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T.C. Memo. 1980-532; Johnson v. Commissioner, 661 F.2d 53, 54-55
(5th Cir. 1981), affg. 74 T.C. 1057 (1980). The statute is
unambiguous on this point. Mrs. Brandkamp was an “active
participant” in the MetLife plan, and petitioners’ modified AGI
exceeded $50,000. Thus, petitioners are not entitled to any 1997
deduction for Mr. Brandkamp’s contribution to his IRA for that
year. Respondent’s determination on this matter is therefore
sustained.
We have carefully considered remaining arguments made by
petitioners for a result contrary to that expressed herein, and,
to the extent not discussed above, we consider those arguments to
be without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
In order to give effect to our disposition of the disputed
issue, as well as the parties’ concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011