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Respondent determined a deficiency in petitioner’s 1997
Federal income tax return in the amount of $560. This Court must
decide whether petitioner is entitled to a deduction in the
amount of $2,000 for contributions to his individual retirement
account (IRA) for the taxable year 1997.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Charlotte, North Carolina, at
the time he filed his petition.
Petitioner Charles Frederick Held, Jr. (petitioner) is a
computer network administrator. During 1997, petitioner was
employed by McNeary Insurance Consulting (McNeary) from January
to mid-February. During his employment with McNeary, petitioner
was covered under a qualified retirement plan. Petitioner
contributed $131.03 to the McNeary retirement plan in 1997.
After leaving McNeary, petitioner was employed by Hynes,
Inc., Harris Group, and Brantech, Inc., for the remainder of
1997. Petitioner was not covered under a qualified retirement
plan during his employment in 1997 by these companies.
During 1997, petitioner also made contributions which
totaled $2,000 to his IRA. He deducted the $2,000 in
contributions to his IRA on his 1997 Federal income tax return.
Petitioner’s adjusted gross income for the year in issue exceeded
$35,000. Respondent disallowed the IRA deduction.
Petitioner contends that as soon as he ceased working for
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