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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.
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Last modified: May 25, 2011