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

PROTECTION AGENCY

1001 I STREET, SACRAMENTO, CALIFORNIA 95814 • P.O. Box 2815, SACRAMENTO, CALIFORNIA 95812-2815

LINDA S.ADAMS (916) 323-2514' (916) 324-0908 FAX • WWW.CALEPA.CA.GOY

SECRETARY FOR

ENVIRONMENfAL PROTECTION

ARNOLD SCHWARZENEGGER

GOVERNOR

Mr. Jared Blumenfeld

Regional Administrator

United States Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, California 94105-3901

Thank you for your letter of October 19, 2010 to Governor Schwarzenegger seeking the

position of the State of California (State) on the proposed listing of the Blue Ledge Mine

on the Superfund National Priorities List (NPL). The State agrees that the environmental

threats identified in your letter must be addressed; however we are concerned with the

long-term funding obligations that typically fall to the State at sites like the Blue Ledge

Mine.

Accordingly, concurrence with this listing or with any future Record of Decision and

subsequent agreement to State Superfund ContraCts must be based in part on selection

of optimal remedial actions that limit or eliminate long-term operation and maintenance

(O&M) costs. Where appropriate, the State will be looking to the United States EPA for

substantial application of removal action funding and support for identification and

selection of protective remedies which will reduce State cost share requirements. The

State will also be seeking a cooperative partnership with U.S. EPA to aggressively pursue

cost recovery against viable responsible parties and to creatively identify alternative

funding sources.

Finally, the State will be looking to the U.S. EPA to help develop long-term sustainability

and optimization of funding sources for cleanup of both NPL fund lead and State Orphan

sites. Meeting this objective will require clo~e coordination with U.S. EPA in developing

funding strategies for existing fund lead sites, as well as consideration of potential longterm burden on the State in selection of future NPL sites. Long-term O&M at fund lead

sites may require management in a fashion that optimizes utilization of available funding

which could include reduction or elimination of certain O&M activities based on

established budget priorities.

AIR RESOURCES BOARD' DEPARTMENT OF PESTICIDE REGULATION' DEPARTMENT OF TOXIC SUBSTANCES CONTROL

OFFICE OF ENVIRONMENTAL HEALTH HAZARD AsSESSMENT

STATE WATER RESOURCES CONTROL BOARD • REGIONAL WATER QUALITY CONTROL BOARDS
,

Mr. Jared Blumenfeld

Page 2

To the extent that the above conditions are acceptable to U.S. EPA, the State supports

listing of Blue Ledge Mine on the NPL. '

-if._ :JtUr0, /Id(U7l4.

~~tams '

Secretary for Environmental Protection

cc: Mr. Thomas Howard

Executive Director

State Water Resources Control Board

Post Office Box 100

Sacramento, California 95812-0100

Ms. Pamela Creedon

Executive Officer

Regional Water Quality Control Board

Central Valley Region

11020 Sun Center Drive, Suite 200

Rancho Cordova, California 95670

Mr. Maziar Movassaghi

Acting Director

Department of Toxic Substances Control

Post Office Box 806

Sacramento, California 95812-0806
§ 1.84-1 Transfer of appreciated property to political organizations. ( a ) *Transfer defined.* A transfer after May 7, 1974, of property to a political organization (as defined in section 527(e)(1), and including a newsletter fund to the extent provided under section 527(g)) is treated as a sale of the property to the political organization if the fair market value of the property exceeds its adjusted basis. The transferor is treated as having realized an amount equal to the fair market value of the property on the date of the transfer. For purposes of this section, a transfer is any assignment, conveyance, or delivery of property other than a bona fide sale for an adequate and full consideration in money or money's worth, whether the transfer is in trust or otherwise, whether the transfer is direct or indirect and whether the property is real or personal, tangible or intangible. Thus, for example, a sale at less than fair market value (other than an ordinary trade discount), or a receipt of property by a political organization under an agency agreement entitling the organization to sell the property and retain all or a portion of the proceeds of the sale, is a transfer within the meaning, of this section. The term “transfer” also includes an illegal contribution of property.
( b ) *Amount realized.* A transferor to whom this section applies realizes an amount equal to the fair market value of the property on the date of the transfer. For purposes of this section, the definition of fair market value set forth in § 1.170A-1(c) (2) and (3) is incorporated by reference.
( c ) *Amount recognized.* A transferor to whom this section applies is treated as having sold the property to the political organization on the date of the transfer. Therefore, the rules of chapter 1 of subtitle A (relating to income tax) apply to the gain realized under this section as if this gain were an amount realized upon the sale of the property. These rules include those of section 55 and section 56 (relating to minimum tax for tax preference), section 306 (relating to disposition of certain stock), section 1201 (relating to the alternative tax on certain capital gains), section 1245 (relating to gain from dispositions of certain depreciable property), and section 1250 (relating to gain from dispositions of certain depreciable realty).
( d ) *Holding period.* The holding period of property transferred to a political organization to which this section applies begins on the day after the date of acquisition of the property by the political organization.
[T.D. 7671, 45 FR 8003, Feb. 6, 1980]
#### § 1.679-0 Outline of major topics.

