§1427

ceiving spouse) re- ceives less compensation than the other spouse, the amount allowable as a deduction for contributions to the lesser-receiv- ing spouse’s IRA shall not exceed $2,000. See Small Business Job Protection Act of 1996, Pub. L. 104-188, sec. 1427(a), 110 Stat. 1802. Under sec. 219(c) as in effect for petitioners’ taxable year 1997, petitioners are entitled to deduct the $2,000 contrib- uted to Ms. Whitehead’s IRA regardless of whether she received any compensation during that year.

t recoupment by the amount of the affirmative recovery, and nevertheless the District Court didn't do so. United States v. Timber Access Indus. Co., supra, which is cited and discussed at some length in 6 Wright et al., Federal Practice & Procedure, sec. 1427, at 197-198 n.8 (2d ed. 1990), illustrates the point that another affirmative recovery with its own independent jurisdictional basis, even when it arises from the same transaction from which a recoupment defense or counterclaim arises, does

t recoupment by the amount of the affirmative recovery, and nevertheless the District Court didn’t do so. United States v. Timber Access Indus. Co., supra, which is cited and discussed at some length in 6 Wright et al., Federal Practice & Procedure, sec. 1427, at 197-198 n.8 (2d ed. 1990), illustrates the point that another affirmative recovery with its own independent jurisdictional basis, even when it arises from the same transaction from which a recoupment defense or counterclaim arises, does