§1305

We hold they are not; (5)n whether petitioners may use special income-averaging provisions pursuant to section 1305 .-We hold they may not; (6) whether Mr.

We hold they are not; (5)n whether petitioners may use special income-averaging provisions pursuant to section 1305 .-We hold they may not; (6) whether Mr.

Estate of Gadlow is similarly distinguishable from the case at hand.

Like the earlier cases, Estate of Gadlow concerned the application of a provision for computing income tax liability upon the receipt of damages for breach of contract by prorating the recovery over the earlier years that the income would have been received but for the breach, section 1305 of the 1954 Code.