3
section 219(g), petitioners' IRA contribution deduction was
limited to zero for 1992. Petitioners contend that petitioner
elected not to contribute to the plan, and, thus, was not an
active participant. Petitioners also contend that respondent
allowed IRA deductions claimed by petitioners in taxable years
1990 and 1991, and argue that respondent is bound by "tacit
approval" of petitioners' position.
Respondent's determinations are presumed correct, and
petitioners have the burden of proving them erroneous. Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933). Deductions are
a matter of legislative grace, and petitioners bear the burden of
proving their entitlement to any deduction claimed. Rule 142(a);
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
Generally, a taxpayer is allowed a deduction for qualified
retirement contributions in an amount not in excess of the lesser
of $2,000 or an amount equal to the compensation includable in
the taxpayer's gross income. Sec. 219(a) and (b)(1). Section
219(g) limits the allowable deduction where the individual or the
individual's spouse is an "active participant". An "active
participant" is defined to include, inter alia, an individual who
is an active participant in a qualified employer provided profit-
sharing plan. Sec. 219(g)(5). The application of section 219(g)
results in total disallowance of an IRA deduction in the case of
taxpayers filing a joint return with adjusted gross income in
excess of $50,000 if one of the taxpayers is an active
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