Memorandum-to-the-File Re: Contingent Liabilities in a Section 351 Transfer Case Facts: An accrual basis taxpayer Charles Cho engages in a Section 351 transaction with the newly-formed Patten Corporation. In the transaction‚ Cho transferred his gas station to Patten‚ in exchange for the stock of Patten and assumption of the contingent environmental liabilities. The land underneath the gas station has potential environmental problems but Cho did not take any remediation to fix environmental problems
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become better people. A lot of people believe that when they get their dream career and their dream lives they would be happy beyond measures‚ but unfourtanely life does not work out that way. You see that stage of loneliness and isolation can happened at any stage in your life child hood‚ adolescence‚ adult hood. We all as human beings must experience this only because it makes us stronger; it opens our eyes to the world. “Cathedral” by Raymond Carver and “Sonny’s Blues “by James Baldwin are two exemplary
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INTERNET IN OUR DAILY LIFE There is a big influence of technique on our daily life. Electronic devices‚ multimedia and computers are things we have to deal with everyday. Especially the Internet is becoming more and more important for nearly everybody as it is one of the newest and most forward-looking media and surely "the" medium of the future. Therefore we thought that it would be necessary to think about some good and bad aspects of how this medium influences us‚ what impacts it has on our social
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The religious life of many Hindus is focused on devotion to God (perceived as Brahman‚ Shiva‚ Vishnu‚ or Shakti) or several gods. This devotion usually takes the form of rituals associated with sculptures and images of gods in home shrines. More philosophically-minded Hindus ignore the gods altogether and seek Realization of the Self through intense meditation. Still others focus primarily on fulfilling the social and moral duties appropriate to their position in life. These various approaches
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The Arts‚ which involve visual arts‚ music‚ dance‚ and drama‚ have been in existence for as long as humans walked the earth. The Arts will always remain a huge part of cultural society‚ for‚ no matter how technologically advanced the world becomes‚ nothing can replace the experience of viewing or interacting with the arts. In today’s world‚ the words “teaching”‚ and “learning”‚ may spark one to simply deduce “textbook education.” My definition of “textbook education” is what students attain
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technological advances‚ which is a fairly new academic development in America. Poor Remain Poor o While general access is not denied‚ some children may not be exposed to computers and other technology because of socio-economic status. A child may live in a home without a computer‚ and chances are he will attend a poor school district with limited numbers of computers available. A student may get to use a computer for a short time‚ or only as a once-a-week activity instead of a regular class period
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Pros and Cons of Being a Hedonist Eater Eating anything I want at any time I want is the way I live my life no matter the consequences. Hedonism describes my eating habits because I eat anything that gives me pleasure no matter what the circumstances. According to Dictionary.com the definition of “hedonist” is “a person whose life is devoted to the pursuit of pleasure and self-gratification”. By following the idea of Hedonism‚ I eat for pleasure and not to conform to societies’ view of
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have limited time‚ attention and accuracy—which means they are not very good at capturing data about things in the real world. Our economy‚ society and survival aren ’t based on ideas or information—they ’re based on things. Ideas and information are important‚ but things matter more. Yet today ’s information technology is so dependent on data originated by people that our computers know more about ideas than things. If we had computers that knew everything there was to know about things—using the
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Whether it is an advertisement on television‚ an aisle in Wal-mart‚ or a collection in a student’s friend’s room‚ the ongoing increase of the use of video games among today’s teenagers is stealthily accumulating. Even though there may be some ratings on games for teenagers today‚ I believe that the ratings should become more emphasized‚ and parents should have stricter guidance on the buying of games. Increasing the rating system for video games and having stricter parental guidance would be influential
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PMRF Republic of the Philippines PHILIPPINE HEALTH INSURANCE CORPORATION PHILHEALTH MEMBER REGISTRATION FORM Citystate Centre Building‚ 709 Shaw Boulevard‚ Pasig City Healthline 441-7444 www.philhealth.gov.ph (October 2013) PhilHealth Identification Number (PIN) IMPORTANT REMINDERS: 1. Your PhilHealth Identification Number (PIN) is your unique and permanent number. 2. The issuance of the PIN does not automatically qualify you or your dependents to be entitled to NHIP benefits. 3. Always use
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