alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
I 

118TH CONGRESS 

1ST SESSION H. R. 1034 

To amend the Internal Revenue Code of 1986 to modify the residence and 

source rules to provide for economic recovery in the possessions of the 

United States. 

IN THE HOUSE OF REPRESENTATIVES 

FEBRUARY 14, 2023 

Ms. PLASKETT introduced the following bill; which was referred to the 

Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to modify 

the residence and source rules to provide for economic 

recovery in the possessions of the United States. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Territorial Tax Equity 

5 and Economic Growth Act of 2023’’. 

6 SEC. 2. MODIFICATION TO RESIDENCE AND SOURCE RULES 

7 INVOLVING POSSESSIONS. 

8 (a) BONA FIDE RESIDENT.—Section 937(a) of the 

9 Internal Revenue Code of 1986 is amended— 


kjohnson on DSK79L0C42PROD with BILLS
2 

•HR 1034 IH

1 (1) by striking the last sentence, and 

2 (2) by amending paragraph (1) to read as fol3 lows: 

4 ‘‘(1) who has a substantial presence (deter5 mined under the principles of section 7701(b)(3)(A) 

6 (applied by substituting ‘122 days’ for ‘31 days’ in 

7 clause (i) thereof) without regard to sections 

8 7701(b)(3)(B), (C), and (D)) during the taxable 

9 year in Guam, American Samoa, the Northern Mar10 iana Islands, Puerto Rico, or the Virgin Islands, as 

11 the case may be, and’’. 

12 (b) SOURCE RULES.—Section 937(b) of such Code 

13 is amended— 

14 (1) in paragraph (1), by striking ‘‘and’’ at the 

15 end, 

16 (2) in paragraph (2), by striking the period at 

17 the end and inserting ‘‘, but only to the extent such 

18 income is attributable to an office or fixed place of 

19 business within the United States (determined under 

20 the rules of section 864(c)(5)),’’, and 

21 (3) by adding at the end the following new 

22 paragraphs: 

23 ‘‘(3) for purposes of paragraph (1), the prin24 ciples of section 864(c)(2), rather than rules similar 

25 to the rules in section 864(c)(4), shall apply for purVerDate Sep 11 2014 07:22 Mar 07, 2023 Jkt 039200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6201 E:\BILLS\H1034.IH H1034

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3 

•HR 1034 IH

1 poses of determining whether income from sources 

2 without a possession specified in subsection (a)(1) is 

3 effectively connected with the conduct of a trade or 

4 business within such possession, and 

5 ‘‘(4) for purposes of paragraph (2), income 

6 from activities within the United States which are of 

7 a preparatory or auxiliary character shall not be 

8 treated as income from sources within the United 

9 States or as effectively connected with the conduct 

10 of a trade or business within the United States.’’. 

11 (c) SOURCE RULES FOR PERSONAL PROPERTY

12 SALES.—Section 865(j)(3) of such Code is amended by 

13 inserting ‘‘, 932,’’ after ‘‘931’’. 

14 (d) EFFECTIVE DATE.—The amendments made by 

15 this section shall apply to taxable years beginning after 

16 December 31, 2022. 

Æ 


kjohnson on DSK79L0C42PROD with BILLS
#### 719.273 The U.S. Agency for International Development (USAID) Mentor-Protégé Program.
Motion Granted; Order filed August 20, 2013.

In The 

## Fourteenth Court of Appeals

____________ NO. 14

- 13

- 00101

- CR

____________ JORGE GUERRERO , Appellant

V.

THE STATE OF TEXAS , Appellee

On Appeal from the 338th District Court

Harris County, Texas Trial Court Cause No. 1354948



### ORDER
Appellant filed a motion to supplement the reporter’s record in this case with the reporter’s record from the waiver of jurisdiction hearing that occurred cause
number 201

- 00331J in the 314th Juvenile District Court on July 18, 2012 and all other hearings that occurred in that juvenile court cause. The motion is granted.We order Julia Rangel , the official court reporter for the 314th District

Court , to file the above

- referenced record in this appeal within 30 days of the date
of this order

. PER CURIA M
Electronically Filed 

Supreme Court 

SCPW-11-0000366 

13-JUN-2011 

02:16 PM 

NO. SCPW-11-0000366
 

IN THE SUPREME COURT OF THE STATE OF HAWAI'I 

DJC, Petitioner,
 

vs.
 

THE HONORABLE SHERRI ANN L. IHA, JUDGE OF THE FAMILY


COURT OF THE FIRST CIRCUIT, STATE OF HAWAI'I;


and JSC, Respondents.
 

ORIGINAL PROCEEDING
 

(FC-D No. 10-1-6277)
 

ORDER
 

(By: Recktenwald, C.J., Nakayama, Acoba, and Duffy, JJ.


and Circuit Judge Sakamoto, in place of McKenna, J. recused)
 

Upon consideration of respondent JSC's motion for 

reconsideration and the papers in support, 

IT IS HEREBY ORDERED that the motion for 

reconsideration is denied. 

DATED: Honolulu, Hawai'i, June 13, 2011. 

