§1251 — Repealed. Pub. L. 98–369, div. A, title IV, § 492(a), July 18, 1984, 98 Stat. 853]

23 cases·8 followed·1 distinguished·14 cited35% support

[§ 1251. Repealed. Pub. L. 98–369, div. A, title IV, § 492(a), July 18, 1984, 98 Stat. 853] Section, added Pub. L. 91–172, title II, § 211(a), Dec. 30, 1969, 83 Stat. 566; amended Pub. L. 92–178, title III, § 305(a), Dec. 10, 1971, 85 Stat. 524; Pub. L. 94–455, title II, § 206(a), (b)(1), (2), title XIV, § 1402(b)(1)(Z), (2), title XIX, §§ 1901(b)(3)(K), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1535, 1732, 1793, 1834; Pub. L. 97–354, § 5(a)(36), Oct. 19, 1982, 96 Stat. 1695; Pub. L. 98–369, div. A, title X, § 1001(b)(23), (e), July 18, 1984, 98 Stat. 1012, related to gain from disposition of property used in farming where farm losses offset nonfarm income. Statutory Notes and Related Subsidiaries Effective Date of RepealRepeal applicable to taxable years beginning after Dec. 31, 1983, see section 492(d) of Pub. L. 98–369, set out as an Effective Date of 1984 Amendment note under section 170 of this title.

  • Treas. Reg. §Treas. Reg. §1.1251-1 General rule for treatment of gain from disposition of property used in farming where farm losses offset nonfarm income
  • Treas. Reg. §Treas. Reg. §1.1251-1(a) Applicability.
  • Treas. Reg. §Treas. Reg. §1.1251-1(b) Ordinary income—(1) General rule.
  • Treas. Reg. §Treas. Reg. §1.1251-1(c) Instances of nonapplication—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.1251-1(d) Partnerships.
  • Treas. Reg. §Treas. Reg. §1.1251-1(e) Relation of section 1251 to other provisions—(1) General.
  • Treas. Reg. §Treas. Reg. §1.1251-1(i) §1.1251-1(i)
  • Treas. Reg. §Treas. Reg. §1.1251-2 Excess deductions account
  • Treas. Reg. §Treas. Reg. §1.1251-2(a) §1.1251-2(a)
  • Treas. Reg. §Treas. Reg. §1.1251-2(b) The other spouse shall have an excess deductions account equal to the amount prescribed in subdivision (i) of this subparagraph minus the amount of such deficit.
  • Treas. Reg. §Treas. Reg. §1.1251-2(c) Property held by a taxpayer on the first day of a one-year period which property becomes farm recapture property in the hands of such taxpayer during such one-year period shall be considered to be farm recapture property on each day of such one-year period.
  • Treas. Reg. §Treas. Reg. §1.1251-2(d) For purposes of this subparagraph (3), if during a taxable year property becomes subject to the requirements of subparagraph (1)(ii) of this paragraph, it shall be considered subject to such requirements on each day it is held during such year.
  • Treas. Reg. §Treas. Reg. §1.1251-2(e) Transfer of excess deductions account—(1) Certain corporate transactions—(i) In general.
  • Treas. Reg. §Treas. Reg. §1.1251-2(f) Joint return—(1) Joint excess deductions account.
  • Treas. Reg. §Treas. Reg. §1.1251-2(i) §1.1251-2(i)
  • Treas. Reg. §Treas. Reg. §1.1251-2(v) Definitions and certain special rules.
  • Treas. Reg. §Treas. Reg. §1.1251-3 Definitions relating to section 1251
  • Treas. Reg. §Treas. Reg. §1.1251-3(a) §1.1251-3(a)
  • Treas. Reg. §Treas. Reg. §1.1251-3(b) Farm net loss—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.1251-3(c) Farm net income.
  • Treas. Reg. §Treas. Reg. §1.1251-3(d) Nonfarm adjusted gross income—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.1251-3(e) Trade or business of farming—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.1251-3(i) §1.1251-3(i)
  • Treas. Reg. §Treas. Reg. §1.1251-4 Exceptions and limitations
  • Treas. Reg. §Treas. Reg. §1.1251-4(a) Exception for gifts—(1) General rule.

23 Citing Cases

§ 1251(a)(1)(H) authorized the Attorney General, at her discretion, to waive the deportation of certain eligible aliens. By settled practice, the Immigration and Naturalization Service (INS) did not consider an eligible alien’s entry fraud when determining whether to waive deportation. Yueh-Shaio Yang entered the United States unlawfully in 1978, a

George B. Dengin, Petitioner T.C. Memo. 2023-31 · 2023

at 1078–79 (holding that the taxpayer fulfilled the essential requirements of section 1251(b)(4) even though they failed to attach the election to their tax returns because their returns showed that they used the accrual method of accounting).

from the sale. Sec. 1374. (An S corporation converted in 2002--the year of RLC’s incorporation--would have had to wait seven years to sell its assets to avoid paying this tax. See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111- 5, sec. 1251(a), 123 Stat. at 342.) A C corporation also cannot avoid double taxation on its built-up profits by converting to an S corporation. Instead it must track the S corporation and C corporation profits for distribution purposes. Sec. 1368. And i

from the sale. Sec. 1374. (An S corporation converted in 2002--the year of RLC’s incorporation--would have had to wait seven years to sell its assets to avoid paying this tax. See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111- 5, sec. 1251(a), 123 Stat. at 342.) A C corporation also cannot avoid double taxation on its built-up profits by converting to an S corporation. Instead it must track the S corporation and C corporation profits for distribution purposes. Sec. 1368. And i

from the sale. Sec. 1374. (An S corporation converted in 2002--the year of RLC’s incorporation--would have had to wait seven years to sell its assets to avoid paying this tax. See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111- 5, sec. 1251(a), 123 Stat. at 342.) A C corporation also cannot avoid double taxation on its built-up profits by converting to an S corporation. Instead it must track the S corporation and C corporation profits for distribution purposes. Sec. 1368. And i

from the sale. Sec. 1374. (An S corporation converted in 2002--the year of RLC’s incorporation--would have had to wait seven years to sell its assets to avoid paying this tax. See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111- 5, sec. 1251(a), 123 Stat. at 342.) A C corporation also cannot avoid double taxation on its built-up profits by converting to an S corporation. Instead it must track the S corporation and C corporation profits for distribution purposes. Sec. 1368. And i

from the sale. Sec. 1374. (An S corporation converted in 2002--the year of RLC’s incorporation--would have had to wait seven years to sell its assets to avoid paying this tax. See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111- 5, sec. 1251(a), 123 Stat. at 342.) A C corporation also cannot avoid double taxation on its built-up profits by converting to an S corporation. Instead it must track the S corporation and C corporation profits for distribution purposes. Sec. 1368. And i

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