- 2 - 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011