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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November 16‚ 2012 TAX FILE MEMORANDUM FROM SUBJECT Peaceful Pastures Funeral Home‚ INC. taxpayer engagement. FACT Peaceful Pastures Funeral Home‚ INC (“Peaceful”) has designed an approach that allows customers to prepay for their funeral goods and services. Under this program‚ the customer pays in advance for the goods and services that will be provided at the time of their death‚ often at a significant discount. Under the terms of the contract‚ the payments are refundable at the contract purchaser’s
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MEMORANDUM TO: Neil S. Braun‚ Dean‚ Lubin School FROM: Zhuojing Lu‚ MS student of Lubin School DATE: September17‚2011 SUBJECT: Why Lubin School Need a CPA Exam Study Forum As a first year student of Lubin school‚ I have noticed that there is no CPA exam study forum. The AICPA website shows a pass rate of 40%-45% per section. It is so important for accounting students to pass such a rigorous examination. Beginning with CPA exam registration‚ to the technical knowledge
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Technical Writing Project Cover Sheet Capstone Proposal Project Name: Network Security Survey Student Name: Peter Planica Degree Program: Information Technology – Security Emphasis Mentor Name: Ted Reasoner Capstone Project Waiver/Release Statement Acknowledgement It is the policy of Western Governors University (“WGU”) that student Capstone projects should not be based upon‚ and should not include‚ any proprietary or classified information or material belonging to your employer or any other
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CENTURY Robert Kaplan makes a compelling argument in his book‚ “The Coming Anarchy‚” that global environmental and social factors such as resource depletion‚ overpopulation‚ crime‚ and tribalism are the most pressing national security issues in the 21st century. He cites numerous examples of crime‚ war‚ and destitution in failing states of West Africa as well as protracted conflicts in the Balkans‚ and Central Asia. However‚ the environmental and social factors described by Kaplan are not security
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1. The purpose of this memorandum is to discuss and reflect upon my experiences as a leader with leadership to date. 2. Firstly‚ the characteristics that encompass who I am as a leader today are as follows: conviction‚ integrity‚ consistency‚ direction‚ and empathy. The traits represent facets of leadership by which I extend my command climate and philosophy of credibility and trust. Altogether‚ my philosophy and characteristics encapsulate and reinforce who I am as a leader today. 3. Moreover
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February 25‚ 2014 IT 220 Internet Concepts James Van Capstone Checkpoint. Capstone CheckPoint • Locate two Web sites that you feel exhibit exemplary design features and explain why you selected each site. What design features stand out on each site? Are these features unique to the Web sites you selected or are they used by their competitors or similar sites? Are these design features used to be visual appealing or to promote usability? How can usability be determined? • Write
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Memorandum Date: October 18‚ 2016 To: Candie Cardigan‚ CARDWARE Inc. From: Robyn Broadwater Re: NEGLIGENCE _____________________________________________________________________________ With this memorandum we would like to convey about the new sweater line of cardwares‚ Meaning of the terms utilized by the Restatement is critical. The word "purpose" is used all through the Restatement to imply that the performer covers the results of his or her demonstration or trusts those outcomes are significantly
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Cohort: Baltic Ocean Team: Baltic Petrels (B2) Team Members: Anesha Agarwal‚ Ana Avelar‚ Nicholas Baladis‚ Clifford Chow‚ Joseph McGovern‚ Rachit Parekh Memorandum – CML19 AOG To: VP of Operations As of January 13‚ 19:30h aircraft CML19 (Boeing 767) has been designated AOG due to a failure in the support assembly (part of the thrust reverser). As a result‚ flight SCL-MIA 067 scheduled for 21:55h will have to be canceled. We have conducted a thorough analysis of all viable strategies‚ and have concluded
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Capstone Analysis Roy J Rosalez Criminal justice 210 January 21‚ 2015 James Weidig Capstone Analysis Throughout history law enforcement has always been plagued with the ongoing dangers and challenges that occur on a daily basis. From the basic traffic stop‚ domestic violence call‚ and up to the critical moment of a standoff with a violent offender. Despite the dangers of the job and the mounting challenges law-enforcement officers face‚ more than 800‚000 sworn law enforcement officers across our
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