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Federal income tax purposes contributions made to the plan would
be deductible from the PC's gross income. Respondent's
determination letter, however, indicated that with respect to the
pension plan, due to anticipated legislation, the determination
letter was only effective until the end of 1975.
During 1990 and 1991, petitioner no longer practiced law
through his PC, rather petitioner practiced law as a sole
proprietor.
In each of the years 1990 and 1991, petitioner deposited
$30,000 into an account maintained in his name apparently at a
stock brokerage company allegedly as a contribution to the above
money purchase pension plan.
On their 1990 and 1991 joint Federal income tax returns,
petitioners claimed Schedule C deductions with respect to each of
the above $30,000 deposits into the stock brokerage account.
These deposits were reflected on petitioners’ joint income tax
returns as deductible contributions to a qualified pension and
profit sharing plan.
In amended joint Federal income tax returns for 1990 and
1991 and to reflect the percentage-of-gross-income limitation
applicable to deductible pension plan contributions, petitioners
reduced the amount of the claimed Schedule C deductions with
respect to the above deposits into the stock brokerage account to
$11,898 for 1990 and $22,339 for 1991.
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