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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.
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