This section lists the major paragraphs contained in §§ 1.679-1 through 1.679-7 as follows:

## § 1.679-1 U.S. transferor treated as owner of foreign trust.

(a) In general.

(b) Interaction with sections 673 through 678.

(c) Definitions.

(1) U.S. transferor.

(2) U.S. person.

(3) Foreign trust.

(4) Property.

(5) Related person.

(6) Obligation.

(d) Examples.

## § 1.679-2 Trusts treated as having a U.S. beneficiary.

(a) Existence of U.S. beneficiary.

(1) In general.

(2) Benefit to a U.S. person

(i) In general.

(ii) Certain unexpected beneficiaries.

(iii) Examples.

(3) Changes in beneficiary's status.

(i) In general.

(ii) Examples.

(4) General rules.

(i) Records and documents.

(ii) Additional factors.

(iii) Examples.

(b) Indirect U.S. beneficiaries.

(1) Certain foreign entities.

(2) Other indirect beneficiaries.

(3) Examples.

(c) Treatment of U.S. transferor upon foreign trust's acquisition or loss of U.S. beneficiary.

(1) Trusts acquiring a U.S. beneficiary.

(2) Trusts ceasing to have a U.S. beneficiary.

(3) Examples.

## § 1.679-3 Transfers.

(a) In general.

(b) Transfers by certain trusts.

(1) In general.

(2) Example.

(c) Indirect transfers.

(1) Principal purpose of tax avoidance.

(2) Principal purpose of tax avoidance deemed to exist.

(3) Effect of disregarding intermediary.

(i) In general.

(ii) Special rule.

(iii) Effect on intermediary.

(4) Related parties.

(5) Examples.

(d) Constructive transfers.

(1) In general.

(2) Examples.

(e) Guarantee of trust obligations.

(1) In general.

(2) Amount transferred.

(3) Principal repayments.

(4) Guarantee.

(5) Examples.

(f) Transfers to entities owned by a foreign trust.

(1) General rule.

(2) Examples.

## § 1.679-4 Exceptions to general rule.

(a) In general.

(b) Transfers for fair market value.

(1) In general.

(2) Special rule.

(i) Transfers for partial consideration.

(ii) Example.

(c) Certain obligations not taken into account.

(d) Qualified obligations.

(1) In general.

(2) Additional loans.

(3) Obligations that cease to be qualified.

(4) Transfers resulting from failed qualified obligations.

(5) Renegotiated loans.

(6) Principal repayments.

(7) Examples.

## § 1.679-5 Pre-immigration trusts.

(a) In general.

(b) Special rules.

(1) Change in grantor trust status.

(2) Treatment of undistributed income.

(c) Examples.

## § 1.679-6 Outbound migrations of domestic trusts.

(a) In general.

(b) Amount deemed transferred.

(c) Example.

## § 1.679-7 Effective dates.

(a) In general.

(b) Special rules.

[T.D. 8955, 66 FR 37889, July 20, 2001]
#### § 1.441-4 Effective date.

Sections 1.441-0 through 1.441-3 are applicable for taxable years ending on or after May 17, 2002.

[T.D. 8996, 67 FR 35012, May 17, 2002]
[if !vml]>[endif]>

[if !vml]>[endif]>

You have reached the FederalDepository Library Program Electronic Collection (FDLP/EC) Archive. Thisarchive assures ongoing access to publications in the FDLP/EC. Access to publicationsin the archive is available through GPO's suite of cataloging and locatorservices, including the Catalog of U.S. Government Publications (CGP). Archived copies of publications are retrieved in the event that publicationsare no longer available from the original publishing agency site. 
**Title:Marine Corps history.**
 
Volume1: No1 | No2
Volume2: No1 | No2
Volume3: No1 | No2
Volume4: No1 | No2
Volume5: No1
 
SuDoc Number:D 214.20: | D 214.511/2:
Item Number:0383-B-01 | 0386-A-03
CGP systemNumber:000962893
 
August 23, 2018
NOTE: Pursuant to Fed. Cir. R. 47.6, this disposition is 

not citable as precedent. It is a public record. 

