- 3 - an exempt organization under section 501 of the internal revenue code. * * * On his return for the year in issue, petitioner claimed a $2,000 deduction for a contribution to an IRA and reported adjusted gross income (AGI) of $37,475. By notice of deficiency, respondent disallowed the entire IRA deduction. Specifically, respondent disallowed the deduction to the extent of $1,763 on the ground that petitioner was an active participant of an employer-sponsored plan as defined in section 219(g)(5)(A).2 OPINION In general, a taxpayer is entitled to deduct the amount contributed to an IRA. See sec. 219(a); sec. 1.219-1(a), Income Tax Regs. The deduction in any taxable year, however, may not exceed the lesser of $2,000 or an amount equal to the compensation includable in the taxpayer's gross income for such taxable year. See sec. 219(b)(1). In addition, the amount of the deduction is limited where the taxpayer is, for any part of the taxable year, an "active participant" in a retirement plan qualified under section 401(a) or a plan established for its employees by the United States, by a State or political subdivision thereof, or by any agency or instrumentality of any of the foregoing. See sec. 219(g)(1), (5)(A)(i), (iii). In the 2 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011