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PAVEL v. COMMISSIONER

Docket No. 11407-77.

40 T.C.M. 76 (1980)

T.C. Memo. 1980-105

Elmer L. and Georgia Pavel v. Commissioner.

United States Tax Court.

Filed April 2, 1980.

Attorney(s) appearing for the Case

Elmer L. Pavel, pro se, P.O. Box 1913, Orlando, Fla. Stuart B. Kalb, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1975 in the amount of $480.25. The issues for decision are (1) whether petitioner, Elmer L. Pavel, was an active participant in a qualified pension plan during 1975 so that his payments to an individual retirement account in that year were not deductible; and (2) whether petitioners are liable for the excise tax on excess contributions...

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