/s/ Mark E. Recktenwald 

/s/ Paula A. Nakayama 

/s/ Simeon R. Acoba, Jr. 

/s/ James E. Duffy, Jr. 


/s/ Karl K. Sakamoto
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## Breadcrumb

            -           FEMA Preparedness Tips for School Administrators      

# FEMA Preparedness Tips for School Administrators

The Preparedness Tips for School Administrators fact sheet is comprised of tips and suggestions on preparedness, as well as links to tools and resources specifically for school administrators.  Resources are pulled from FEMA, the Department of Education, CDC, and practitioners in the field. This document can help school administrators answer the questions parents might have regarding emergency management planning and practices. The resource also provides tips for administrators to explain school and parent roles and responsibilities in preparing for and responding to emergencies.

http://www.fema.gov/media-library/assets/documents/30509
#### 31.201-7 Construction and architect-engineer contracts.

Specific principles and procedures for evaluating and determining costs in connection with contracts and subcontracts for construction, and architect-engineer contracts related to construction projects, are in 31.105. The applicability of these principles and procedures is set forth in 31.000 and 31.100.
Exhibit 32.1
  
 STATEMENT OF CHIEF EXECUTIVE OFFICER UNDER 18 U.S.C. ss 1350
 
  I, Peter C. Chang, the chief executive officer of Alliance Fiber Optic Products, Inc. (the "Company"), certify for the purposes of section 1350 of chapter 63 of title 18 of the United States Code that, to the best of my knowledge,
  (i)           the Annual Report of the Company on Form 10-K for the period ended December 31, 2010 (the "Report"),  fully complies with the requirements of section 13(a) or section 15 (d) of the Securities Exchange Act of 1934, and
  (ii)           the information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company.
  
  /s/ Peter C. Chang
 Peter C. Chang
 
 March 18, 2011
<PAGE>



EXHIBIT 32.1

                CERTIFICATION PURSUANT TO 18 U.S.C. SECTION 1350,
                             AS ADOPTED PURSUANT TO
                  SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

In connection with the Quarterly Report on Form 10-Q of Chicago Rivet & Machine
Co. (the "Company") for the quarterly period ended June 30, 2005 as filed with
the Securities and Exchange Commission on the date hereof (the "Report"), I,
John A. Morrissey, as Chief Executive Officer of the Company, hereby certify,
pursuant to 18 U.S.C. ss. 1350, as adopted pursuant to ss. 906 of the
Sarbanes-Oxley Act of 2002, that, to the best of my knowledge:

         (1) The Report fully complies with the requirements of Section 13(a) or
15(d) of the Securities Exchange Act of 1934; and

         (2) The information contained in the Report fairly presents, in all
material respects, the financial condition and results of operations of the
Company.


/s/ John A. Morrissey
------------------------------
Name:  John A. Morrissey
Title: Chief Executive Officer
Date:  August 12, 2005


                                       18
#### In the Matter of the Arbitration between De Reve & Company et al., Appellants, and Intsel Corporation, Respondent.

— Order, Supreme Court, New York County, entered August 4, 1978, temporarily staying arbitration pending a hearing to determine whether a valid agreement to arbitrate was entered into by the parties, unanimously reversed, on the law, and the motion for a permanent stay of arbitration is granted, with $50 costs and disbursements of this appeal payable to appellants by respondent. The petitioner De Reve & Company and the respondent Intsel Corporation are in the business of buying and selling metals. Intsel’s claim is that on May 2, 1978 a metal trader from Intsel, Ralph Klein, received a call from Morris Goldstein, a partner at De Reve, in which Goldstein offered to sell 17,000 pounds of cobalt at $8 a pound. Klein accepted the offer by telephone later that day. An Intsel purchase-order form was mailed that day to De Reve. The form contained an arbitration clause. Klein signed the form on behalf of Intsel. De Reve received the form in the mail on May 11 but, rather than signing and returning it, De Reve sent a letter denying the confirmation and denying any contract entered into between the parties. Intsel commenced an arbitration proceeding against De Reve, and De Reve in turn moved at Special Term to stay arbitration. Special Term temporarily stayed arbitration pending a hearing to determine whether the parties had entered into a valid agreement to arbitrate. We would reverse and grant a permanent stay of arbitration. There is a dispute between the parties as to whether an oral agreement was reached on May 2; however, the issue before Special Term was whether the parties agreed to arbitrate, and not whether there was merit to the underlying dispute *(Matter of Prinze [Jonas],*38 NY2d 570, 574). The rejection by De Reve of the written "confirmation” from Intsel immediately upon its receipt precludes a finding that the parties agreed to arbitrate, since, even assuming an initial oral agreement existed, the inclusion of an arbitration clause in the written confirmation amounts to a material alteration of a contract for the sale of goods *(Matter of Marlene Inds. Corp. [Carnac Textiles],*45 NY2d 327, 334), which was not accepted by De Reve. In this posture, we need not reach the question of the effect of subdivision (2) of section 2-201 of the Uniform *624Commercial Code upon the rights of the parties. Concur — Kupferman, J. P., Birns, Lane and Markewich, JJ.
#### Stanley Stylinski, appellee, v. Alexander Towy et al., on appeal of Alexander Towy, appellant.

