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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. 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 …
4. ERISA § 408(a)(1) (29 U.S.C. § 1108) — Exemptions from prohibited transactions
   ERISACode / StatuteJan 6, 2025related by meaning
   (a)(1) (1) administratively feasible, (a)(2) (2) in the interests of the plan and of its participants and beneficiaries, and (a)(3) (3) protective of the rights of participants and beneficiaries of such plan.
5. 89 FR 64538 — Quality Control Standards for Automated Valuation Models
   IRCFinal Rules (FR)Aug 7, 2024
   0 labor hours = 26,196 labor hours. Back to Citation 89.  (2,183 * 10 percent AVM use rate) * 40 labor hours = 8,732 labor hours. Back to Citation 90.  The assumed distribution of occupation groups involved in the actions taken by institutions in response to the proposed rule in year 1 include Financial Analysts (40 pe…
6. ERISA § 3(37)(G)(v)(III) (29 U.S.C. § 1002) — Definitions
   ERISACode / StatuteJan 6, 2025related by meaning
   (37)(G)(v)(III) (III) A plan administrator's failure to provide the notice required under this subparagraph shall be treated for purposes of section 1132(c)(2) of this title as a failure or refusal by the plan administrator to file the annual report required to be filed with the Secretary under section 1021(b)(1) of th…
7. 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…
8. ERISA § 4219(b)(2)(B)(iii) (29 U.S.C. § 1399) — Notice, collection, etc., of withdrawal liability
   PBGCCode / StatuteJan 6, 2017related by meaning
   (b)(2)(B)(iii) (iii) the reason for any change in the determination of the employer's liability or schedule of liability payments.
9. 84 FR 37508 — Definition of “Employer” Under Section 3(5) of ERISA-Association Retirement Plans and Other Multiple-Employer Plans
   ERISAFinal Rules (FR)Jul 31, 2019related by meaning
   Back to Citation 123.  The Pew Charitable Trusts, “Employer Barriers to and Motivations for Offering Retirement Benefits,” 2017. Back to Citation 124.  Transamerica Center for Retirement Studies, “All About Retirement: An Employer Survey, 17th Annual Transamerica Retirement Survey” (Aug. 2017). Back to Citation 125.  T…
10. 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…
11. ERISA § 4(b)(5) (29 U.S.C. § 1003) — Coverage
    ERISACode / StatuteJan 6, 2017related by meaning
    (b)(5) (5) such plan is an excess benefit plan (as defined in section 1002(36) of this title) and is unfunded.
12. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011
    … 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…
13. ERISA § 514(e)(3)(B)(ii) (29 U.S.C. § 1144) — Other laws
    ERISACode / StatuteJan 6, 2017related by meaning
    (e)(3)(B)(ii) (ii) the participant has a reasonable period of time, after receipt of the notice described in clause (i) and before the first elective contribution is made, to make such election, and (e)(3)(B)(iii) (iii) the notice explains how contributions made under the arrangement will be invested in the absence of …
14. 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…
15. ERISA § 411(a)(1) (29 U.S.C. § 1111) — Persons prohibited from holding certain positions
    ERISACode / StatuteJan 4, 1995related by meaning
    (a)(1) (1) as an administrator, fiduciary, officer, trustee, custodian, counsel, agent, employee, or representative in any capacity of any employee benefit plan, (a)(2) (2) as a consultant or adviser to an employee benefit plan, including but not limited to any entity whose activities are in whole or substantial part d…
16. U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner
    IRCCourt RulingsDec 13, 2018
    …ner, T.C. Memo. 1987-457, © without published opinion, 865 F.2d 255 (4th Cir. 1988)); see also sec. 183 (generally providing that if an activity is not engaged in for profit, then no deduction attributable to that activity is allowed). Focusing on the first factor, the taxpayer's profit motive, we accord greater weight…
17. 88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCProposed Rules (FR)Proposed Nov 20, 2023
    …reholder for 122 days. Thus, H's modified basis is $3.33X ($10X × 122/366). I was a shareholder for 183 days. Thus, I's modified basis is $5X ($10X × 183/366). J was a shareholder for 244 days. Thus, J's modified basis is $12.67X ($19X × 244/366). K was a shareholder for 183 days. Thus, K's is $7X ($14X × 183/366). (m)…
18. 80 FR 72006 — Savings Arrangements Established by States for Non-Governmental Employees
    ERISAProposed Rules (FR)Proposed Nov 18, 2015related by meaning
    …(S.B. 1234) (West); Oregon 2015 Session Laws, Ch. 557 (H.B. 2960) (June 2015). Back to Citation 5.  ERISA includes several express exemptions in section 4(b) from coverage under Title I, for example, for pension plans established or maintained by governmental entities or churches for their employees, certain foreign pl…
19. ERISA § 305A(h)(4)(D) (29 U.S.C. § 1085a) — Minimum funding standards
    ERISACode / StatuteJan 6, 2025related by meaning
    (h)(4)(D) (D) Election An employer may elect not to have this subparagraph apply. Such an election, once made, may be revoked only with the consent of the Secretary of the Treasury.
20. ERISA § 104(e) (29 U.S.C. § 1024) — Filing with Secretary and furnishing information to participants and certain employers
    ERISACode / StatuteJan 6, 2025related by meaning
    (e) (e) Cross references For regulations respecting coordination of reports to the Secretaries of Labor and the Treasury, see section 1204 of this title.