Majid Naemi - Page 3




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          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           
               Respondent determined a deficiency of $657 in petitioner’s             
          1997 Federal income tax.  Respondent concedes that petitioner is            
          entitled to a refund of Social Security tax in an amount to be              
          determined based upon our resolution of the issue in this case.             
          The sole issue remaining for decision is whether petitioner is              
          entitled to a deduction for a $2,000 contribution to an                     
          individual retirement account (IRA).                                        
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the accompanying exhibits are                  
          incorporated herein by reference.  Petitioner resided in Falls              
          Church, Virginia, at the time the petition in this case was                 
          filed.                                                                      
                                     Background                                       
               Petitioner was employed by CDI Corporation (CDI) in December           
          1997 for a period of 2 weeks which included two pay cycles.                 
          During both pay periods petitioner contributed to an employer-              
          sponsored retirement plan.  Also during the year in issue,                  
          petitioner made a $2,000 contribution to his IRA.  On Form 1040             
          of his Federal income tax return filed for 1997, petitioner                 
          claimed a deduction of $2,000 for a contribution to an IRA.                 
               By notice of deficiency, respondent disallowed the entire              
          IRA deduction.  Respondent agrees that petitioner made a $2,000             






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