United States Court of Appeals for the Federal Circuit 

 

05-3285 

CHARLES R. JORDAN, 

 Petitioner, 

 v. 

MERIT SYSTEMS PROTECTION BOARD, 

Respondent. 

 __________________________ 

 DECIDED: April 7, 2006 

 __________________________ 

Before MAYER, LOURIE, and LINN, Circuit Judges. 

PER CURIAM. 

Charles R. Jordan appeals the decision of the Merit Systems Protection Board, 

which dismissed his appeal for lack of jurisdiction. Jordan v. Dep’t of the Air Force, 

SF3443040747-I-1 (MSPB Aug. 29, 2005). We affirm. 

This court may only reverse a board’s decision if it was arbitrary, capricious, an 

abuse of discretion, or unlawful; procedurally deficient; or unsupported by substantial 

evidence. See 5 U.S.C. § 7703(c). Whether the board has jurisdiction over an appeal 

is a question of law that we review de novo. See Herman v. Dep’t of Justice, 193 F.3d 

1375, 1378 (Fed. Cir. 1999). 
Jordan had the burden to establish the board’s jurisdiction by presenting 

evidence that he was an eligible civilian federal employee entitled to appeal to the board 

under the Uniformed Services Employment and Reemployment Rights Act of 1994 

(codified as amended at 38 U.S.C. §§ 4301-4333) (“USERRA”). Although aware his

status as a “civilian employee” was at issue, Jordan failed to present any evidence that 

he was a civilian employee of the Air Force. His military medical history was not 

relevant to that question. We find no error in the board’s factual determinations and 

conclude that the board lacked jurisdiction over the appeal. 

05-3285 2
#### § 1.6417-0 Table of Contents.

This section lists the table of contents for §§ 1.6417-1 through 1.6417-6.

## § 1.6417-1 Elective payment election of applicable credits.

(a) In general.

(b) Annual tax return.

(c) Applicable entity.

(d) Applicable credit.

(e) Applicable credit property.

(f) Disregarded entity.

(g) Electing taxpayer.

(h) Elective payment amount.

(i) Elective payment election.

(j) Guidance.

(k) Indian tribal government.

(l) Partnership.

(m) S corporation.

(n) Section 6417 regulations.

(o) Statutory references.

(p) U.S. territory.

(q) Applicability date.

## § 1.6417-2 Rules for making elective payment elections.

(a) Elective payment elections.

(b) Manner of making election.

(c) Determination of applicable credit.

(d) Timing of payment.

(e) Denial of double benefit.

(f) Applicability date.

## § 1.6417-3 Special rules for electing taxpayers.

(a) In general.

(b) Elections with respect to the credit for production of clean hydrogen.

(c) Election with respect to the credit for carbon oxide sequestration.

(d) Election with respect to the advanced manufacturing production credit.

(e) Election for electing taxpayers.

(f) Applicability date.

## § 1.6417-4 Elective payment election for electing taxpayers that are partnerships or S corporations.

(a) In general.

(b) Elections.

(c) Effect of election.

(d) Determination of amount of the credit.

(e) Partnerships subject to subchapter C of chapter 63.

(f) Applicability date.

## § 1.6417-5 Additional information and registration.

(a) Pre-filing registration and election.

(b) Pre-filing registration requirements.

(c) Registration number.

(d) Applicability date.

## § 1.6417-6 Special rules.

(a) Excessive payment.

(b) Basis reduction and recapture.

(c) Mirror code territories.

(d) Partnerships subject to subchapter C of chapter 63 of the Code.

(e) Applicability date.

[TD 9988, 89 FR 17584, Mar. 11, 2024; 89 FR 66562, Aug. 16, 2024]
<TABLE> <S> <C>

<ARTICLE>                            5
<LEGEND>                THIS SCHEDULE CONTAINS SUMMARY FINANCIAL
                        INFORMATION EXTRACTED FROM 10Q DATED 
                        JUNE 30, 1997 AND IS QUALIFIED IN ITS
                        ENTIRETY BY REFERENCE TO SUCH FINANCIAL
                        STATEMENTS
<MULTIPLIER>                 1000
       
