alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
§ 20.2056A-3 QDOT election. ( a ) *General rule.* Subject to the time period prescribed in section 2056A(d), the election to treat a trust as a QDOT must be made on the last federal estate tax return filed before the due date (including extensions of time to file actually granted) or, if a timely return is not filed, on the first federal estate tax return filed after the due date. The election, once made, is irrevocable.
( b ) *No partial elections.* An election to treat a trust as a QDOT may not be made with respect to a specific portion of an entire trust that would otherwise qualify for the marital deduction but for the application of section 2056(d). However, if the trust is actually severed in accordance with the applicable requirements of § 20.2056(b)-7(b)(2)(ii) prior to the due date for the election, a QDOT election may be made for any one or more of the severed trusts.
( c ) *Protective elections.* A protective election may be made to treat a trust as a QDOT only if at the time the federal estate tax return is filed, the executor of the decedent's estate reasonably believes that there is a bona fide issue that concerns either the residency or citizenship of the decedent, the citizenship of the surviving spouse, whether an asset is includible in the decedent's gross estate, or the amount or nature of the property the surviving spouse is entitled to receive. For example, if at the time the federal estate tax return is filed either the estate is involved in a bona fide will contest, there is uncertainty regarding the inclusion in the gross estate of an asset which, if includible, would be eligible for the QDOT election, or there is uncertainty regarding the status of the decedent as a resident alien or a nonresident alien for estate tax purposes, or a similar uncertainty regarding the citizenship status of the surviving spouse, a protective QDOT election may be made. The protective election is in addition to, and is not in lieu of, the requirements set forth in § 20.2056A-4. The protective QDOT election must be made on a written statement signed by the executor under penalties of perjury and must be attached to the return described in paragraph (a) of this section, and must identify the specific assets to which the protective election refers and the specific basis for the protective election. However, the protective election may otherwise be defined by means of a formula (such as the minimum amount necessary to reduce the estate tax to zero). Once made, the protective election is irrevocable. For example, if a protective election is made because a bona fide question exists as to the includibility of an asset in the decedent's gross estate and it is later finally determined that the asset is so includible, the protective election becomes effective with respect to the asset and cannot thereafter be revoked.
( d ) *Manner of election.* The QDOT election under paragraph (a) of this section is made in the form and manner set forth in the decedent's estate tax return, including applicable instructions.
[T.D. 8612, 60 FR 43540, Aug. 22, 1995]
[DO NOT PUBLISH]

In the

United States Court of Appeals

For the Eleventh Circuit

____________________

No. 22-10470

Non-Argument Calendar

____________________

UNITED STATES OF AMERICA, 

Plaintiff-Appellee,

versus

JAMIE JOSEPH MANZ, 

Defendant-Appellant.

____________________

Appeal from the United States District Court

for the Middle District of Florida

D.C. Docket No. 8:18-cr-00477-WFJ-SPF-1

____________________

USCA11 Case: 22-10470 Date Filed: 07/29/2022 Page: 1 of 2
22-10470 Opinion of the Court 2

Before WILLIAM PRYOR, Chief Judge, WILSON and 

ANDERSON, Circuit Judges.

PER CURIAM:

Jenny Devine, appointed counsel for Jamie Manz in this 

direct criminal appeal, has moved to withdraw from further 

representation of the appellant and filed a brief pursuant to Anders 

v. California, 386 U.S. 738 (1967). Our independent review of the 

entire record reveals that counsel’s assessment of the relative merit 

of the appeal is correct. Because independent examination of the 

entire record reveals no arguable issues of merit, counsel’s motion 

to withdraw is GRANTED, and Manz’s revocation of supervised 

release and sentence are AFFIRMED.

