Eanes v. Commissioner
United States Tax Court
Petitioner participated in his employer's qualified retirement plan during 3 months of employment in 1981. Upon termination of employment, petitioner irrevocably forfeited all rights in the retirement plan. If he were reemployed by the company, he would receive no credit for prior contributions and would be treated as a new employee for plan purposes.
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Petitioner participated in his employer's qualified retirement plan during 3 months of employment in 1981. Upon termination of employment, petitioner irrevocably forfeited all rights in the retirement plan. If he were reemployed by the company, he would receive no credit for prior contributions and would be treated as a new employee for plan purposes. Petitioner subsequently contributed $ 1,500 to an Individual Retirement Account (IRA) in 1981 and deducted that amount on his Federal income tax return. Respondent disallowed the IRA deduction and sought to impose an excise tax under sec. 4973,…
1Opinion of the Court
Panuthos, Special Trial Judge:
This case was heard pursuant to the provisions of section 7456(d) of the Code.1
Respondent determined a deficiency of $474.10 in petitioner’s2 1981 Federal income tax. The issue for decision is whether petitioner is entitled to a deduction of $1,500 for a contribution to an Individual Retirement Account (IRA).3
At the time of filing his petition, petitioner resided in Alameda, California. Some of the facts have been stipulated and are incorporated herein by this reference.
FINDINGS OF FACT
Petitioner was employed by Tudor Engineering Co. from November 3, 1980,…
2Cases cited11 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Orzechowski v. CommissionerUnited States Tax Court · 1978
- Richard W. And Janet Orzechowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
- John F. Foulkes and Joyce A. Foulkes v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1981
- Johnson v. CommissionerUnited States Tax Court · 1980
6 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Porter v. CommissionerUnited States Tax Court · 1987
- Moosally v. CommissionerUnited States Tax Court · 2014
- MoneyGram International, Inc. v. CommissionerUnited States Tax Court · 2015
- Felber v. CommissionerUnited States Tax Court · 1992
- Aronson v. CommissionerUnited States Tax Court · 1985
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