David Edward Neumeister - Page 5

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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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