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earnings from self-employment, no earned income, and accordingly,
no compensation.
There is no question but that petitioners had various items
of income properly reportable on their income tax return.
Unfortunately, neither petitioner received any compensation, as
Congress defined this term for IRA purposes, during 2000.
Accordingly, we conclude that petitioners are not entitled to the
claimed IRA deduction in issue. We have no choice but to sustain
respondent’s determination.
Contentions we have not addressed are irrelevant, moot, or
without merit.
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