Legal Opinion

Shankar v. Comm'r

United States Tax Court

Decided August 26, 2014No. Docket No. 24414-12Published

R disallowed Ps' deduction for contributions to their IRAs, which Ps claim are deductible because the limitations on deductibility either do not apply or are unconstitutional. R also included in Ps' gross income the value of an airline ticket that P-H received by redeeming "thank you" award points that P-H claims he never received.

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R disallowed Ps' deduction for contributions to their IRAs, which Ps claim are deductible because the limitations on deductibility either do not apply or are unconstitutional. R also included in Ps' gross income the value of an airline ticket that P-H received by redeeming "thank you" award points that P-H claims he never received. R also redetermined Ps' alternative minimum tax. 1. Held: Ps are not entitled to a deduction for IRA contributions because P-W is an "active participant" in an employer-sponsored retirement plan and Ps' combined modified adjusted gross income is above the phaseout…

1Opinion of the Court

PARIMAL H. SHANKAR AND MALTI S. TRIVEDI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Shankar v. Comm'r

Docket No. 24414-12.

United States Tax Court

143 T.C. 140; 2014 U.S. Tax Ct. LEXIS 36; 143 T.C. No. 5;

August 26, 2014, Filed

Decision will be entered under Rule 155.

R disallowed Ps' deduction for contributions to their IRAs, which Ps claim are deductible because the limitations on deductibility either do not apply or are unconstitutional. R also included in Ps' gross income the value of an airline ticket that P-H received by redeeming "thank you" award points that P-H claims he…

2Cases cited4 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Guest v. CommissionerUnited States Tax Court · 1979
  3. Keeler v. CommissionerUnited States Tax Court · 1978
  4. Shankar v. Comm'rUnited States Tax Court · 2014

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