Day v. Commissioner
United States Tax Court
Petitioner-husband accrued vested benefits in his employer's noncontributory tax-qualified pension plan until June 30, 1976. During 1976, he contributed $1,500 to an individual retirement account (IRA). Held: (1) Petitioner-husband was an active participant in a tax-qualified pension plan for part of 1976. Consequently, the IRA contribution is not deductible. Sec. 219(b)(2)(A)(i), I.R.C. 1954, as then in effect.
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Petitioner-husband accrued vested benefits in his employer's noncontributory tax-qualified pension plan until June 30, 1976. During 1976, he contributed $1,500 to an individual retirement account (IRA). Held: (1) Petitioner-husband was an active participant in a tax-qualified pension plan for part of 1976. Consequently, the IRA contribution is not deductible. Sec. 219(b)(2)(A)(i), I.R.C. 1954, as then in effect. (2) The 6-percent excise tax on excess contributions to an IRA under section 4973(a) applies.
1Opinion of the Court
ROBERT V. AND PAMELA H. DAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Day v. Commissioner
Docket No. 11335-79.
United States Tax Court
T.C. Memo 1985-251; 1985 Tax Ct. Memo LEXIS 380; 49 T.C.M. (CCH) 1555; T.C.M. (RIA) 85251;
May 28, 1985.
Petitioner-husband accrued vested benefits in his employer's noncontributory tax-qualified pension plan until June 30, 1976. During 1976, he contributed $1,500 to an individual retirement account (IRA).
Held: (1) Petitioner-husband was an active participant in a tax-qualified pension plan for part of 1976. Consequently, the IRA contribution is…
2Cases cited19 opinions
- Nachman Corp. v. Pension Benefit Guaranty CorporationSupreme Court of the United States · 1980
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Orzechowski v. CommissionerUnited States Tax Court · 1978
- Richard W. And Janet Orzechowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
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