Dale Reid Edmonds - Page 6

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          alternative, respondent argues that, even if petitioner did make            
          a qualified IRA contribution during 1994, he is precluded by the            
          limitations of section 219(g) from deducting such contribution.             
               Petitioner freely admits that he claimed the subject $2,000            
          IRA deduction solely in an attempt to recoup the funds collected            
          by respondent in connection with the 1993 levy of his CD at                 
          Asheville Savings, which he contends was wrongful.  Petitioner              
          acknowledged at trial that he did not make any contribution to an           
          IRA during 1994.  Thus, the Court finds that petitioner did not             
          make a qualified retirement contribution to an IRA in 1994.                 
          Petitioner also admitted that he was a participant in the Federal           
          Employees Retirement System (FERS) in connection with his                   
          employment at USDA during that entire year.  Thus, the Court                
          finds that petitioner was an active participant in a retirement             
          plan for that year.  Petitioner's adjusted gross income for 1994,           
          without regard to his deduction for an IRA contribution, was                
          $53,663, which exceeds the point at which an IRA deduction is               
          entirely phased out for a married couple filing jointly.                    
               In short, petitioner failed to meet the statutory                      
          requirements under section 219 for claiming a deduction for an              
          IRA contribution in 1994.  Thus, the Court holds that petitioner            
          is not entitled to any deduction for a contribution to an IRA in            
          1994.  Petitioner, moreover, is admonished over the manner in               
          which he attempted to circumvent what he felt was an improper               





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