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
Premium Tax Taxation in the United States Internal Revenue Service
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
Premium Tax refund Tax Money
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
Premium Student University Education
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
Premium Leadership Critical thinking Non-commissioned officer
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
Premium Law Performing arts Statute
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
Premium Decision theory The Delivery Delay
Memorandum To: Senior Management‚ JMZ Adventure Ecotours From: IT Department‚ JMZ Adventure Ecotours Date: 4/20/2013 Re: Information Security Risk Assessment Findings The IT department was recently given the task of performing an information security risk assessment in order to help guide management in prioritizing their approach to mitigating security risks for JMZ Adventure Ecotours. This memo will show the results of that analysis; identifying the greatest IT vulnerabilities and risks within
Premium Security Information security Risk
this is half and half. This is because it was wrong to take of photo of her English teacher without her knowing but he did not doing anything inappropriate to the photo. There is a girl in Natalie’s class who likes to dress creatively. On Tuesday‚ Natalie Tweets a rude comment about the outfit she wore that day along with #whatnottowear and #epic fail. That is harmful. This is because this is a mean comment and if hurts the person who wore the dress. You should not say anything mean about someone online
Premium Woman Girl Family
Memorandum A restaurant is a type of business that I would like to own after my graduation. My entire childhood was based on family restaurant‚ because my parents owned one. I liked the busy life style‚ and a place full of different people. I also liked challenges associated with it‚ and new ways of making the place better and more competitive. When I came to USA‚ I understood that this is what I want to do here‚ and I know that with some of my unique ideas I am able to create a successful
Premium Restaurant Food Marketing
-versus - PETER PASCUAL Defendant-Appellant‚ x-----------------------------------x MEMORANDUM Defendant-appellant‚ Peter Pascual‚ through counsel‚ in compliance with the Honorable Court’s order‚respectfully submits this Memorandum Prefatory Statement Plaintiff-appellee RAUL GERONIMO and ANNA GERONIMO in the instant case claims‚ with the lower Court’s sanction‚ that there should be an annulment of
Premium Contract 2009