- 2 - FINDINGS OF FACT On her timely filed 1998 Federal income tax return, petitioner reported $43,209 in wages, claimed a $2,000 IRA deduction, and elected married filing separately status. On June 22, 2001, respondent disallowed the deduction and determined a $574 deficiency. During 1998, petitioner was a real estate agent and an employee of the State of Florida, Department of Transportation. She had a defined benefit plan sponsored by the Florida Retirement System (FRS plan),1 which required employers to pay all funding costs and provided that employees’ benefits vest in 10 years. In 1998, petitioner made a $2,000 contribution to a Keogh plan that was established prior to her employment with the State of Florida. Petitioner resided in Tampa, Florida, at the time the petition was filed. OPINION Generally, a taxpayer is entitled to deduct the amount contributed to an IRA. Sec. 219(a); sec. 1.219-1(a), Income Tax Regs. The deduction in any taxable year, however, may not exceed the lesser of $2,000 or an amount equal to the compensation 1 Under the FRS plan, participation, as of the date of employment, is compulsory for those employed on or after December 1, 1970. Fla. Stat. Ann., sec. 121.051(1)(a) (West 2002).Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011