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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner’s Federal
income tax of $420 for the taxable year 1998.
The issues for decision are: (1) Whether petitioner is
entitled to deduct a contribution to an Individual Retirement
Account (IRA); and (2) whether petitioner is entitled to deduct
the payment of certain legal fees.1
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Philadelphia, Pennsylvania, on the date the petition was filed in
this case.
From January through May of 1998, petitioner was employed by
the U.S. Defense Finance and Accounting Service. She earned
$32,265 in this position, and was covered by her employer’s
pension plan during that time. In May 1998, petitioner’s
employment was terminated due to a reduction in force.
Petitioner was later employed by Management Consulting, Inc.,
from which she earned $11,051 during 1998.
1The latter issue was raised by petitioner for the first
time in the petition. Petitioner also asserted for the first
time in the petition that she “suffered a loss of $521.00” from a
mutual fund investment. Respondent concedes that petitioner is
entitled to deduct this loss, which was not reflected in the
notice of deficiency.
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