In this case, the petitioner claimed that the statutory limits on deductibility of IRA contributions were unconstitutional. The court disagreed, and held that no deduction was allowed for IRA contributions because the petitioner's wife was an active participant in her employer's sponsored retirement plan and the couples combined MAGI was greater than the phaseout ceiling. While the petitioner claimed that he never received airline "thank you" reward points, the court determined that the value had to be included in income. Shankar v. Comr., 143 T.C. No. 5 (2014).