Search results for: time-and-cause

Reports of United States Tax Court V 141 July 1 2013 to December 31 2013

Author : Government Publications Office
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Volume of the United States Tax Court Reports containing case abstracts and opinions of the court regarding cases between July 1, 2013 December 31, 2013. Cases in each volume are listed in the prefatory table. The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to "constitute Tribunals inferior to the Supreme Court. “The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule”).” Contents 8 Findings of Fact 8 Background 8 John Hancock’s History9 Investment Process and Review10 Leasing10 LILO and SILO Transactions 10 Basic Structure 15 History 17 Due Diligence 18 The Hoosier Transaction 19 The LILO Test Transactions 20 OBB LILO20 Lease and Sublease23 End of Sublease Term25 SNCB 2 and SNCB 5 Lot 1 LILO Transactions25 Lease and Sublease28 End of Sublease Term 28 The SILO Test Transactions 29 TIWAG29 Lease and Sublease33 End of Sublease Term35 Two Dortmund Transactions35 Lease and Sublease38 End of Sublease39 SNCB SILO39 Grant and Subgrant42 End of Subgrant Term 43 Tax Returns, Notices of Deficiency, and Trial 43 Procedural History48 Trial 53 Opinion 53 Burden of Proof53 Principal Place of Business54 Leveraged Lease Transactions54 Frank Lyon58 LILO and SILO Litigation 77 The Test Transactions 78 Economic Substance79 Objective Inquiry88 Subjective Inquiry89 Substance Over Form91 OBB and SNCB LILO Transactions110 SILO Test Transactions 145 Interest Deductions 147 Original Issue Discount 149 Transaction Expenses 149 Conclusion NOTE: NO FURTHER DISCOUNTS FOR ALREADY REDUCED SALE ITEMS. Keywords: tax court reports, reports of the united states tax court, u.s. tax court reports, united states tax court reports, united states tax court, u.s. tax court, tax court

The Works of Samuel Clarke

Author : Benjamin Hoadly
File Size : 90.20 MB
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Feeling Tired All the Time A Comprehensive Guide to the Common Causes of Fatigue and How to Treat Them

Author : Joe Fitzgibbon
File Size : 64.43 MB
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Do you ever feel utterly exhausted? Perhaps you feel like falling asleep on your feet right now? If so, you are not alone! One in four people complains of feeling tired all the time, and finds it hard to maintain a normal lifestyle as a result. ‘Doctor, I feel tired all the time’ is the single most common complaint presented by patients to their doctors. In studies in the UK and the USA, up to twenty per cent of men, and thirty per cent of women identified themselves as having the complaint. Unfortunately, because fatigue is such a common problem and is sometimes caused by psychological factors, the complaint may not be taken seriously and the patient seeking help may be too easily dismissed. Feeling Tired All the Time has been written for the layperson. In it, Dr Fitzgibbon explains the common and treatable causes of fatigue. Using the most up-to-date research and information available, he aims primarily to help people identify the cause of their tiredness, and specifically to help them distinguish between ‘ME’ (Chronic Fatigue Syndrome) and other possible causes. Dr Fitzgibbon strongly refutes the notion that nothing can be done to help the fatigued. Each section in the book provides checklists which help the reader to recognise the conditions that might apply to them, together with a sensible and practical approach to treatment. The text is generously complemented by real-life case histories taken from the author’s personal experience. A directory of support organisations is also included. Feeling Tired All the Time: Table of Contents Introduction SECTION 1. Putting Fatigue in Context The Complex Problem of Fatigue Normal Energy Levels SECTION 2. The Most Common Causes of Fatigue I. Psychological and Psychiatric Explanations of Fatigue Social Attitudes to Psychological Distress Stress Depression Anxiety Panic and Phobia Hysteria and Hypochondriasis II. Physical Explanations of Fatigue Fatigue as a Symptom of Physical Disease SECTION 3. Forgotten Causes of Fatigue I. Fatigue and Sleep Normal Sleep Pattern and Sleep Requirements Chronic Sleep Deprivation Sleep Disorders II. Fatigue and Diet Diet, Mood and Energy Overweight and Obesity Nutritional Deficiency Food Allergy and Intolerance Caffeine Hypoglycaemia – Low Blood Sugar III. Fatigue and germs The Truth about Candida Parasites, Bacteria and Viruses IV. Fatigue and Chemicals Multiple Chemical Sensitivity Syndrome SECTION 4. Chronic Debilitating Fatigue Fibromyalgia Chronic Fatigue Syndrome (ME) From Controversy to Consensus in CFS Assessing the Impact of Chronic Fatigue The Treatment of Chronic Fatigue Appendix 1. An Effective Treatment for Allergy Appendix 2. Useful Addresses

Problem Solving and Decision Making Illustrated Course Guides

Author : Jeff Butterfield
File Size : 51.70 MB
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The Illustrated Series Soft Skills titles are designed to make it easy to teach students the essential soft skills necessary to succeed in today's competitive workplace. Each book and companion CourseMate cover 40 critical skills, providing students with extensive knowledge they can bring with them into the real world. CourseMate brings each text to life with an audio visual eBook, scenario videos, access to Career Transitions, interactive activities for reinforcement, and Engagement Tracker, a first-of-its-kind tool that monitors student engagement in the course! Important Notice: Media content referenced within the product description or the product text may not be available in the ebook version.

Terms of Court Chambers and Rules of Practice for the Supreme Court and the District Courts of the State of North Dakota

Author : North Dakota. Supreme Court
File Size : 30.79 MB
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House Bills

Author : Illinois. General Assembly. House of Representatives
File Size : 21.20 MB
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Code of Federal Regulations

Author :
File Size : 63.7 MB
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The Bankers Encyclopedia

Author :
File Size : 22.33 MB
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Synchronization of Fault tolerant Distributed Real time Multicomputers

Author : Alan David Olson
File Size : 62.58 MB
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Vital Statistics of the United States

Author :
File Size : 36.77 MB
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