In recent columns you have discussed the new IRA requirements as they apply to persons no longer having "earned income," which doesn't include either investment or retirement income so that neither of these qualify for an IRA deduction. Yet this same income, which doesn't qualify for an IRA, is added to "earned income" and may prevent an IRA deduction because of the Adjusted Gross Income maximums. Don't you feel this is unfair, since the AGI maximum takes into consideration all types of income, both earned and unearned? I know many retired individuals who have started a second career and now fall into this trap. Please let me know if I am missing something.

Well, you're not missing any of the facts. The situation is as you describe it: Investment income and retirement pay, when added to earned income, may disqualify an IRA even though those types of income may not be used to qualify someone for an IRA. But you are missing some of the philosophy behind the concept of the Individual Retirement Account. The IRA was intended as an incentive to encourage people not covered by pension plans to build retirement plans of their own. In the early years, anyone covered by any kind of plan was not eligible for an IRA. In 1981 the Economic Recovery Tax Act that cut tax rates also opened the door for any worker to make tax-deductible contributions to an IRA. The Tax Reduction Act of 1986 was designed to be revenue-neutral -- that is, to produce the same total revenue for the government as before. To offset revenue lost through cuts, the 1986 tax bill had to generate compensating income. One of the agreements reached in designing this massive tax bill was to go part way back to the original IRA concept.

So now the rule is that if you do not have a pension plan at work, you may contribute to an IRA and claim a tax deduction. But if you are covered by some form of employer's retirement plan you may only deduct IRA contributions on your tax return if your income, from all sources, is under the ceiling.

Since the IRA is a retirement planning mechanism, it is not unreasonable to exclude retirement pay itself from the income that qualifies you for an IRA deduction. But since the aim of the program was a tax incentive to help ensure adequate income for workers after retirement, it is not unreasonable to include a means test and limit the tax break to those who might not otherwise have an adequate retirement income.

My questions are related to moving money among various IRA accounts at different institutions. I know I can make an unlimited number of "transfers" from one institution to another, but this can take four to six weeks. The alternative, "rollovers," are limited to one per year. Does the once-a-year rule apply to each account separately or to all accounts as a group? If it applies separately and I roll over from one account to a second, what is the effect on my ability to roll over from the second account to a third?

The once-per-year rollover rule applies to each account separately; the governing date is the date you receive the distribution, not the date you reinvest the money in another account. And a rollover from one account to another does not start a clock ticking for the second account. The once-a-year limitation applies only to the account from which the funds were withdrawn, so no waiting period is applied against a rollover from the second account.

With regard to your article on Oct. 5: Meals while doing volunteer work for a charitable organization are not deductible unless the person was away from home overnight, according to IRS Publication 17.

You -- and the IRS -- are right. You may deduct the cost of transportation when contributing your services, as I wrote. But you may not claim the cost of lunches or other meals unless you are traveling away from home overnight, as this sharp-eyed reader pointed out. I apologize for the error.Abramson is a family financial counselor and tax adviser. Questions of general interest on tax matters, insurance, investments, estate planning and other aspects of family finances will be answered in this column. Advice cannot be given on an individual basis. Address all questions to E.M. Abramson, The Washington Post, Business News, 1150 15th St. NW, Washington, D.C. 20071