§76 — Repealed. Pub. L. 94–455, title XIX, § 1901(a)(14), Oct. 4, 1976, 90 Stat. 1765]

r's favor), rev'g 86 T.C. 669 (1986); Rockefeller v. Commissioner, 676 F.2d 35, 42 (2d Cir. 1982) ("Courts have consistently reaffirmed that public policy demands a broad and flexible interpretation ofstatutes governing charitable contributions."), § 76 T.C. 178 (1981). We are interpreting a regulatoryprovision, not a statute. The statute is silent as to the effect ofa possible extinguishment ofthe conservation easement. In the event ofan extinguishment the perpetuity requirement could not be me

593 (1981); Torre v. Commissioner, T.C. Memo. 2001-218, 2001 WL 904250, at *3, M, 52 F. App'x 965 (9th Cir. 2002); see also Pulvers v. Commissioner, 407 F.2d 838, 839 (9th Cir. 1969), 48 T.C. 245 (1967). As a result, an "other casualty" is a loss arising from something "sudden, unexpected, or unusual,"9 see, e.g., Maher, 680 F.2d at 9 The

2015). During 2015 Mr. Skaggs earned income from working part time, performing custodial duties for the hospital. Mr. Skaggs filed a tax return for 2015 reporting $2,921 in income, including $62 in taxes withheld by his employer. Mr. Skaggs also claimed an EITC of$224 on his 2015 return, for a total refund of$286. On June 8, 201

76-6-405 (1978)) . - 9 - Petitioners also argue that because Mr . Green himself had ;no qualifications in any trade, Mr . Green's promotional materials ; fraudulently reflected that he would personally supervise the construction of their house . We disagree . Even though Mr. Green has admitted that he lacked the technical ability to perform m

They are to be treated as partnerships under section 76l(a) even though the underlying activities of the partnerships lacked a profit objective under section 183.

d or capable of identification that its title can pass to the trustee upon actual delivery of the trust corpus. In re Schnitz, 52 Bankr. 951, 955 (W.D. Mo. 1985); Newton v. Wimsatt, 791 S.W. 2d 823, 827 (Mo. Ct. App. 1990); cf. 1 Restatement, supra sec. 76; Bogert, supra sec. 113, at 323-329. Thus, only the person who has title or interest in property can make it the subject matter of a trust. Buhl v. Kavanagh, 118 F.2d 315, 320 (6th Cir. 1941); Brainard v. Commissioner, 91 F.2d 880, 881 (7th Ci

They are to be treated as partnerships under section 76l(a) even though underlying activity of the partnerships lacked a profit objective under section 183.

d or capable of identification that its title can pass to the trustee upon actual delivery of the trust corpus. In re Schnitz, 52 Bankr. 951, 955 (W.D. Mo. 1985); Newton v. Wimsatt, 791 S.W. 2d 823, 827 (Mo. Ct. App. 1990); cf. 1 Restatement, supra sec. 76; Bogert, supra sec. 113, at 323-329. Thus, only the person who has title or interest in property can make it the subject matter of a trust. Buhl v. Kavanagh, 118 F.2d 315, 320 (6th Cir. 1941); Brainard v. Commissioner, 91 F.2d 880, 881 (7th Ci

d or capable of identification that its title can pass to the trustee upon actual delivery of the trust corpus. In re Schnitz, 52 Bankr. 951, 955 (W.D. Mo. 1985); Newton v. Wimsatt, 791 S.W. 2d 823, 827 (Mo. Ct. App. 1990); cf. 1 Restatement, supra sec. 76; Bogert, supra sec. 113, at 323-329. Thus, only the person who has title or interest in property can make it the subject matter of a trust. Buhl v. Kavanagh, 118 F.2d 315, 320 (6th Cir. 1941); Brainard v. Commissioner, 91 F.2d 880, 881 (7th Ci

They are to be treated as partnerships under section 76l(a) even though underlying activity of the partnerships lacked a profit objective under section 183.