- 5 - not excluded under the eligibility provisions of the plan." Sec. 1.219-2(b)(1), Income Tax Regs. Since petitioners were "active participants" in their respective retirement plans during 1992, and their adjusted gross income for that year exceeded $50,000, petitioners are not entitled to an IRA contribution deduction for the year 1992. Sec. 219(a), (c)(2), (g)(1), (2), and (3); Johnson v. Commissioner, 74 T.C. 1057 (1980), affd. 661 F.2d 53 (5th Cir. 1981); Felber v. Commissioner, T.C. Memo. 1992-418, affd. without published opinion 998 F.2d 1018 (8th Cir. 1993). Based on the foregoing, respondent's determination is sustained. Decision will be entered for respondent.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011