Hauser v. Comm'r
United States Tax Court
From Jan. 1, 1975, to Dec. 27, 1976, petitioner was employed by a company which maintained a pension plan for some of its employees. Under the pension plan's 1975 rules, petitioner was ineligible to receive plan benefits.
Read the full summary
From Jan. 1, 1975, to Dec. 27, 1976, petitioner was employed by a company which maintained a pension plan for some of its employees. Under the pension plan's 1975 rules, petitioner was ineligible to receive plan benefits. In 1978, the company amended the plan effective retroactive to Oct. 1, 1976. If the 1978 rules had applied in 1976, then petitioner would have been an active participant in the plan for part of 1976. In 1976, petitioner contributed $ 1,500 to an individual retirement account and took a sec. 219, I.R.C. 1954, deduction for this amount. Respondent disallowed this deduction and…
1Opinion of the Court
Nims, Judge-.
Respondent determined a deficiency in petitioners’ 1976 Federal taxes in the amount of $570. The issues for our decision are (1) whether petitioners are entitled to a section 2191 deduction for amounts contributed during 1976 to an individual retirement account (IRA); and (2) whether petitioners are liable for a section 4973(a) excise tax for excess IRA contributions.
FINDINGS OF FACT
Some of the facts are stipulated. The stipulation and its attached exhibits are incorporated herein by reference.
Petitioners resided in Pelham, N.Y., when they filed the petition in this case.…
2Cases cited7 opinions
- 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
- Bart H. Johnson, Jr. And Jimmie Ruth Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
2 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Orvis v. CommissionerUnited States Tax Court · 1984
- Mortenson Roofing Co. v. CommissionerUnited States Tax Court · 1992
- Day v. CommissionerUnited States Tax Court · 1985
- Hauser v. Comm'rUnited States Tax Court · 1982