Kobell v. Comr., T.C. Memo. 2011-66

(taxpayer not entitled to deduction for IRA contribution; for year at issue taxpayer listed "investor/trader" as occupation and had income from  corporate bond interest, dividends and Social Security benefits; contribution deduction limited to lesser of deductible amount or taxpayer's compensation (earned income) includable in gross income; Social Security is not compensation, and dividends and interest only constitutes compensation if taxpayer dealer in stocks or securities and dividends/interest received in course of trade or business as dealer; taxpayer held bonds that were not for sale to customers and engaged in only three stock transactions, had no customers and no place of business - taxpayer not a dealer). 

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