Abstract
Taxpayers with variable incomes potentially face disadvantages in their computation of annual tax liability as compared with counterparts having more stable incomes over time. Graduated tax rates, combined with phase-outs of certain tax benefits, effectively increase tax liability during high income years. Conversely, deductions and credits may provide only limited benefits during low income years. Although this problem is shared by many taxpayers, Congress has provided relief in I.R.C. § 1301 for taxpayers engaged in a farming or fishing business. This article discusses eligibility for relief and the mechanics of application for I.R.C. § 1301.