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sufficient to override the literal language of the controlling
statute.
In the Employee Retirement Income Security Act of 1974,
(ERISA) Pub. L. 93-406, 88 Stat. 829, Congress enacted section
408(a), which provided for the creation of individual retirement
accounts. In adopting the individual retirement provisions of
ERISA, the goal of Congress was to create a system whereby
employees not covered by qualified retirement plans would have
the opportunity to set aside at least some retirement savings on
a tax-sheltered basis. See H. Rept. 93-807 (1974), 1974-3 C.B.
(Supp.) 236, 361; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80,
210. Under the statutory framework thus established, individuals
could obtain a limited deduction for amounts contributed to
individual retirement accounts while earnings on such amounts
would accrue tax free. See secs. 219, 408, 409; see also
Orzechowski v. Commissioner, 69 T.C. 750, 752-753 (1978), affd.
592 F.2d 677 (2d Cir. 1979); H. Rept. 93-807, supra, 1974-3 C.B.
(Supp.) at 361-362; S. Rept. 93-383, supra at 130, 1974-3 C.B.
(Supp.) at 209. Individuals who were active participants in
employer-sponsored plans were not permitted to make deductible
IRA contributions because they were already benefitting as
participants in tax-favored plans. See sec. 219(b)(2) as
originally enacted by ERISA sec. 2002, 88 Stat. 958.
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