USCA11 Case: 22-10470 Date Filed: 07/29/2022 Page: 2 of 2
##### 



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
 .
  1.
    
    the Form 10-Q fully complies with the requirements of Section 13(a) or 15(d) as
applicable, of the Securities Exchange Act of 1934; and2.
    
    the information contained in the Form 10-Q fairly presents, in all material respects,
the financial condition and results of operations of the Company as of, and for, the
periods presented in the Form 10-Q.
 Date:  May 8, 2008
    /s/ James R. RidingsJAMES R. RIDINGSChairman of the Board and
Chief Executive Officer
Petition for Writ of Mandamus Denied and Memorandum Majority and 

Concurring Opinions filed November 23, 2021.

In The

Fourteenth Court of Appeals 

NO. 14-21-00438-CV

IN RE RONALD SCOTT CATT, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

268th District Court

Fort Bend County, Texas

Trial Court Cause No. 16-DCV-229074

MEMORANDUM MAJORITY OPINION

On August 5, 2021, relator Ronald Scott Catt filed a petition for writ of 

mandamus in this court. See Tex. Gov’t Code Ann. § 22.221; see also Tex. R. App. 

P. 52. In the petition, relator asks this court to compel the Honorable O’Neil 

Williams, presiding judge of the 268th District Court of Fort Bend County, to return 

forfeited property to relator.
2

Relator has not established that he is entitled to mandamus relief. 

Accordingly, we deny relator’s petition for writ of mandamus. 

PER CURIAM

Panel consists of Justices Jewell, Spain, and Wilson (Spain, J., concurring).
Editorial Note on Part 301
Editorial Note: In the text of this part, integral section references are to sections of the Internal Revenue Code of 1954; decimal section references are to the Code of Federal Regulations. References in the text to the “Code” are references to sections of the Internal Revenue Code of 1954.

§ 301.6103(a)-1 Disclosures after December 31, 1976, by officers and employees of Federal agencies of returns and return information (including taxpayer return information) disclosed to such officers and employees by the Internal Revenue Service before January 1, 1977, for a purpose not involving tax administration. ( a ) *General rule.* Except as provided by paragraph (b) of this section, a return or return information (including taxpayer return information), as defined in section 6103(b) (1), (2), and (3) of the Internal Revenue Code, disclosed by the Internal Revenue Service before January 1, 1977, to an officer or employee of a Federal agency (as defined in section 6103(b)(9)) for a purpose not involving tax administration (as defined in section 6103(b)(4)) pursuant to the authority of section 6103 (or any order of the President under section 6103 or rules and regulations thereunder prescribed by the Secretary or his delegate and approved by the President) before amendment of such section by section 1202 of the Tax Reform Act of 1976 (Pub. L. 94-455, 90 Stat. 1667) may be disclosed by, or on behalf of, such officer, employee, or agency after December 31, 1976, for any purpose authorized by such section (or such order or rules and regulations) before such amendment.
( b ) *Exception.* Notwithstanding the provisions of paragraph (a) of this section, a return or return information (including taxpayer return information) disclosed before January 1, 1977, by the Service to an officer or employee of a Federal agency for a purpose unrelated to tax administration as described in paragraph (a) may, after December 31, 1976, be disclosed by, or on behalf of, such agency, officer, or employee in an administrative or judicial proceeding only if such proceeding is one described in section 6103(i)(4) of the Code and if the requirements of section 6103(i)(4) have first been met.
(Secs. 6103 and 7805 of the Internal Revenue Code of 1954 (90 Stat. 1667, 68A Stat. 917; 26 U.S.C. 6103 and 7805))
[T.D. 7723, 45 FR 65566, Oct. 3, 1980]
Editorial Note on Part 301
Editorial Note: In the text of this part, integral section references are to sections of the Internal Revenue Code of 1954; decimal section references are to the Code of Federal Regulations. References in the text to the “Code” are references to sections of the Internal Revenue Code of 1954.

