Wayne E. and Ann L. Burk - Page 3

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               Respondent determined a deficiency of $803 in petitioners’             
          2000 Federal income tax.  This Court must decide whether                    
          petitioners are entitled to a claimed $4,000 deduction for                  
          contributions to their individual retirement accounts (IRA).                
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioners resided in La Grange, Illinois, at the               
          time they filed their petition.                                             
               Section 7491(a) does not apply because this case involves a            
          legal issue.                                                                
               For taxable year 2000, petitioners jointly filed a Form                
          1040, U.S. Individual Income Tax Return.  On their Form 1040,               
          petitioners reported taxable interest of $51,217.07, ordinary               
          dividends of $2,130.79, taxable refunds of $126, a business loss            
          of $10,144.92 from the sole proprietorship of petitioner Wayne E.           
          Burk (petitioner), and taxable pensions and annuities of                    
          $3,107.04.  Petitioners each claimed an IRA deduction of $2,000.            
          Respondent disallowed the total amount of $4,000 claimed by                 
               Respondent contends that petitioners are not entitled to the           
          claimed IRA deduction because neither petitioner received                   
          compensation, as defined in the Internal Revenue Code, during the           
          taxable year in issue.                                                      
               Section 219(a) allows a deduction for qualified retirement             
          contributions of an individual.  Section 219(b)(1) limits the               

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