...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 before the exchange. • A year later, Patten pays a third party $100,000 for environmental clean-up costs to remediate the site. • The transaction does not have tax avoidance purpose. Issues The main issue encountered in this case is whether the contingent environmental liabilities assumed by Patten is a liability that would give rise to a deduction within the meaning of Internal Revenue Code (IRC) section 357 (c)(3) and whether Cho’s basis in the stock is determined by reference to Section358 (d)(1) or Section 358 (d)(2). The issue for Patten is how to determine the tax consequence based on the transaction. Applicable Laws The most pertinent Sections are directly cited form Code and listed as below: IRC Section 351(a): “No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c) of the corporation.” IRC Section 357(a): “Except as provided in subsections (b)...
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... | | |The introduction of your paper should acquaint the reader with the company being analyzed and demonstrate your ability to succinctly describe the company| | |from a historical perspective. Take this opportunity to highlight key factors and past strategies, which have led the company to its present position. | | |It is important for you to understand precisely why the company has been successful (or unsuccessful) in the past. Taking time to articulate this may | | |suggest distinctive competencies that you might otherwise overlook when writing the following sections. | | | | |Conclude the “Introduction” of your paper by...
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...with an ethical issue. Deliverable: 1. Introduction. It was something I witnessed, an ethical issue which I wish to point out. It is not really similar to that of the Lab’s video. It is about an investigation into a safety incident whereby a soldier, Solider A, fractured his hand during a botched attempt to lift an armored vehicle’s engine panel. 2. Background leading to incident. A background to the incident is necessary for a complete understanding of the ethical issue. Corporal A belonged to Platoon 1 Section 1, which was not assigned the task of lifting the engine panel. Platoon 2 Section 2 was assigned the task. Platoon 2 Section 2 Leader, Sergeant B, was not yet certified to operate the crane, hence they were in a fix as to how to proceed. However, Sergeant B is the senior ranking soldier and was supposed to be in charge of the operation. Corporal A came along and notice the situation, and decided to help. He and some of his buddies from Section 1 decided to operate the crane. The chains were not secured properly and gave way due to the weight, and crushed...
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...How To Read University Texts or Journal Articles Choose a section preferrably not longer than 25 or 30 pages - perhaps one chapter, or a section of a chapter - that you can handle at one sitting. Step 1. Read the title, the introduction, and the conclusion (5 minutes). Step 2. Read the title, the introduction again, all sub-headings, and the conclusion, again. (5-10 minutes). Step 3. Read the title, the introduction one more time, sub-headings, the Topic Sentence of each paragraph - usually the first or second sentence, (you may read the last sentence as well, if you have time), any italicized or boldfaced words, lists (you can skim these), and the conclusion (10 minutes). (Force yourself to do steps 1 to 3 in less than 25 minutes.) Step 4. Close your textbook. Step 5. Make a Mind-Map of all you can remember in the chapter. Do not stop until at least half an hour is up, even if you feel that you can't possibly remember any more--more will surface if you give yourself the time. DO NOT REFER TO THE TEXT WHILE YOU ARE DOING THIS. If you come to a dead end, try alternative memory techniques to the ones you have been using: associating ideas, either from within the section itself or from other related material; visualizing pages, pictures, graphs etc.; recalling personal associations that may have come to mind; staring out the window and blanking out your thoughts; and so on. This is strenuous, but it is rewarding. It will show you exactly how much you have learned...
