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presented a bill in the amount of $1,263 for automobile insurance
premiums for three vehicles; two cars and a pick-up truck.
Petitioner has not established that he used any of these vehicles
in his rental activity or that the amount of this bill was paid
in the year in issue. Petitioner has established that he is
entitled to a deduction for automobile expense in the amount of
$876.
Petitioner presented no evidence to establish that he paid
any utilities expense during the year in issue. Petitioner has
not established that he incurred a loss in excess of $25,000, and
therefore we need not reach petitioner's argument that section
469 does not limit a loss in excess of $25,000.
IRA Deduction
Generally, an individual is allowed a deduction for
contributions to an IRA in an amount not in excess of the lesser
of $2,000, or an amount equal to the compensation includable in
the taxpayer's gross income. Sec. 219(a) and (b)(1). Section
219(g) limits the allowable deduction where the individual is an
"active participant" in a qualified retirement plan. In the case
of an unmarried taxpayer, the $2,000 limitation is reduced by an
amount determined using a ratio in which the excess of the
taxpayer's adjusted gross income, subject to certain adjustments,
over $25,000 is divided by $10,000. Sec. 219(g)(2) and (3). As
relevant here, adjusted gross income is determined after the
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