Gen. No. 30,539.

Action for personal injuries. Judgment for plaintiff. Appeal from the Superior Court of Cook county; the Hon. John J. Sullivan, Judge, presiding. Heard in the second division of this court for the first district at the October term, 1925.

Affirmed.

Opinion filed May 25, 1926.

Henry Knaus, for appellant; Anderson *So*Roaehe and John H. Lyk, of counsel.

Frank Greskowialc and Ewart Harris, for appellee.

Mr. Presiding Justice Barnes

delivered the opinion of the court.
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## Breadcrumb

            -           Money As You Grow: Facilitator's Guide      

# Money As You Grow: Facilitator's Guide

Booklet for facilitators who are implementing Money as You Grow Book Club.

https://pueblo.gpo.gov/CFPBPubs/CFPBPubs.php?PubID=13246
#### UNITED STATES of America, Plaintiff-Appellee v. Oscar Mario VALVERDE-DELGADO, Defendant-Appellant.

No. 07-50697

Conference Calendar.

United States Court of Appeals, Fifth Circuit.

Nov. 8, 2007.

Joseph H. Gay, Jr, Assistant U.S. Attorney, U.S. Attorney’S Office, Western District of Texas, San Antonio, TX, for Plaintiff-Appellee.

Federal Public Defender’s Office, Western District of Texas, San Antonio, TX, for Defendant-Appellant.

Before KING, BARKSDALE, and DENNIS, Circuit Judges.

PER CURIAM: *

Appealing the Judgment in a Criminal Case, Oscar Mario Valverde-Delgado raises arguments that are foreclosed by *Almendarez-Torres v. United States,*523 U.S. 224, 235, 118 S.Ct. 1219, 140 L.Ed.2d 350 (1998), which held that 8 U.S.C. § 1326(b)(2) is a penalty provision and not a separate criminal offense. *See United States v. Pineda-Arrellano,*492 F.3d 624, 625 (5th Cir.2007), *petition for*cert. *filed*
      *436(Aug. 28, 2007) (No. 07-6202). The Government’s motion for summary affirmance is GRANTED, and the judgment of the district court is AFFIRMED.

Pursuant to 5th Cir. R. 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Cir R. 47.5.4.
#### ISBELL-PORTER CO. v. HEINEMAN.

(Supreme Court, Appellate Division, First Department.

March 16, 1906.)

Action by the Isbell-Porter Company against Isaac Heine-man.

No opinion. Motion denied, on payment of $10 costs. Order filed.
p130181.eng INITIAL REVIEW ENGINEERING REPORT PMN: 13-0181 Focus Ready Draft 1/14/2013 ENGINEER: Choudhary \ AH PV (kg/yr):

Page 1p130181.eng

SAT (concerns) (11/06/2012): Related Cases and Related Cases and Misc SAT Info: Migration to groundwater: Negligible PBT rating: P2B3T1 Linear: P1B2T1 // Branched: P2B3T1. Health: 2 Dermal, Inhalation Eco: 3 Water (All releases to water with a CC = 2 ppb.), XB Testing (Testing desired)
OCCUPATIONAL EXPOSURE RATING: 1D
NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

Page 2p130181.eng

Page 3p130181.eng

INITIAL REVIEW ENGINEERING REPORT PMN: 13-0181

Page 4p130181.eng

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Page 5p130181.eng

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Page 8p130181.eng

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## Breadcrumb

            -  Announcements 
            -           Resource: Most Kids with Parent in Same-Sex Relationship Live with Female Couple      

# Resource: Most Kids with Parent in Same-Sex Relationship Live with Female Couple

These Census Bureau data compare the characteristics of children of same- and opposite-sex couples. Geographic information, race and ethnicity of children, marital status of parents, and other demographic characteristics are explored. **Learn more.**
#### 801.404 Class deviations.

The SPE may authorize class deviations from the FAR and VAAR when a class deviation is in the best interest of the Government.
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## Breadcrumb

            -  Announcements 
            -           Resource: Pediatric Medical Traumatic Stress Toolkit for Health Care Providers      

# Resource: Pediatric Medical Traumatic Stress Toolkit for Health Care Providers

This toolkit, developed by the National Child Traumatic Stress Network, guides medical professionals in effectively assessing and treating medical traumatic stress in children and families. It includes guidebooks on implementing trauma-informed care, case studies and examples, and patient handouts for children and parents with evidence-based tips and activities in English and Spanish. **Learn more.**
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## Breadcrumb

            -  Evidence and Innovation 
            -  Teen Pregnancy Prevention Evidence Review 
            -           PPRER0S22069      

# PPRER0S22069

Wolfe DA, Crooks C, Jaffe P, Chiodo D, Hughes R, Ellis W, et al. A school-based program to prevent adolescent dating violence: A cluster randomized trial. Arch Pediatr Adolesc Med. 2009;163:692–9. pmid:19652099

N/ADid not meet the review's screening criteria