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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IMPORTANT NOTICE / DISCLAIMER This Contract is fictitious and prepared for the study purpose of the students of IIT Delhi. It does not have any legal authenticity and is not valid in the court of law or any part of India. Memorandum of Understanding This Memorandum of Understanding is executed at Ahmedabad on this 16.05.2016 by and between Balrampur Chini Mills Ltd.‚ a private limited company incorporated under the provisions of the Companies Act‚ 2013 on dated 14 July 1975 bearing CIN No
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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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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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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
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-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
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MEMORANDUM To: S. Partner‚ C.P.A. From: Nicole J. Badalamenti‚ J. Accountant Date: August 27‚ 2012 Subject: Mr. B. Potato I FACTS Mr. B. Potato‚ a wealthy real estate investor‚ recently purchased a house on a parcel of land for $400‚000. The house was appraised at a value of $300‚000 and the land had an appraised value of $100‚000. Mr. Potato plans to tear down the house and replace it with a new house worth $1‚500‚000 with the intentions of living in
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