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...IS4799: Unit 1 Common RFP Sections The common sections of an RFP are: Introduction: The Introduction section of an RFP states the purpose, scope, and necessary background information about the RFP. The introduction sets the stage for the RFP and summarizes its main points. Each RFP introduction is different and contains information that is specific to that RFP. Many RFPs contain general information that is common, including the following: • Statement of purpose: The statement of purpose summarizes the intent and purpose of the RFP and briefly conveys its reasons for its existence. While it does not contain many performance requirements, this section provides a very general overview of the RFP. The statement of purpose is deliberately high-level and provides few details. • Scope: Readers should gain a general sense of the performance requirements of the RFP from this section. The scope defines the specific products, services, period, terms, and conditions of the RFP. In many RFPs, the scope section simply refers readers to appropriate appendices for more detailed coverage. • Compliance stipulations : The introduction often contains any general compliance stipulations that apply to the RFP process, including vendor selection and performance of the proposal contents. W hile government-related RFPs usually contain statements of compliance with equal opportunity and disability regulations, any other mandatory compliance requirements will be included...
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.... The purpose of this memorandum shall be to provide a summary of TW04 LLAB activities and explain why the activity covers certain objectives. Attachment 1 shows the activities for LLAB TW04, and the objectives that coincide with the activities. 2. The first activity for TW04 LLAB shall be the POC LLAB brief, which lasts for 15 minutes. For this C/Foy explains what she wants to see from the POC at LLAB. C/Foy states her expectations on how to instill proper followership and leadership within the GMC corps at LLAB (28). 3. The second activity shall be warrior knowledge, lasting for five minutes. This consists of POC asking GMC their Warrior Knowledge for the week. Cadets are responsible for needing to know the Honor Code, which was assigned as Warrior Knowledge (3). GMC may be asked the Honor Code during this time, as well as having to explain what it means. GMC use Customs and Courtesies while addressing POC during Warrior Knowledge (23). 4. The third activity shall be opening formation, which lasts for five minutes. Opening formation consists of the two GMC flights falling into the Gym for the start of LLAB. Objectives 5, 6, 10, 11, 23, and 24 are included in this activity. The GMC must fall in with basic individual and flight drill movements (6), and to fall in they must know the individual and flight drill positions (5). The 200s in charge of the flight must apply effective flight commander skills to reach the fall in destination in a quick and efficient manner (11)...
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...order to master the game type. 1) Make 3 photocopies of every LG 2) Separate them using the classification method of choice - Blueprint, Kaplan, etc. will all work but I prefer PowerScore 3) Do each LGB section in order and work on the respective game types as you progress. For this I usually do 2-3 new games and 3 repeats every day, but it doesn't matter as long as you get it done. Try to keep some separation (24 hours+) between the first and second time you attempt a game. Repetition is crucial - after you have done a lot of games a lot of times anything they throw at you will seem elementary and routine. LR: Pretty simple really. Do the appropriate LRB section and then work through the corresponding chapter in Kaplan Mastery/Big Orange Book. I generally reviewed the LRB section thoroughly the first time, and then just read the summary of points and strategies at the start of the question set to refresh myself after that. Do up to 10 problems at each sitting and monitor which question types give you the most trouble. Review those questions heavily. If you're really motivated, cut out particularly troublesome questions for later review. I found that writing out explanations for question types I struggled with helped immensely. RC: This is the most difficult section to improve on. You have to develop a feel for what the passage as a whole is conveying while making sure not to miss small details...
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...The Stones Cry Out: Analytical Essay In Hikaru Okuizumi's book, "The Stones Cry Out", we follow a man named Manase through his life after the war. Although this seems like just a look on a mans life, there are many themes that tie us in. Hikaru uses many literary elements to develop those themes. Four of those elements are complication, false assumptions, flashbacks, and foreshadowing. Although there are many key themes, the two I noticed the most were the psychological effects of war and family complications due to the loss of a loved-one. Complications are defined as obstacles that increase tension. In the beginning of the book, the complications would be when Manase is faced with his memories of the time he was in the cave with the captain during the war, "He did not want to remember-Manase understood that very well. Even though he could taste his fear, he needed only to remind himself that he was lying on a soft mattress, not a cold bed of rocks."(28) The effects the war had on him were so immense that every night he would have nightmares of it. As this quote states, he didn't want to remember it. He would imagine those times in the war and the dreams seemed as real to him as the day they happened, that's why he needs to constantly remind himself that the war is over. When something is believed to be true; however is not true. An assumption isn't what's said, it is what is behind the words. This is the definition of false assumptions. Though Hikaru Okuizumi...
