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Respondent determined a $990 deficiency in petitioners’
Federal income tax and a $198 accuracy-related penalty under
section 6662(a) for 2002.1
The issues for decision are: (1) Whether petitioners are
entitled to a deduction under section 219 for a contribution made
by petitioner-husband to an individual retirement account (IRA)
for 2002; and (2) whether respondent is estopped from denying
petitioners’ claimed IRA deduction because of a decision document
entered by this Court in their case, docket No. 2788-04S, for
2001.
Background
Some of the facts have been stipulated and are so found.
Petitioners resided in Ogden, Utah, when they filed their
petition in this case.
Gary H. Bell (petitioner) retired in 1998 under the Civil
Service Retirement System after 30 years of service as a U.S.
Government employee. He worked from 1991 to 1998 for the
Bonneville Power Administration as a project coordinator for the
construction of high voltage transmission lines. Petitioner was
over age 50 in 2002.
1Respondent has conceded the accuracy-related penalty under
sec. 6662(a). Petitioners conceded adjustments relating to
interest income of $2,997 and dividend income of $71. The
computation included in the deficiency notice shows that
petitioners previously paid $584 as tax and interest of $74 on
these adjustments for 2002.
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Last modified: May 25, 2011