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After petitioner’s concession,1 the issues for decision are
whether petitioner may deduct for 2001 (1) $1,916 that she paid
to a French retirement plan, and (2) real estate taxes. We hold
that she may not.
Unless otherwise stated, section references are to the
Internal Revenue Code as amended and in effect in the year in
issue, and Rule references are to the Tax Court Rules of Practice
and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Seattle, Washington, when the petition
was filed. In 2001, petitioner was a citizen of France and a
resident of the United States for tax purposes.
In 2001, petitioner was a professor at the University of
Washington, Central Washington University, and Evergreen State
College. In 2001, Central Washington University contributed
$4,653.22 on petitioner’s behalf to a retirement plan in the
United States, and petitioner paid the equivalent of $1,916 to a
pension plan in France (French pension plan).
Petitioner filed a Form 1040, U.S. Individual Income Tax
Return, for 2001, reported that she was married filing
1 Petitioner concedes that she failed to report $3,396 of
income from Evergreen State College on her Form 1040 for 2001 as
determined by respondent.
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