Memorandum-to-the-file
Date: December 5, 2015
From: Nyatiah Nickens NN
Re: DLK Corporation: Tax Implications Facts: Five years ago, Lacey, Kaylee, and Doug organized a software corporation, DLK, which develops and sells Online Meetings software for businesses. DLK is a C corporation and each individual contributed $10,000 to the company in exchange for 1,000 shares of DLK stock (for a total of 3,000 shares). The corporation also borrowed $250,000 from ACME Venture Capital to finance operating costs and capital expenditures. It was suggested by Lacey that Kaylee and Doug (original investors) contribute an additional $25,000 to DLK in exchange for five 20-year debentures. The debentures will be unsecured and subordinate to ACME’s debt. Annual
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Hardman v. U.S., Cite as 60 AFTR 2d 87-5651 (827 F.2d 1409), Code Sec(s) 163, (CA9), 09/18/1987. Rudolph A. Hardman, Frances N. Hardman and Hardman, Inc., Plaintiffs-Appellants v. U.S., Defendant-Appellee. Hardman, Inc. bought twenty acres of land abutting Hale Field. In 1977, the corporation resold the property, including the extra twenty acres of land, for $600,000. It paid Mrs. Hardman $109,568 (one third of the net profit attributable to the 100 acres of land of Hale Field). Hardman Inc. characterized the $109,568 as part consideration for the purchase of property from Mrs. Hardman. The Hardman’s treated the payment as a “capital gain” and then Hardman, Inc. added the payment to its basis in the property. The IRS felt that the payment from Hardman Inc. to Mrs. Hardman was considered a “payment” as a dividend to Frances Hardman. The IRS felt that the payment was taxable as “ordinary income” to Mrs. Hardman and improperly added to the corporation's basis on resale. As a result, Rudolph and Frances Hardman and Hardman, Inc. appealed the district court decisions upholding tax deficiencies assessed by the Internal Revenue …show more content…
1419] treated for tax purposes as a valid "indebtedness." Were intent the sole consideration, we would have to agree that the parties here intended, both subjectively and objectively, to create an indebtedness. But the question is not so simple. Despite what many decisions state or imply, the issue is not so much what the parties intended, but whether for tax purposes the transaction will be so
Mr. Shields’ should accept Mr. Fordham’s proposal in relation to the acquisition of Upstate Canning Company, Inc. In this case, Mr. Shields attempts to conclude if he should acquire the company from its owner, Mr. Fordham, using his personal savings of $35,000 in addition to an investment of $65,000 from his associates. Moreover, Mr. Fordham proposes that he will loan Mr. Shields’ $300,000 worth of income bonds, to be repaid in up to 10 years. Mr. Fordham provides Mr. Shields’ with a bond repayment schedule which allows Mr. Shields’ to repay the bonds at a discount if he meets the wishes to repay the bonds back early. Mr. Shields’ faces a
The appellants view the “substance” of the transaction is over the “form”. Generally, taxpayers are bound by the form of their transaction and may not argue the substance triggers different tax consequences. The Tax Court found the form and substance of the transaction was a loan from the bank to VAFLA and not to the appellants. The proceeds were to be used in the operation of the business and petitioners were not free to dispose the loan. Nor were the payments reported as constructive dividends.
In 2013 Marianne sold land, building and equipment with a combined basis of $150,000 to an unrelated third party and in return received an installment note of $80,000 per year for five years. Of the $250,000 gain on sale, $150,000 was classified as Section 1245 gain and the remaining $100,000 was Section 1231 gain. In 2013, Marianne had a capital loss carryover of $60,000, $50,000 of which she used to offset her Section 1231 gain; she recognized no Section 1245 gain. The following year she recognized $40,000 of 1245 gain and $10,000 of Section 1231 gain which she promptly offset with the last $10,000 of the capital loss carryover. In 2015, she recognized $50,000 Section 1245 gain and no Section 1231 gain.
