§214 — Repealed. Pub. L. 94–455, title V, § 504(b)(1), Oct. 4, 1976, 90 Stat. 1565]

The joint filing requirement is very similar to a requirement under former section 214, which allowed a deduction for child care expenses for married taxpayers but only ifthey filedjoint returns.

under section 214 of the Revenue Act of 1921”); Farish v. Commissioner, 103 F.2d 63, 65 (5th Cir. 1939) (holding that “[a]s to both partnerships we conclude that they were transactions entered into for profit and the losses incurred . . . were deductible” under section 23 of the Revenue Act of 1932), rev’g 36 B.T.A. 1114 (1937); Bessenyey v. Commissioner

214.1(a)(3)(ii) (2012). One can envision the following situation. A student from Europe lives in a dormitory during the academic year, at the conclusion of which he must move out ofhis room. He comes to the United States on the SWTP and spends the summer in this country. In the fall he returns to his home country and moves into another dormito

214.1(a)(3)(ii) (2012). One can envision the following situation. A student from Europe lives in a dormitory during the academic year, at the conclusion of which he must move out ofhis room. He comes to the United States on the SWTP and spends the summer in this country. In the fall he returns to his home country and moves into another dormito

214.1(a)(3)(ii) (2012). One can envision the following situation. A student from Europe lives in a dormitory during the academic year, at the conclusion of which he must move out ofhis room. He comes to the United States on the SWTP and spends the summer in this country. In the fall he returns to his home country and moves into another dormito

s tendency to benefit favored entities." * * * In 1921, there was no generally available exclu- sion for employer-provided housing, and a minister receiving housing from his current church clearly would not have been eligible for the deduction under Section 214(a) of the 1921 Revenue Act for traveling expenses, including lodging, "while away from home in the pursuit of a trade or business." 42 Stat.

’s tendency to benefit favored entities.” * * * In 1921, there was no generally available exclusion for employer-provided housing, and a minister receiving housing from his current church clearly would not have been eligible for the deduction under Section 214(a) of the 1921 Revenue Act for traveling expenses, including lodging, “while away from home in the pursuit of a trade or business.” 42 Stat.

- 5 - While in Florida, petitioner obtained a license to buy and sell real estate. Petitioner went to Iran about once every 2 years during the years he was an undergraduate student. He stayed 2-3 weeks per visit. In the late 1960s and early 1970s, petitioner told his parents that he intended to reside in the United States. Petiti

- 5 - While in Florida, petitioner obtained a license to buy and sell real estate. Petitioner went to Iran about once every 2 years during the years he was an undergraduate student. He stayed 2-3 weeks per visit. In the late 1960s and early 1970s, petitioner told his parents that he intended to reside in the United States. Petiti

terest on its books, but did not report actual income, but merely a loss of anticipated earnings. * * * See also Beekman v. Commissioner, 17 B.T.A. 643, 648 (1929). 8The statute under construction in Collin v. Commissioner, 1 B.T.A. 305 (1925), was sec. 214(a)(7) of the Revenue Act of 1918, ch. 18, 40 Stat. 1067. - 12 - such interest for tax purposes, could not claim a bad debt deduction for the accrued interest. See Dist. Bond Co. v. Commissioner, 39 B.T.A. 739, 746 (1939), affd. in part on thi

terest on its books, but did not report actual income, but merely a loss of anticipated earnings. * * * See also Beekman v. Commissioner, 17 B.T.A. 643, 648 (1929). 8The statute under construction in Collin v. Commissioner, 1 B.T.A. 305 (1925), was sec. 214(a)(7) of the Revenue Act of 1918, ch. 18, 40 Stat. 1067. - 12 - such interest for tax purposes, could not claim a bad debt deduction for the accrued interest. See Dist. Bond Co. v. Commissioner, 39 B.T.A. 739, 746 (1939), affd. in part on thi

1520, 1549. The committee reports described the situation in pertinent part as follows: Present law * * * * * * * If, at the end of a given year, the taxpayer has not conducted the activity for 5 (or 7) years, a special provision allows the taxpayer to elect to postpone a determination as to whether he can benefit by this presump