- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011