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After concessions by petitioners, the sole issue for
decision is whether petitioners are entitled to a deduction under
section 219(a) for an individual retirement account (IRA)
contribution of $2,000 by Santos M. Castillo (petitioner) for the
year 1999.2
Some of the facts were stipulated. Those facts and the
accompanying exhibits are so found and are incorporated herein by
reference. Petitioners’ legal residence at the time the petition
was filed was Miami, Florida.
During the year at issue, petitioner was employed as an
automobile salesman by Carmax. He began his employment with
Carmax sometime during 1998 and terminated his employment with
that employer on August 22, 1999, because of his need to have
several surgeries. He worked approximately 1-1/2 years with
Carmax. As an employee of Carmax, petitioner was an active
participant in two Circuit City Stores, Inc., retirement plans:
the Retirement Plan of Circuit City Stores, Inc., and the Circuit
City Stores, Inc. 401K Plan.3 At the time petitioner's
employment with Carmax terminated on August 22, 1999, petitioner
2 At trial, petitioners conceded unreported interest
income of $362 and unreported self-employment income of $2,500.
3 Circuit City Stores, Inc., is believed to be the parent
company of Carmax.
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