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Respondent determined a deficiency in petitioners’ Federal
income tax of $600 for the taxable year 1995.
The issue for decision is whether petitioners are entitled
to a deduction for contributions made to individual retirement
accounts (IRA’s) in 1995.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Topeka, Kansas, on the date the petition was filed in this case.
Petitioner husband (petitioner), was employed by La Siesta
Foods, Inc. (Siesta), during 1995. At that time, Siesta
maintained for its employees a profit-sharing plan.
Approximately $442 was contributed by Siesta to a plan account in
petitioner’s name during 1995. After Siesta was acquired by
Reser’s Fine Foods, Inc. (Reser’s) in 1996, the plan was
terminated and its participants became fully vested. Petitioner
subsequently rolled the $442 over into an IRA account.
On their joint Federal income tax return for taxable year
1995, petitioners claimed deductions totaling $4,000 for
contributions to IRA’s. The adjusted gross income reported on
the return was $61,652, reflecting the deductions claimed for the
IRA contributions. In the only adjustment made in the statutory
notice of deficiency, respondent disallowed the IRA contribution
deductions in their entirety.
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