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70 documents · 0.16sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    183 generally limits allowable - 7 - deductions attributable to the activity to the extent of gross income generated by the activity. See sec. 183(b). The test for determining whether an individual is carrying on an activity for profit is whether the taxpayer's actual and honest objective in engaging in the activity is…
  2. T.C. Summary Opinion 2015-48 — Joshua W. Pingel v. Commissioner
    IRCCourt RulingsAug 10, 2015
    …, supplementing T.C. Memo. 2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144. - 12 - II. Section 1839 A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and necessary expenses incurred in conducting a trade or business or for the production of income. Secs. 162(a), 212(1). To determin…
  3. Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c…
    IRCNoticesMay 6, 2024
    … and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
  4. T.C. Summary Opinion 2002-39 — Joseph R. & Diana K. Trudel v. Commissioner
    IRCCourt RulingsApr 15, 2002
    …e costs of self-employed health insurance. Discussion I. Activity Not Engaged in for Profit Section 183(a) provides that if an activity engaged in by an individual is not engaged in for profit, no deduction attributable to such activity shall be allowed, except as provided in section 183(b). In the case of an activity …
  5. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …   See Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​05/​03/​provider-charges-relative-to-medicare-rates-2012-2018/​. Back to Citation 210…
  6. REG-141075-09 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Proposed regulations under section 83 …
    IRCProposed Rules (FR)Proposed Jun 18, 2012related by meaning
    hief Counsel for Advocacy of the Small Business Administration for comment on their impact on small business. Comments and Requests for Public Hearing Before these proposed regulations are adopted as final regulations, consideration will be given to any written (a signed original and eight (8) copies) or electronic com…
  7. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011★ strong match
    … taxpayer begins training and showing horses. On January 4, 2011, the taxpayer elects under section 183(e) to defer the determination of whether the horse-related activity will be presumed (under section 183(d)) to be engaged in for profit. Accordingly, under section 183(e)(1), a determination of whether the section 18…
  8. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …gaged i n for profit . If an activity is not engaged in for profit, deductions are limited. Section 183(a) provides that, if an activity is not engaged in for profit, “no deduction attributable to such activity shall be allowed,” except to the extent of income from the activity as provided in section 183(b). See also T…
  9. 88 FR 11386 — Extension of Import Restrictions Imposed on Certain Archaeological Material of Belize
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    notice of proposed rulemaking is required, the provisions of the Regulatory Flexibility Act (5 U.S.C. 601 et seq.) do not apply. Executive Order 12866 CBP has determined that this document is not a regulation or rule subject to the provisions of Executive Order 12866 because it pertains to a foreign affairs function of…
  10. 87 FR 80097 — Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities
    IRCProposed Rules (FR)Proposed Dec 29, 2022related by meaning
    ). However, other personnel from the Treasury Department and the IRS participated in their development. List of Subjects in 26 CFR Part 1 Income taxes Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 1 as follow…
  11. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
  12. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
    e taxes Pensions Reporting and recordkeeping requirements 26 CFR Part 301 Employment taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR parts 1, 53, 54 and 301 are proposed to be amended as follows: PART 1…
  13. 89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
    IRCFinal Rules (FR)Apr 3, 2024
    …hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2020/​08/​04/​fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
  14. 75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Jun 16, 2010related by meaning
    URE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *. Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows: § 301.6404-0 Table of Contents. * * * * * § 301.6404-4 Suspension of interest and c…
  15. T.C. Memo. 1996-146 — Lloyd Patterson v. Commissioner
    IRCCourt RulingsMar 25, 1996
    …eicer v. Commissioner , supra . The regulations set - 5 - forth various factors to consider. Sec. 1.183-2(b), Income Tax Regs. On this record, we must conclude that petitioner did not engage in his apartment house activity in 1991 for profit within the meaning of sections 162, 212, or 183. We turn to section 183(b) whi…
  16. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    Court, the two cases were consolidated for hearing on the motions to dismiss. The hearing was held on November 29, 2004, in San Francisco, California. Discussion Section 6033(a)(1) requires an organization exempt from taxation under section 501(a) to file."an annual return, stating specifically the ite s of gross incom…
  17. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …nal gambler, the taxpayer must have engaged in gambling with the objective of making a profit. Sec. 183(a), (b), and (c); Commissioner v. Groetzinger, 480 U.S. 23, 35 (1987); sec. 1.183-2(a), Income Tax Regs. Although a reasonable expectation of profit is not required, the taxpayer's profit objective must be actual and…
  18. 88 FR 11388 — Extension of Import Restrictions on Archaeological and Ethnological Materials of Libya
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    nction of the United States, as described above, and therefore is specifically exempted by section 3(d)(2) of Executive Order 12866. Signing Authority This regulation is being issued in accordance with 19 CFR 0.1(a)(1), pertaining to the Secretary of the Treasury's authority (or that of his/her delegate) to approve reg…
  19. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
  20. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002related by meaning
    es on private income having its source in the receiving State and capital taxes on investments made in commercial undertakings in the receiving State; Similarly, article 49(d) of the Vienna Convention on Consular Relations (article 49), 21 U.S.T. at 108, provides that consular officers and employees are exempt from all…