- 5 - considered an active participant whether or not his rights under a plan are vested or forfeited. Orzechowski v. Commissioner, 69 T.C. 750, 754 (1978), affd. 592 F.2d 677 (2d Cir. 1979). Therefore, because petitioner was an active participant in his former employer's plans during 1999, the claimed IRA deduction for 1999 is not allowable. Respondent is sustained on this issue. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011