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be entered in this case is not reviewable by any other court, and
this opinion should not be cited as authority.
Respondent determined a deficiency in petitioners’ Federal
income tax for 1997 in the amount of $560. After concessions by
the parties,2 the sole issue for decision is whether petitioners
are entitled to a deduction in the amount of $2,000 for a
contribution to petitioner Fred P. Brandkamp’s individual
retirement account (IRA). We hold that petitioners are not
entitled to such deduction.
Background3
Some of the facts have been stipulated, and they are so
found. Petitioners resided in Duluth, Georgia, at the time that
their petition was filed with the Court.
Petitioner Fred P. Brandkamp (Mr. Brandkamp) was employed in
1997, the taxable year in issue, by Winter Wyman Contract
Services, Inc. and Data Tabulating Service, Inc. During that
year, Mr. Brandkamp was not covered by any qualified pension plan
or retirement program that may have been sponsored by either of
his employers.
2 Respondent concedes the $13 adjustment in the notice of
deficiency for “dependent care benefits”. Petitioners concede
the collection-related matter raised in the petition.
3 At trial, we deferred ruling on certain relevancy
objections made by Mr. Brandkamp to portions of various exhibits.
We now overrule those objections, and our findings reflect that
ruling.
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