Monson v. Commissioner
United States Tax Court
Petitioners elected to compute their tax liability for 1977 by use of the income averaging provisions under secs. 1301- 1305, I.R.C. 1954. Held in computing their base period income for 1973 and 1974 for income averaging purposes, petitioners are required to adjust their negative taxable income figures to zero in accordance with sec. 1302(b)(2), and sec. 1.1302-2(b)(1), Income Tax Regs., before adding the zero bracket amount as required by sec. 1302(b)(3).
1Opinion of the Court
John R. Monson and Susan B. Monson, Petitioners v. Commissioner of Internal Revenue, Respondent
Monson v. Commissioner
Docket No. 5641-80
United States Tax Court
77 T.C. 91; 1981 U.S. Tax Ct. LEXIS 98;
July 23, 1981, Filed
Decision will be entered for the respondent.
Petitioners elected to compute their tax liability for 1977 by use of the income averaging provisions under secs. 1301- 1305, I.R.C. 1954. Held in computing their base period income for 1973 and 1974 for income averaging purposes, petitioners are required to adjust their negative taxable income figures to zero in accordance with sec.…
2Cases cited4 opinions
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Tebon v. CommissionerUnited States Tax Court · 1970
- Monson v. CommissionerUnited States Tax Court · 1981