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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.
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Last modified: May 25, 2011