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plan described in section 219(g)(5)(A)(iii) as a plan
“established for its employees * * * by a State or political
subdivision thereof”. We disagree with petitioner.
Petitioner would have us construe the language of section
219(g)(5)(A)(iii) much more narrowly than we are willing to do.
The legislative history of section 219 establishes that the
section was enacted in an attempt to achieve some degree of
parity between those individuals who have access to tax-
advantaged retirement plans through employment and those
individuals who do not. See H. Rept. 93-779, at 127 (1974),
1974-3 C.B. 244, 370; H. Rept. 93-807, at 128 (1974), 1974-3 C.B.
(Supp.) 236, 363 (providing that the deduction for contributions
to individual retirement accounts is to be available only where
an individual “does not participate in any other tax-supported
retirement plan”); H. Conf. Rept. 93-1280, at 355 (1974), 1974-3
C.B. 415, 496-498. Thus, active participants of tax-advantaged
plans with income above various levels are denied completely the
tax deduction that is provided by section 219 to individuals who
are not otherwise covered by similar tax-advantaged retirement
plans. See sec. 219(g)(5).
The Lansing school district is a part of the Michigan public
school system. The MPSERS was established by the State of
Michigan for its public school employees. Petitioner, through
his employment with the Lansing school district, had the
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