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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.
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Last modified: May 25, 2011