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parties, the issue for decision is whether petitioners are
entitled to claim a deduction for petitioner’s IRA contributions
in 2001. Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
These cases were submitted fully stipulated under Rule 122.
The stipulated facts are incorporated as our findings by this
reference. Petitioners resided in Cibolo, Texas, at the time
that they filed their petitions.
Petitioners timely filed joint Federal income tax returns
for 2001 and 2002. During 2001 and 2002, petitioner was an
active participant in a section 403(b) employer-sponsored
retirement plan through his employment with the University of
Texas Medical Branch. Petitioner claimed IRA contribution
deductions of $2,000 and $3,000 in 2001 and 2002, respectively.
As reported on petitioners’ joint income tax returns for 2001 and
2002, petitioners’ modified adjusted gross income (AGI) was
$114,193.66 in 2001 and $124,304.43 in 2002. (We use the term
“modified AGI” to mean AGI computed without regard to any
deduction for an IRA contribution.) In 2001, petitioner’s
reported earnings were $61,256.27, his spouse’s reported earnings
were $52,000.08, and they reported interest income of $937.31.
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