Gloria Yuen-Mee Ho and Alexander Chi-Shun Tsang - Page 2

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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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