Gary H. and L. Marianne Bell - Page 3

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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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