<S>                          <C>
<PERIOD-TYPE>                6-MOS
<FISCAL-YEAR-END>            DEC-31-1997
<PERIOD-END>                 JUN-30-1997
<CASH>                       201760
<SECURITIES>                 1300214
<RECEIVABLES>                91744
<ALLOWANCES>                 5623
<INVENTORY>                  0
<CURRENT-ASSETS>             1688549
<PP&E>                       141797
<DEPRECIATION>               94349
<TOTAL-ASSETS>               2140463
<CURRENT-LIABILITIES>        219814
<BONDS>                      0
<PREFERRED-MANDATORY>        0
<PREFERRED>                  0
<COMMON>                     238
<OTHER-SE>                   1755013
<TOTAL-LIABILITY-AND-EQUITY> 2140463
<SALES>                      0
<TOTAL-REVENUES>             219953
<CGS>                        0
<TOTAL-COSTS>                168880
<OTHER-EXPENSES>             0
<LOSS-PROVISION>             0
<INTEREST-EXPENSE>           0
<INCOME-PRETAX>              209635
<INCOME-TAX>                 83900
<INCOME-CONTINUING>          116908
<DISCONTINUED>               0
<EXTRAORDINARY>              0
<CHANGES>                    0
<NET-INCOME>                 116908
<EPS-PRIMARY>                4.97
<EPS-DILUTED>                0
        

</TABLE>
[ DO NOT PUBLISH] 

## In the 

# United States Court of Appeals For the Eleventh Circuit

____________________
No. 22

- 14262

Non

- Argument Calendar

____________________
UNITED STATES OF AMERICA,
Plaintiff

- Appellee,

versus CLAYTON EUGENE POWELL,

Defendant

- Appellant.

____________________ Appeal from the United States District Court for the Middle District of Alabama D.C. Docket No. 2:21

- cr

- 00443

- WKW

- SMD

- 1

____________________ USCA11 Case: 22-14262 Document: 21-1 Date Filed: 07/05/2023 Page: 1 of 22 Opinion of the Court 22

- 14262

Before N EWSOM , G RANT , and B LACK , Circuit Judges.

PER CURIAM: The Government’s motion to dismiss this appeal pursuant to the appeal waiver in Appellant’s plea agreement is GRANTED. See United States v. Bushert , 997 F.2d 1343, 1350

– 51 (11th Cir. 1993) (sentence appeal waiver will be enforc ed if it was made knowingly and voluntarily); United States v. Bascomb , 451 F.3d 1292, 1297 (11thCir. 2006) (appeal waiver “cannot be vitiated or altered by comments the court makes during sentencing”); United States v. Grinard

Henry , 399 F.3d 1294, 1296 (11th Cir. 2005) (waiver of the right to appeal includes waiver of the right to appeal difficult or debatable legal issues or even blatant error). USCA11 Case: 22-14262 Document: 21-1 Date Filed: 07/05/2023 Page: 2 of 2
**Exhibit 32.2**

**Certification ofthe Chief Financial OfficerPursuant to 18 U.S.C. Section 1350**

Inconnection with the Quarterly Report on Form 10-Q of Kaiser Group Holdings,Inc. (the “Company”) for the period ended September 30, 2006, as filed with theSecurities and Exchange Commission on the date hereof (the “Report”), I,Nicholas Burakow, Chief Financial Officer of the Company, certify, to the bestof my knowledge, pursuant to 18 U.S.C. § 1350, as adopted pursuant to § 906 ofthe Sarbanes-Oxley Act of 2002, that:

(1)  The Reportfully complies with the requirements of Section 13(a) or 15(d) of theSecurities Exchange Act of 1934, as amended; and

(2)  Theinformation contained in the Report fairly presents, in all material respects,the financial condition and results of operations of the Company.
| November 14, 2006 |   | /s/ Nicholas Burakow     |
|-------------------|--------|--------------------------|
|              |   | Nicholas Burakow, Ph.D., |
|              |   | Chief Financial Officer  |

 

----
39447.

#### HOUSING AUTHORITY OF THE CITY OF MARIETTA v. YORK.

Carlisle, Presiding Judge.

1. Where in a condemnation case the property sought to be condemned is shown to be part of a larger tract being acquired by the condemnor for the purposes of urban renewal or urban redevelopment, and where the evidence shows that the acquisition of the particular property is part of a comprehensive plan for clearing out the area, widening and relocating streets, and redeveloping the area by selling the property to private or corporate purchasers for the purpose of developing light industry or the erection of new homes, an instruction by the court that, “If at the time the property sought to be condemned was to be estimated, it was known or anticipated that certain improvements would be made in the locality where the property was situated, and this fact serves to enhance the market value of the property, the owner would be entitled to the actual market value as affected by the reason of the fact that it was known or anticipated that such improvements are to be made by the condemning party,” was not erroneous as against the contention that it was neither authorized by the pleadings or the evidence *42or that it submitted an improper and illegal matter for the jury’s consideration in arriving at a verdict on the question of value. *Gate City Terminal Co. v. Thrower,*136 Ga. 456 (3) (71 SE 903).