- K.D. was unconscious for about three minutes during sexual activities with J.A, (She was aware this might happen when she asked to be choked)
The second case in the use of K9 deployment for the use of force on a suspect is the case of Burrows v. City of Tulsa. The situation of this case was whether the K9 named Schafer had bit the suspect after he was placed in handcuffed. The plaintiff claims his Fourth Amendment rights were violated which brings the court to review it as either a Fourth or a Fourteenth Amendment issue? In trail an expert witness states that a K9 handler must be in control of a K9 at all times because a K9 are not capable of identifying defensive or an aggressive act. The suspect in the situation must stay perfectly still to avoid aggravating the K9, as a result the K9 will perceives the actions as a threat causing the K9 to continue to bit and hold the suspect.
In conclusion, I believe Mr. Grimko needs to have a heart to heart talk with is staff. An educational leadership retreat would be the perfect opportunity to strengthen and build trusting relationships. Mr. Grimko
Mark R. Miske, Senior Vice President, CFO and Treasurer referenced his slides on pages 39-53 stating that he had good financial news to report. Mr. Miske stated growth and policy count is beginning to drive the premium growth as both Direct Written Premium and Earned were up over last year.
I feel that Dr. P has a case in this situation. I feel he has the ability to sue for compensatory damages. I would argue that Dr. P is a public figure. As you said he is the foremost academic on exposure to violence and the human psyche. Since he is a public figure and his work is important to public interest. Because of this we have to prove malice. In this case we also have to determine how defamation of DR. P is present. We have to answer how his reputation is being harmed, how his standing in the community is being harmed.
discussion of risk information about the product: FDA suggest that the firm should provide a direct hyperlink to a website, PDF, or similar electronic resource that is devoted exclusively to the communication of risk information and does not contain any promotional material. The draft guidance states that the FDA will not object to the use of URL-shortening services, however URL should not be promotional in content or tone.
Yahoo Mail users were greeted with a notice: "Please disable Ad Blocker to continue using Yahoo Mail." These users were incapable of accessing their accounts until they turned removed their ad blocker or found a workaround for the dilemma. This message is not a new policy, but was part of a trial, a Yahoo spokesman told Engadget over the weekend. A "small number" of Yahoo Mail users were prevented from accessing their email accounts because Yahoo detected they had an ad blocker installed on their computer. The message was most likely a result from an A/B test, a technique technology companies push changes to a small number of users to measure user reaction before deploying them
The above projected sales forecast reflects a slow start as initial on-boarding of clientele is expected to be low in the first quarter. Initial sales target dictate focusing on securing yearly contracts as opposed to monthly. Additionally, sales generated from customized solutions and monthly packages are not factored in this sales forecast. The 2nd Quarter should provide for better sales figures as a result of the company’s networking and marketing campaign.
Daktronics Corporation was founded in 1968. The company is a designer and manufacturer of electronic scoreboards and large displays for sports venues. Just few years ago, the company was the undisputed market leader with nearly 70 percent market share for the collage and professional sports venue for large displays. The company also produced integrated sound systems and hoist and rigging systems for a variety of entertainment and sports facilities. Recently, however, the company has seen a decrease in its market share and profitability due to changing market and increased competition.
1. Which option, or other options, or combinations thereof, for securing IVK in the aftermath of the attack would you choose? Why?
To understand better how the complexity of the Internal Revenue Code affects both parties I focus my research paper in the formation of Garrison Litigation Management Group created by Coltec Industries, Inc. a publicly-traded holding company. Garrison was created to separate potential asbestos liabilities following a complex series of prearranged steps to reduce potential tax cost qualifying under section 351.
Income: A company's amount of income is more important when considering debt than equity ; equity's common stock dividends only have to be paid out when the extra corporate funds are available, while interest on debt needs to be paid each month. Based on after-tax profit projections on exhibit 6, Rosario Acero S.A. should not have a problem making an annual interest payment of $980,000 per year under the 8-year debt financing option. However, it is important to note that the provisions stated in the proposed private placement agreement (i.e. debt financing), indicate that Rosario will have to pay $1,875,000 in the seventh year of the placement, and $5,625,000 in the eighth year. The sum of these two fixed payments is equal to the entire $7,500,000 face value of the private placement. Based on this payment plan, it is imperative that Rosario generates enough income in years