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extent deductions shall be allowed depends upon legislative
grace; and only as there is clear provision therefor can any
particular deduction be allowed.” New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934).
Because petitioner was an active participant in CDI’s
qualified retirement plan during 1997 and his gross income for
the year exceeded $35,000, petitioner is not entitled to an IRA
contribution deduction for tax year 1997.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011