Memorandum Opinion
TIETJENS, Judge:
Respondent determined a deficiency of $147.93 in petitioners' Federal income tax for 1975 and imposed an excise tax of $40.34. The issues for our determination are: (1) whether taxpayer whose sole proprietorship showed a net loss may deduct his contribution to an individual retirement account; and (2) whether such contribution constitutes an excess contribution subject to the 6 percent excise tax imposed by section 4973...
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