- 5 -
Commissioner, supra; see also Wade v. Commissioner, supra; Freese
v. Commissioner, T.C. Memo. 1996-224.
Petitioners reported a modified AGI of $114,193.66 on their
2001 joint income tax return. Therefore, petitioners are not
entitled to claim a deduction for petitioner’s IRA contribution
in 2001 because petitioner was an active participant in an
employer-sponsored retirement plan during that year and because
petitioners’ modified AGI exceeded the $63,000 threshold set for
that year.
Petitioners request in their brief that the Court “dismiss
the interest penalties assessed by the IRS on both tax years, as
it significantly delayed notification of its findings”. As a
general rule, this Court does not have jurisdiction over matters
involving interest. Perkins v. Commissioner, 92 T.C. 749, 752
(1989). None of the exceptions to this rule apply in these
cases. See, e.g., sec. 7481(c); see also sec. 6404(h).
We have considered all of the remaining arguments that have
been made by petitioners for a result contrary to that expressed
herein, and, to the extent not discussed above, they are either
without merit or irrelevant to our decision.
To reflect the foregoing,
Decisions will be entered
for respondent.
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Last modified: May 25, 2011