Legal Opinion

Collins v. Commissioner

United States Tax Court

Decided August 29, 1978No. Docket No. 6748-77PublishedCited by 7 opinions

On Mar. 12, 1975, petitioner-wife established a qualified individual retirement account with Fidelity Savings & Loan Association and deposited $ 500 to the account. Fifteen percent of the amount she earned ($ 4,729.03) in 1975 was $ 709.35, which was the maximum amount of allowable contribution to her IRA.

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On Mar. 12, 1975, petitioner-wife established a qualified individual retirement account with Fidelity Savings & Loan Association and deposited $ 500 to the account. Fifteen percent of the amount she earned ($ 4,729.03) in 1975 was $ 709.35, which was the maximum amount of allowable contribution to her IRA. On Jan. 2, 1976, petitioner deposited $ 710 to the IRA, of which $ 209.35 was treated as a contribution for the year ended Dec. 31, 1975. Petitioner claimed a deduction of $ 709.35 for 1975 under sec. 219(a)(1), I.R.C. 1954. Respondent disallowed $ 209.35 of the claimed deduction because…

1Opinion of the Court

Dawson, Judge:

Respondent, in his notice of deficiency dated May 25, 1977, determined a deficiency of $101.17 in petitioner's Federal income tax for the year 1975. Actually, the total amount includes an income tax deficiency of $52.35 and an excise tax deficiency1 of $48.82 on “excess contributions” made to the individual retirement account (IRA) of petitioner Dorothy Collins under the provisions of section 4973, Internal Revenue Code.2

At issue are (1) whether the $209.35 contribution made to petitioner’s IRA on January 2, 1976, is deductible under section 219(a)(1) in determining her taxable…

2Cases cited1 opinion

  1. Orzechowski v. CommissionerUnited States Tax Court · 1978

3Cited by7 opinions

  1. Johnson v. CommissionerUnited States Tax Court · 1980
  2. Cavana v. CommissionerUnited States Tax Court · 1980
  3. Collins v. CommissionerUnited States Tax Court · 1978
  4. Cummings v. CommissionerUnited States Tax Court · 1984
  5. Johnson v. CommissionerUnited States Tax Court · 1980

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