Decided April 30, 1962

Rehearing denied May 16, 1962.

*Edwards, Bentley, Awtrey & Bartlett, Fred E. Bartlett, Jr.,*for plaintiff in error.

*Holcomb & McDuff, Robert E. McDuff,*contra.

2. Neither was such charge erroneous in that it amounted to an intimation to the jury trying the case that there were in fact known or anticipated improvements to be made by the condemnor since the instruction began by telling the jury that *“if”*the improvements were to be made in the locality they might take that fact into consideration in considering whether such anticipated improvements would enhance the market value of the property. *Gray v. Junction City Mfg. Co.,*195 Ga. 33 (2) (22 SE2d 847).

*Judgment affirmed.*

*Eberhardt and Russell, JJ., concur.*
§ 1.651(a)-3 Distribution of amounts other than income. ( a ) A trust does not qualify for treatment under section 651 for any taxable year in which it actually distributes corpus. For example, a trust which is required to distribute all of its income currently would not qualify as a simple trust under section 651 in the year of its termination since in that year actual distributions of corpus would be made.
( b ) A trust, otherwise qualifying under section 651, which may make a distribution of corpus in the discretion of the trustee, or which is required under the terms of its governing instrument to make a distribution of corpus upon the happening of a specified event, will be disqualified for treatment under section 651 only for the taxable year in which an actual distribution of corpus is made. For example: Under the terms of a trust, which is required to distribute all of its income currently, half of the corpus is to be distributed to beneficiary A when he becomes 30 years of age. The trust reports on the calendar year basis. On December 28, 1954, A becomes 30 years of age and the trustee distributes half of the corpus of the trust to him on January 3, 1955. The trust will be disqualified for treatment under section 651 only for the taxable year 1955, the year in which an actual distribution of corpus is made.
( c ) See section 661 and the regulations thereunder for the treatment of trusts which distribute corpus or claim the charitable contributions deduction provided by section 642(c).
BEFORE THE UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

------------------------------------------------------------------- X In re the Complaint of PENSACOLA AVIATION CENTER , LLC

Complainant,

- against

- Docket No. 16

- 12
- 12 PENSACOLA INTERNATIONAL AIRPORT, A DIVISION OF THE CITY OF PENSACOLA

Respondent. Pursuant to Part 16 of the Federal Aviation Regulations

---------------------------------------------------------------------X **MOTION FOR EXTENSION OF TIME**  COMES NOW THE COMPLAI NANT, PENSACOLA AVIATION CENTER, LLC pursuant to CFR §16.11, and requests an extension of time to January 1 4, 2013 within which to file its responsive repl y to the Respondent’s Answer and its opposition to Respondent’ s Motion to Dismiss in this proceeding. In support thereof, Complainant states as follows: 1. The Complaint in this proceeding was docketed on or about September 18, 2012. 2. Complainant served the Complaint on October 9, 2012 (which Respondent received on Octob er 15, 2012). 3. Respondent served its Answer on or about November 28, 2012. 4. By

an initial agreement of the parties, the deadline for a responsive reply and opposition to any

motion to dismiss was extended to January 14, 2013.5. Upon thorough review of the Resp ondent’s Answer and Motion to Dismiss,

Complainant has determined that it requires an extension of time in which to repl y to the Answer and respond to Respondent’s Motion to Dismiss. 6. The FAA may

authorize an extension of time pursuant to 14 CFR §16.11(a). WHEREFORE, Complainant requests an extension of time up to and including January 14, 2013, within which to file its responsive reply and opposition to Respondent’s Motion to Dismiss
. Dated: Jericho, New York December 27, 2012 Respectfully Submitted , By : /s/ Leonard D. Kirsch Leonard D. Kirsch McBreen & Kopko 500 North Broadway, Suite 129 Jericho, New York 11753 (516) 364

- 1095 lkirsch@mklawnyc.com Counsel to Complainant, Pensacola Aviation Center, LLC**CERTIFICATE OF SERVICE**

I hereb y certify

that on December 2 7 , 2012, a true and correct cop y of the foregoing MOTION FOR EXTENSION OF TIME was served by F ederal Express Next Day Mail and electronic mail upon the following:

Eric T. Smith, Esq. Schnader Harrison Segal & Lewis, LLP Fifth Avenue Place 120 Fifth Avenue, Suite 2700 Pittsburgh, PA 15222

- 3001 esmith@schnader.com
/s/ Leonard D. Kirsch Leonard D. Kirsch Counsel to Complainant, Pensacola Aviation Center, LLC