- 6 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011