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tioners claimed in their 1996 joint return for the $2,000 contri-
bution made to Ms. Whitehead’s IRA during that year. Respondent
made that determination because respondent determined that Ms.
Whitehead did not receive any compensation during 1996. On
brief, respondent concedes that, pursuant to section 219(c) as in
effect for petitioners’ tax year 1996, petitioners are entitled
to a deduction of $250 with respect to contributions of $2,000
that were made to Ms. Whitehead’s IRA during that year.
It is petitioners’ position that they are entitled to a
deduction for 1996 for contributions made to Ms. Whitehead’s IRA
in the amount that they claimed in their joint return for that
year, i.e., $2,000. In support of their position, petitioners
contend, as they do with respect to the respective values of
petitioners’ respective uses of certain Burien Nissan automobiles
during the years at issue, that Ms. Whitehead performed at least
120 hours of services for Burien Nissan during 1996 for which
Burien Nissan compensated her by permitting her to use certain
Burien Nissan automobiles, the value of which was $6,600.48
Section 219 generally allows a deduction for contributions
48On brief, petitioners also contend that, valuing at $17
per hour the 120 hours of services that they contend Ms. White-
head performed for Burien Nissan during 1996, her compensation
for those services would have been $2,040, which is an amount
substantially less than the value ($6,600) that petitioners
claimed in their 1996 joint return. Assuming arguendo that Ms.
Whitehead had worked 120 hours for Burien Nissan during 1996, the
value of her services would have to have been $55 per hour in
order for her to have received compensation of $6,600.
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