Taylor Miller - Page 33




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          1992, the full funding limitation under sections 412 and 404 was            
          $40,729.  For purposes of this case, under section                          
          404(a)(1)(A)(i), the full funding limitation would result in a              
          maximum deductible contribution of $40,729 for the plan year                
          ending October 31, 1992.                                                    
               Schedule B for the plan year ending October 31, 1993, showed           
          that petitioner made the following contribution to the TJM                  
          Pension Plan:                                                               
                    Date                          Amount                              
                    January 8, 1993               $50,365                             
               Based on the plan provisions and assumptions used by the               
          actuary for the TJM Pension Plan plan year ending October 31,               
          1993, the full funding limitation under sections 412 and 404 was            
          $52,443.  For purposes of this case, under section 404(a)(1)                
          (A)(i) and section 1.404(a)-14(c), Income Tax Regs., the full               
          funding limitation would result in a maximum deductible                     
          contribution of $52,443 for the plan year ending October 31,                
          1993.                                                                       
               During 1975, petitioner earned $12,895 in wages from                   
          Fidelity; petitioner earned no self-employment income.  During              
          1976 and 1977, respectively, petitioner earned $4,849 and $1,059            
          in net self-employment income from sales of Fidelity insurance              
          products.  Petitioner had no self-employment income for the 1989            
          tax year.  For the 1990 and 1991 tax years, petitioner reported             






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