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...Committee Report Fall 2011 Board Meeting Alfredo Herrera, Committee Chair 1. The Humanitarian Initiatives Committee (HIC) in brief The HIC mission is to support humanitarian initiatives, new ventures and collaborations in which Canadian IEEE members are involved; for example: by identifying Canadian humanitarian initiatives already underway, by leveraging external (corporate, community, association) relationships for humanitarian solution partnerships, or by nurturing initiatives that our members raise like relief efforts in disasters like the December ’04 tsunami in southeastern Asia or the January ’10 earthquake in Haiti. One way it believes it can effectively accomplish this is by providing leadership, encouragement, and support to Sections and Chapters interested in humanitarian initiatives. 2. Current status and sleight for 2012 The Committee consist of IEEE Canada members and an expert panel of humanitarian advisors as follows: the HIC Chair; the Past-Chair of the HIC; the Past- President of IEEE Canada; a representative from each Area; the IEEE Canada President (ex-officio); and appointments to the HIC by the IEEE Canada Past-President, appointments include both IEEE volunteers and humanitarian advisors. => Webpage/blog: http://ewh.ieee.org/mu/r7-hic/ => Virtual Community: http://ieeecanadahic.oc.ieee.org/ |Role |2011 |2012 | |HIC Chair:...
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...SSG Stevenson, William David 07 January 2011 Area Recon PE 1 1. The platoon leader assigns the task of conducting area reconnaissance based off of the orders received, S3 information and guidance given using METT-TC. The Platoon leader knows the location of area recon (EG 17086770 to EG 16858710) and his instructions to determine insurgent supply route and drop point. The PL knows the mission must be completed NLT 011800OCT07. 2. In order to utilize the triangle technique to occupy the ORP the platoon leader will assign and ensure the squads know their positions. The lead squad will be the base of the triangle, facing in the direction of travel. The tip of the triangle will be the 6 o’clock position. The left corner of the triangle will cover the 10 o’clock position, while the right covers the 2 o’clock position. The HQ element will be within the triangle finalizing plans. In order to make up the triangle, the Trail squad covers from the 6 o’clock position up to the 10 o’clock position where the lead squad is. The middle squad covers from the 6 o’clock position up to the 2 o’clock position. 3. The most desirable method for executing and area reconnaissance is ling range observation and reconnaissance. This method adds to stealth and limits the detection by enemy. Also, this method keeps the soldiers out of range for small arms fire helping them withdrawal and break contact. 4. Once the mission is complete all squads and members of the reconnaissance operation assemble...
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...| — | Roll No.: Total Printed Pages :1 22M6201M. B. A. (Sem.II) (Main & Back) Examination, JunelJuly-201 1 M-201 Human Resource Management | | | | 11 l11 Time: 3 Hours] [Total Marks :70 [Mm. Passing Marks :28 The question paper is divided in two sections. There are sections A and B. Section A contains six questions out of which the candidate is required to attempt any four questions. Section B contains short case study/application base one question which is compulsory. All questions are carrying equal marks. Use of following supporting material is permitted during examination. (Mentioned in form No. 205) 1. Nil 2. Nil SECTION - A 1 Suppose HR planners estimate that because of several technological innovations your company needs 25 percent fewer employees in three years. What actions do you suggest for an effective functioning ? 2 (1) “Smaller organisations do not need job analysis for their jobs because most of their employees conduct a myriad of activities too far reaching for a standard job analysis”. Elucidate (2) The input throught put and output of HRD is human resources. Elucidate. 3 How would you identify the training and development needs of managerial personnel in a large industrial undertaking? Also suggest a method for evaluating the effectiveness of in company training programmes in an organisation. 4 (1) Describe the components of...
