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Kalodner v. Commonwealth
Citations: 636 A.2d 1230; 161 Pa. Commw. 226; 1994 Pa. Commw. LEXIS 4
Court: Commonwealth Court of Pennsylvania; January 5, 1994; Pennsylvania; State Appellate Court
Philip P. and Margaret B. Kalodner (Taxpayers) filed exceptions to a judgment favoring the Commonwealth of Pennsylvania regarding their 1986 Pennsylvania Income Tax Return. The Taxpayers, self-employed sole proprietors, deducted $43,240 in contributions to their individual retirement plans, which the Department of Revenue later deemed non-deductible. This decision was upheld by the Department’s Board of Appeals and subsequently by the Board of Finance and Revenue, which required the Taxpayers to report these contributions as taxable income due to their status as non-employees under the Tax Reform Code of 1971. The Taxpayers appealed to the court, arguing that the Department's regulations misinterpreted the Tax Code and that the Tax Code itself was unconstitutional under state and federal law. The court upheld the regulation, finding it reasonable and not in violation of equal protection or uniformity provisions of the constitutions. The Taxpayers submitted exceptions to this judgment, reiterating their previous arguments about the regulation's validity and the Tax Code's constitutionality. Upon review, the court affirmed its earlier decision, dismissing the Taxpayers' exceptions and directing judgment in favor of the Commonwealth. The dismissal occurred on January 6, 1994, before the conclusion of Judge Palladino’s service.