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section references are to the Internal Revenue Code in effect for
the years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners’ Federal
income taxes for the years 2003 and 2004 in the amounts of $2,925
and $3,246, respectively. The issue for decision is whether
petitioners can deduct amounts deposited to a qualified simple
retirement account during the taxable years at issue. The
adjustments in the notice of deficiency to itemized deductions,
personal exemptions, and alternative minimum tax are
computational and will be resolved by the Court’s holding in this
case.
Background
This case was submitted fully stipulated pursuant to Rule
122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioners resided in New Berlin, Wisconsin. Unless
otherwise indicated, all references to petitioner are to James
Forret.
During the years at issue, petitioner was an employee of
Total Lighting Sales, Inc. Total Lighting Sales, Inc.
established a qualified simple retirement account under section
408(p), commonly referred to as a SIMPLE IRA. Petitioner
deposited $9,000 and $10,500 to the SIMPLE IRA in 2003 and 2004,
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