672-80.

42 T.C.M. 1166 (1981)

T.C. Memo. 1981-534

Roscoe J. Hackney II and Georgina L. Hackney v. Commissioner.

United States Tax Court.

September 22, 1981.

Attorney(s) appearing for the Case

James K. Rice, 3530 Edwards Road, Cincinnati, Ohio. For the petitioners. Genevieve K. Murtaugh, for the respondent.

Memorandum Opinion

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1977 in the amount of $717. Petitioners have conceded the adjustments to income made by the Commissioner. The only issue for decision is whether, in computing "averagable income" for purposes of income averaging for the taxable year 1977, base period income under section 13021 for any pre-1977 tax...

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