- 11 - governs deductions for pension payments made in 2001. The French Foreign Ministry publication does not apply to petitioner’s payments to the French pension plan in 2001. We conclude on this record that the French pension plan to which petitioner paid $1,916 in 2001 does not generally correspond to a trust as defined by section 501(c)(18). Thus, petitioner may not deduct $1,916 that she paid to her French retirement plan in 2001.5 B. Whether Petitioner May Deduct Real Estate Tax in 2001 Petitioner asserts that she is entitled to deduct real estate taxes she paid when she bought property in France in 2001.6 At trial, petitioner offered to give respondent an English translation of a settlement statement that she received when she bought the property in question. The settlement statement shows that certain taxes were calculated in connection with petitioner’s purchase of the property. However, the record does not show whether the taxes are foreign real estate taxes 5 In light of this conclusion, we need not decide respondent’s contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, and the English translation of them, Exhibits 14-P and 16-P, should not have been admitted in evidence. 6 The Court granted petitioner’s motion for leave to file the amended petition raising this issue when this case was called for trial.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011