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Federal income tax in the amount of $560. This Court must decide
whether petitioner is entitled to a deduction in the amount of
$2,000 for a contribution to her individual retirement account
(IRA) for the taxable year 1996.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Raleigh, North Carolina, at the
time she filed her petition.
Petitioner Mary Holland Trull (petitioner) is a computer
programmer. During 1996, petitioner was employed by Carolina
Power and Light Company (CP&L) until January 17, when she was
laid off. The official termination date on CP&L records is March
20, 1996. During her employment with CP&L, petitioner was
covered by an employer pension plan. She was vested in the CP&L
pension plan. Petitioner contributed $1,175.46 to the CP&L
pension plan in 1996. Even though her employment was terminated,
petitioner did not forfeit her right to the pension plan funds.
After leaving CP&L, petitioner was employed by Wake County
Hospital System, Inc. (WCHS) beginning February 26, 1996.
Petitioner was not covered by the WCHS employer pension plan
during 1996. Petitioner’s adjusted gross income for the year in
issue exceeded $35,000.
During 1996, petitioner also made a contribution in the
amount of $2,000 to her IRA. She deducted the $2,000 IRA
contribution on her 1996 Federal income tax return. She filed
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