Susan L. Rosetti - Page 4

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          tax deductible.  Even if the contribution had been made to an               
          IRA, petitioner would not be entitled to a deduction because she            
          was married filing a separate return, an active participant in              
          the FRS plan, and earned more than $10,000 during 1998.  Sec.               
          219(g).                                                                     
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          



























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