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Rept. 93-807, at 128 (1974), 1974-3 C.B. (Supp.) 236, 363. While
the result to petitioner may appear harsh, we cannot ignore the
plain language of the statute, and, in effect, rewrite the
statute to achieve what would seem a more equitable result.
Eanes v. Commissioner, supra at 171.
We find that petitioner was an active participant in an
employer retirement plan and because his adjusted gross income
exceeded $35,000, he is not entitled to a deduction for his 1997
contributions to an IRA. Sec. 219(g)(1) and (2).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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