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181, and 182.1 Respondent determined a deficiency in
petitioners' 1992 Federal income tax in the amount of $1,120.
The only issue in dispute is whether petitioners are
entitled to a deduction in the amount of $4,000 for contributions
to their respective individual retirement accounts (IRA).
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition, petitioners resided in Largo, Florida.
During 1992, petitioner Hugo M. Nicolai was employed by
Varian Associates, Inc. (Varian). In October 1992, Mr. Nicolai
became eligible to participate in Varian's pension plan. On
December 31, 1992, Mr. Nicolai had a balance of $377.60 to his
credit in Varian's pension plan.
Petitioner Susanne J. Nicolai was employed by Morton F.
Plant Hospital in 1992. Mrs. Nicolai began working at the
hospital in 1990 and terminated her employment during the summer
of 1992. The hospital had a pension plan wherein an employee
received forfeitable rights until vested, which required 6 years
of employment. Since Mrs. Nicolai worked approximately 2 years
for the hospital, her rights did not vest in the pension plan.
1 All section references are to the Internal Revenue Code
in effect for the tax year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
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