Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $3,716.91 in the petitioners' Federal income tax for 1978. The sole issue for decision is whether the petitioners may utilize the income averaging provisions in determining their liability for the minimum tax.
Findings of Fact
Some of the Facts have been stipulated, and those facts are so found.
The petitioners, George L. and Delia...
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