Legal Opinion

Collins v. Commissioner

United States Tax Court

Decided August 29, 1978No. Docket No. 6748-77Published

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

Wendell H. and Dorothy B. Collins, Petitioners v. Commissioner of Internal Revenue, Respondent

Collins v. Commissioner

Docket No. 6748-77

United States Tax Court

70 T.C. 785; 1978 U.S. Tax Ct. LEXIS 67;

August 29, 1978, Filed

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 $…

2Cases cited2 opinions

  1. Orzechowski v. CommissionerUnited States Tax Court · 1978
  2. Collins v. CommissionerUnited States Tax Court · 1978

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