- 4 -
deduction under sections 62(a)(9) and 165 for payment of the
penalty for premature withdrawal of funds from his CD in December
1993. Finally, respondent determined that petitioner was liable
for the 10-percent additional tax on an early distribution from a
qualified retirement plan under section 72(t) in the amount of
$50.
At trial, petitioner conceded that he received $19 in
unreported taxable interest income in 1994. Also, the parties
agree that petitioner is entitled to the $115 deduction with
respect to the penalty for early cancellation of petitioner's CD
in December 1993. Moreover, the computational adjustments to
petitioner's miscellaneous itemized deductions will be resolved
by the Court's holdings on the issues herein.
The first issue is whether petitioner is entitled to a
$2,000 deduction for a contribution to an IRA in 1994. In
general, an individual 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 includible in
the individual's gross income". Sec. 219(a) and (b)(1). A
"qualified retirement contribution" is defined as "any amount
paid in cash for the taxable year by or on behalf of an
individual to an individual retirement plan for such individual's
benefit" and "any amount contributed on behalf of any individual
to a plan described in section 501(c)(18)." Sec. 219(e).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011