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joint return for 2001 on which the modified AGI exceeded $63,000,
the application of section 219(g)(2) and (3) results in a total
disallowance of the IRA contribution deduction. See Felber v.
Commissioner, T.C. Memo. 1992-418, affd. without published
opinion 998 F.2d 1018 (8th Cir. 1993); see also Wade v.
Commissioner, T.C. Memo. 2001-114.
Petitioners contend that because section 219(g)(2)(A)(i)
refers to the AGI of the taxpayer in the singular form, the
“literal reading” of section 219 requires the IRS to consider
only the individual spouse’s AGI in determining the reduction or
elimination of an IRA contribution deduction. Petitioners argue,
therefore, that, because petitioner had less than $63,000 of
income in 2001, the $2,000 IRA contribution deduction should be
allowed. Petitioners’ argument overlooks the structure of
section 219(g)(3)(B), which prescribes two tables for the
applicable dollar amounts to be used in determining the reduction
or elimination of a contribution deduction. Because taxpayers
who file jointly are entitled to a higher ceiling for their AGI,
see sec. 219(g)(3)(B)(i), the necessary implication is that the
AGI to be used in the calculation is that of both spouses. In
applying section 219(g)(2) and (3), the Court has looked to the
combined AGI of married taxpayers filing jointly and not to an
individual spouse’s AGI to determine the reduction or elimination
of the IRA contribution deduction. See, e.g, Felber v.
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