- 2 - 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,Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007