Porter v. Commissioner
United States Tax Court
Deductions of contributions made by petitioners to individual retirement accounts were disallowed by respondent because respondent determined that the male petitioners, all judges of the United States entitled to hold office for life during good behavior, were active participants of a plan established for its employees by the United States.
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Deductions of contributions made by petitioners to individual retirement accounts were disallowed by respondent because respondent determined that the male petitioners, all judges of the United States entitled to hold office for life during good behavior, were active participants of a plan established for its employees by the United States. See sec. 219(b)(2)(A)(iv), I.R.C. 1954. Held: The judge petitioners are not "employees" as that term is used in sec. 219(b)(2)(A)(iv) and therefore they are not qualified participants in a plan established for its employees by the United States. The…
1Opinion of the Court
Donald J. and Harriet J. Porter, et al. 1 v. Commissioner of Internal Revenue, Respondent
Porter v. Commissioner
Docket Nos. 19340-84, 19368-84, 26149-84, 29669-84, 39130-84
United States Tax Court
88 T.C. 548; 1987 U.S. Tax Ct. LEXIS 30; 88 T.C. No. 28; 8 Employee Benefits Cas. (BNA) 1374;
March 5, 1987. March 5, 1987, Filed
Decisions will be entered for the petitioners.
Deductions of contributions made by petitioners to individual retirement accounts were disallowed by respondent because respondent determined that the male petitioners, all judges of the United States entitled to hold office for…
2Cases cited28 opinions
- Buckley v. ValeoSupreme Court of the United States · 1976
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- United States Ex Rel. Toth v. QuarlesSupreme Court of the United States · 1955
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- United States v. Theodore J. Isaacs and Otto Kerner, Jr.Court of Appeals for the Seventh Circuit · 1974
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