- 5 - Commissioner, supra; see also Wade v. Commissioner, supra; Freese v. Commissioner, T.C. Memo. 1996-224. Petitioners reported a modified AGI of $114,193.66 on their 2001 joint income tax return. Therefore, petitioners are not entitled to claim a deduction for petitioner’s IRA contribution in 2001 because petitioner was an active participant in an employer-sponsored retirement plan during that year and because petitioners’ modified AGI exceeded the $63,000 threshold set for that year. Petitioners request in their brief that the Court “dismiss the interest penalties assessed by the IRS on both tax years, as it significantly delayed notification of its findings”. As a general rule, this Court does not have jurisdiction over matters involving interest. Perkins v. Commissioner, 92 T.C. 749, 752 (1989). None of the exceptions to this rule apply in these cases. See, e.g., sec. 7481(c); see also sec. 6404(h). We have considered all of the remaining arguments that have been made by petitioners for a result contrary to that expressed herein, and, to the extent not discussed above, they are either without merit or irrelevant to our decision. To reflect the foregoing, Decisions will be entered for respondent.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011