Footnotes

¹ which required employers to pay all funding costs and provided that employees’ benefits vest in 10 years. In 1998, petitioner made a $2,000 contribution to a Keogh plan that was established prior to her employment with the State of Florida. Petitioner resided in Tampa, Florida, at the time the petition was filed. OPINION Generally, a taxpayer is entitled to deduct the amount contributed to an IRA. Sec. 219(a); sec. 1.219-1(a), Income Tax Regs. The deduction in any taxable year, however, may not exceed the lesser of $2,000 or an amount equal to the compensation

² or a plan established for its employees by the United States, by a State or political subdivision thereof, or by any agency or instrumentality of any of the foregoing. Sec. 219(g)(1), (5)(A)(i), (iii). No deduction is allowed for an active participant who is married filing a separate return and whose adjusted gross income exceeds $10,000. See sec. 219(g)(3)(iii). Petitioner contends that she is entitled to a $2,000 IRA deduction. We disagree. Petitioner made a contribution to a Keogh plan rather than an IRA. Although taxpayers with “earned income” from self-employment are eligible to deduct contributions made to a qualified Keogh plan,

³ petitioner, in 1998, received wages from the Department of Transportation and interest income but did not receive any earned income from self-employment. See secs. 401(c)(1) and (2)(A), 404(a)(8)(C), and 1402(a), (c). Accordingly, petitioner’s contributions to the Keogh plan are not