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...SUBJECT: Library Database Environment DATE: Tuesday, March 1, 2016 Analysis of the Database environment This environment in which this database is based on is a library.it seeks to look into a library setting and all attributes associated with a library. Basically a library contains documentation for reference, research and learning purposes with a variety of fields to look into. Some may also have archived materials that are still being used. Current libraries have a section where you can access materials like newspapers to catch up with news updates. This database will use a MYSQL environment to manage the data related to the library and Delphi in designing the interface Problems and constraints The existing library has a category of sections from which reference materials for research and learning can be obtained. Unfortunately no systematic sorting has been done to categorize books in each section. This makes it some worth difficult and time consuming to find a specific book of interest within the sections Objectives of the database environment The objectives of the database environment are enlisted below * Provide an all-in-one system for accessing reference materials * Develop a system that will store user details and item details * Create an easy to understand and friendly environment * Develop a system that can replace the manual library management system * Provide borrow and return records * Provide user access levels(i.e. Only Admin updates...
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...complementary merchandises. Mannequins: The mannequins are used to display the merchandise in both individually by using half mannequins and mixed using complementary merchandise with both ‘monochromatic’, ‘complementary’ colours. Fixtures The fixture density is high; the type of fixtures is comparatively high for the store. They are using both floor and wall fixtures in their store. Floor Fixtures The store have used different floor fixtures such as 4-Way: They were using 4-way fixtures mostly in the store. The 4 way fixture is mostly concentrated in the women’s section in the first level. Gondolas: They have used most of their gondolas in kitchen and home decorative sections. The rest were used in the apparel, footwear sections. Nesting Tables: They are using 2- table paired nesting tables. The nesting table are very less compared to other floor fixtures; they are seen in both the men’s and kids section. Bins: Bins were not used as fixtures in the store....
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...about the organization is that is doesn’t have a picture of the product on the cover page. Although we know what a Blu-ray/DVD system looks like and it should automatically have the correct manual in its box, there may be an instance where that has not happened or if you misplaced your original manual and need another. The photo would come in handy especially if there is a certain layout that this particular has as opposed to other models. Having the photo is further reinforcement that you have the correct product. II. Layout The layout of this manual is standard. The warning sections and intial operating instructions are seen in most user manuals. Something that used to be uncommon which we are seeing more often in user manuals is the unpacking section. This section further details the parts of the entertainment system piece by piece. The remainder of the layout includes more standard sections such as how to operate each source, sound adjustments, settings, and of course a manual is not complete without the index. III. Instructions : Visuals Visuals in this user manual are detailed enough so that a first time buyer and an experienced electronics buyer can get the same experience using this manual. Not only does this manual give you instructions of how to set up...
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...A Walk Over The Fence. By Colin Moore. “Read this and sign it’ The section commander mumbled to me. I had noticed him moving from man to man offering the unofficial looking document for inspection. I knew what it was, as did every one else. I took the sheet of paper from him and moved my eyes down the list of names until I found mine, next to it I scribbled my signature and read what was written, then handed it back. ‘ O group 1400 hrs’. Said the section commander and then he moved off and out of the tent. The paper was a warning order informing the platoon that we were to cross the fence and move by foot to set an ambush at a yet to be disclosed position, full details would be given at the 1400 O group. I had only been with this platoon a week and I still didn’t know any one, pretty much the outsider. In all I’d been in this army for four and a half months, four months basic training then posted to this combat unit I had served once before in another army in another place and another time but had never been in combat. What lay ahead of me was now untried ground and I was scared. Scared of dying or being wounded but most of all scared of letting down the platoon, these men who didn’t know me, and who I didn’t know. The O group was brief; everyone already knew what they were doing and what was their role in the mission, so every one was preparing gear and collecting ammunition and expendables. By this time I was shit scared; all this was becoming way too real. For...
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