- 2 - Respondent determined a deficiency in petitioners’ Federal income tax for 2002 in the amount of $999. Petitioners timely filed a petition with the Court. The sole issue for decision is whether petitioner Patricia Marie Colombell is an active participant in her former employer’s qualified retirement plan and thus ineligible to deduct her $3,500 contribution to an individual retirement account under section 219. Background Some of the facts have been stipulated, and they are so found. We incorporate by reference the parties’ stipulation of facts at trial and accompanying exhibits. At the time the petition was filed, Patricia Marie Colombell (Mrs. Colombell) and William Edward Colombell (Mr. Colombell) resided in Fairfax County, Virginia. Mrs. Colombell worked as an employee as a pro re nata (PRN) emergency room nurse for Inova Health System (Inova) for 15 years, until her retirement in 2005. PRN nurses have no set schedule but work as needed. During the time she worked as a PRN nurse at Inova, Mrs. Colombell was not entitled to health benefits, sick leave, or vacation time. Inova maintained a cash balance retirement plan, a type of defined benefit plan under section 401(a), for its employees. Beginning in July 1998, participation in the retirement plan was both automatic and mandatory for all employees.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011