Hay v. Commissioner
United States Tax Court
Held: For income averaging purposes in computational year 1977, negative taxable income for the 4 base years must be adjusted to zero pursuant to section 1.1302-2(b)(1), Income Tax Regs., prior to addition of the zero bracket amount as required by section 1302(b)(3) of the Internal Revenue Code.
1Opinion of the Court
RALPH E. HAY AND EVELYN F. HAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hay v. Commissioner
Docket No. 6834-80.
United States Tax Court
T.C. Memo 1982-343; 1982 Tax Ct. Memo LEXIS 400; 44 T.C.M. (CCH) 172; T.C.M. (RIA) 82343;
June 21, 1982.
Held: For income averaging purposes in computational year 1977, negative taxable income for the 4 base years must be adjusted to zero pursuant to section 1.1302-2(b)(1), Income Tax Regs., prior to addition of the zero bracket amount as required by section 1302(b)(3) of the Internal Revenue Code.
Jack Miller, for the petitioners.
Alan J. Pinner,…
2Cases cited3 opinions
- Tebon v. CommissionerUnited States Tax Court · 1970
- Monson v. CommissionerUnited States Tax Court · 1981
- Title Insurance & Trust Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1981