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Respondent determined a deficiency in petitioner's Federal
income tax for the year 1993 in the amount of $1,005.
After concessions by petitioner,2 the issue for decision is
whether petitioner is entitled to an IRA deduction in excess of
the amount determined by respondent. We hold that he is not.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Omaha, Nebraska, at the time that
his petition was filed with the Court.
For the year in issue, petitioner and his wife filed a joint
Federal income tax return reporting wage income, which was earned
by petitioner's wife, in the amount of $4,235, interest income in
the amount of $34, dividend income in the amount of $4,640,
capital gain in the amount of $353, taxable IRA distributions in
the amount of $2,900, and taxable pensions and annuities in the
amount of $10,645. On a Schedule C, petitioner reported gross
income (in the form of commissions) in the amount of $271 and
(...continued)
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 Petitioner conceded the following adjustments: (1)
Interest income in the amount of $24, (2) dividend income in the
amount of $2, and (3) capital gain in the amount of $4,950.
Petitioner remitted $750 to respondent toward the deficiency
arising out of the aforementioned adjustments.
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