Frederick and Judith H. Butcher - Page 4




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          deficiency has expired.  See Unser v. Commissioner, 59 T.C. 528,            
          530 (1973).  Thus, for income-averaging purposes, respondent may            
          increase petitioners' 1984 taxable income by $30,729.  As a                 
          result, petitioners are not eligible for income averaging.                  
          Accordingly, we sustain respondent's determination.                         
               To reflect the foregoing,                                              


                                             Decision will be entered                 
                                             for respondent.                          
































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