- 4 -
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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Last modified: May 25, 2011