Johnson v. Commissioner
United States Tax Court
Petitioner-husband was an active participant in one employer's tax-qualified profit-sharing plan until Mar. 14, 1975. He became an active participant in a second employer's tax-qualified profit-sharing plan on Apr. 1, 1976. On Dec. 22, 1975, he opened an individual retirement account (an IRA) and contributed $ 1,500 to it. Petitioners did not claim any deduction on account of the $ 1,500 contribution, and included in their gross income the interest earned by the account.
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Petitioner-husband was an active participant in one employer's tax-qualified profit-sharing plan until Mar. 14, 1975. He became an active participant in a second employer's tax-qualified profit-sharing plan on Apr. 1, 1976. On Dec. 22, 1975, he opened an individual retirement account (an IRA) and contributed $ 1,500 to it. Petitioners did not claim any deduction on account of the $ 1,500 contribution, and included in their gross income the interest earned by the account. Held, petitioner-husband made an excess contribution to an IRA (within the meaning of sec. 4973(b)(1), I.R.C. 1954) for…
1Opinion of the Court
OPINION
Chabot, Judge:
Respondent determined deficiencies in Federal excise tax1 under section 49732 against petitioners in the amount of $90 for each of the years 1975 and 1976. The issue for decision is the taxability under section 4973(a) of petitioner-husband’s contribution to an individual retirement account.
All of the facts have been stipulated; the stipulation and the stipulated exhibits are incorporated herein by this reference.
When the petition in this case was filed, petitioners Bart H. Johnson, Jr. (hereinafter sometimes referred to as Johnson), and Jimmie Ruth Johnson, husband and…
2Cases cited4 opinions
- Orzechowski v. CommissionerUnited States Tax Court · 1978
- Richard W. And Janet Orzechowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
- Guest v. CommissionerUnited States Tax Court · 1979
- Collins v. CommissionerUnited States Tax Court · 1978
3Cited by37 opinions
- Horvath v. CommissionerUnited States Tax Court · 1982
- Anthes v. CommissionerUnited States Tax Court · 1983
- Campbell v. CommissionerUnited States Tax Court · 1997
- Eanes v. CommissionerUnited States Tax Court · 1985
- Benbow v. CommissionerUnited States Tax Court · 1984
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