26 C.F.R. § 1.211-1
Allowance of deductions
In computing taxable income under section 63(a), the deductions provided by sections 212, 213, 214, 215, 216, and 217 shall be allowed subject to the exceptions provided in Part IX, Subchapter B, Chapter 1 of the Code (section 261 and following, relating to items not deductible).
Notes of Decisions
Cited in 6
cases, 1981–2004 · leading case: Luman v. Comm'r, 79 T.C. 846 (Tax Ct. 1982).
Luman v. Comm'r, 79 T.C. 846 (Tax Ct. 1982). “Secs. 1.211-1 , 1.212-1, Income Tax Regs. In Epp v.”
Epp v. Comm'r, 78 T.C. 801 (Tax Ct. 1982). “The deduction provided by section 212(2) is limited in application; an expenditure is not deductible under such section if it is a personal, living, or family expense which is nondeductible under section 262 .”
Sumter v. United States, 61 Fed. Cl. 517 (Fed. Cl. 2004). “In support of her claim, the plaintiff cites IRC §§ 63(e)(2), 4 1341(a)(5)(B), 183(b)(1), 5 212(1) 6 and 26 C.F.R. § 1.211-1 . 7 *523 The assertion by the plaintiff that IRC § 63(e)(2) gives her authority to itemize proper deductions is uncontested; however, the plaintiffs…”
Contini v. Comm'r, 76 T.C. 447 (Tax Ct. 1981). “111 (1933) ; Rule 142(a), Tax Court Rules of Practice and Procedure.”
Hoelzer v. Comm'r, 43 T.C.M. 264 (Tax Ct. 1982). “Petitioners are not entitled to deduct expenses under section 212(1) or (2) if the expenses are nondeductible under section 262 as personal, living, or family expenses. Sections 1.”
Hicks v. Comm'r, 43 T.C.M. 1081 (Tax Ct. 1982). “Petitioner may not deduct under section 212 expenses *569 which are personal in nature.”
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