Shankar v. Comm'r
United States Tax Court
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
Halpern, Judge:
Respondent determined a deficiency of $563 in petitioners’ 2009 Federal income tax. The deficiency resulted principally from respondent’s making the following adjustments to petitioners’ reported 2009 tax. Respondent increased petitioners’ gross income by $668 on account of that amount’s being reported by Citibank, N.A. (Citibank), as the value of 50,000 “Thank You Points” (thank you points) petitioner husband (Mr. Shankar) redeemed in 2009 to purchase an airline ticket. Respondent disallowed petitioners’ deduction of $11,000 reflecting their contributions of that sum under a…
2Cases cited3 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Guest v. CommissionerUnited States Tax Court · 1979
- Keeler v. CommissionerUnited States Tax Court · 1978
3Cited by2 opinions
- Parimal H. Shankar & Malti S. Trivedi v. CommissionerUnited States Tax Court · 2014
- Shankar v. Comm'rUnited States Tax Court · 2014