- 6 -
Sec. 219(g)(3)(B)(i). In other words, the taxpayer’s IRA
contribution deduction starts to phase out when the modified AGI
is $54,000, and the deduction is completely phased out when the
modified AGI exceeds $64,000.
If the limitation on deductions for IRA contributions under
section 219(g) applies to a taxpayer solely because his spouse
was an active participant, the applicable dollar amount is
$150,000. Sec. 219(g)(7). This means that the taxpayer’s IRA
contribution deduction starts to phase out when the modified AGI
is $150,000, and the deduction is completely phased out when the
modified AGI exceeds $160,000. See sec. 219(g)(2)(A).
Petitioners’ modified AGI is $164,828.15 ($161,328.15 +
$3,500). Petitioners are not allowed to claim an IRA
contribution deduction for 2002, because Mrs. Flank was an active
participant and the modified AGI exceeded $160,000.
Whether a Portion of the 2002 Distribution Was Taxed Twice
Petitioner asserts that $3,500 of the distribution that he
received in December of 2002 represents the amount of the IRA
contribution that he made earlier in the same year. He argues
that he is taxed on the $3,500 as a result of the distribution in
December of 2002 and that he will be taxed on the same $3,500 as
a result of respondent’s disallowing the IRA contribution
deduction claimed on his 2002 return.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011