Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was heard pursuant to section 7443A(b) and Rule 180 et seq.
Respondent determined a deficiency in petitioner's 1986 Federal income tax in the amount of $4,778.20. The sole issue for decision is whether petitioner is subject to the alternative minimum tax imposed by section 55(a) when he utilized income averaging in computing his tax.
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