§ 301.6314-1 Receipt for taxes. ( a ) *In general.* The district director or the director of a service center shall upon request, issue a receipt for each tax payment made (other than a payment for stamps sold and delivered). In addition, the district director or the director of a service center shall issue a receipt for each payment of 1 dollar or more made in cash, whether or not requested. In the case of payments made by check, the canceled check is usually a sufficient receipt. No receipt shall be issued in lieu of a stamp representing a tax, whether the payment is in cash or otherwise.
( b ) *Duplicate receipt for payment of estate taxes.* Upon request, the district director or the director of a service center will issue duplicate receipts to the person paying the estate tax, either of which will be sufficient evidence of such payment and entitle the executor to be credited with the amount by any court having jurisdiction to audit or settle his accounts. For definition of the term “executor”, see section 2203.
[T.D. 7214, 37 FR 23176, Oct. 31, 1972]
Line 1 

(CWPB 3) GF (#/T) PF (#/T) TF (#/T)

 Secondary (Roof 

monthly avg.) 

 Primary 

(Stack) Total Limit

1/3/2013 0.26 0.25 0.51

1/4/2013 0.22 0.25 0.47

1/16/2013 0.22 0.25 0.46 0.48 0.917 1.40 2.5

2/5/2013 0.39 0.29 0.68

2/6/2013 0.31 0.20 0.51

2/21/2013 0.29 0.31 0.60 0.60 0.917 1.51 2.5

3/5/2013 0.52 0.25 0.76

3/6/2013 0.29 0.28 0.57

3/20/2013 0.34 0.39 0.73 0.69 0.917 1.60 2.5

4/2/2013 0.36 0.36 0.72

4/3/2013 0.24 0.28 0.52

4/18/2013 0.65 0.46 1.11 0.78 0.917 1.70 2.5

5/10/2013 1.40 0.58 1.98

5/19/2013 1.02 0.30 1.32

5/20/2013 0.73 0.38 1.11 1.47 0.917 2.39 2.5

6/7/2013 0.77 0.43 1.21

6/8/2013 0.82 0.38 1.20

6/18/2013 0.25 0.07 0.32 0.91 0.917 1.83 2.5

Line 2 

(CWPB 3) GF (#/T) PF (#/T) TF (#/T)

 Secondary (Roof 

monthly avg.) 

 Primary 

(Stack) Total Limit

1/3/2013 0.17 0.16 0.33

1/4/2013 0.23 0.20 0.42

1/16/2013 0.19 0.21 0.40 0.38 0.917 1.30 2.5

2/5/2013 0.24 0.24 0.48

2/6/2013 0.14 0.13 0.27

2/21/2013 0.55 0.29 0.84 0.53 0.917 1.45 2.5

3/5/2013 0.72 0.25 0.97

3/6/2013 0.51 0.30 0.81

3/20/2013 0.27 0.34 0.61 0.80 0.917 1.71 2.5

4/2/2013 0.09 0.06 0.15

4/3/2013 0.09 0.09 0.18

4/16/2013 0.14 0.11 0.25 0.19 0.917 1.11 2.5

5/9/2013 0.13 0.05 0.18

5/17/2013 0.17 0.05 0.22

5/18/2013 0.15 0.07 0.22 0.21 0.917 1.12 2.5

6/7/2013 0.46 0.23 0.69

6/18/2013 0.59 0.27 0.86

6/19/2013 0.42 0.19 0.61 0.72 0.917 1.64 2.5

Line 3 

(CWPB 3) GF (#/T) PF (#/T) TF (#/T)

 Secondary (Roof 

monthly avg.) 

 Primary 

(Stack) Total Limit

01/03/13 0.52 0.39 0.90

01/04/13 0.95 0.66 1.60
01/16/13 0.46 0.46 0.92 1.14 0.917 2.06 2.5

02/05/13 0.43 0.32 0.75

02/06/13 0.45 0.34 0.79

02/21/13 0.34 0.25 0.59 0.71 0.917 1.62 2.5

03/05/13 0.43 0.30 0.74

03/06/13 0.57 0.38 0.94

03/20/13 0.39 0.40 0.79 0.82 0.917 1.74 2.5

04/02/13 0.62 0.54 1.16

04/03/13 0.45 0.29 0.74

04/18/13 0.50 0.09 0.59 0.83 0.917 1.75 2.5

05/09/13 0.72 0.24 0.96

05/10/13 0.78 0.16 0.94

05/17/13 0.96 0.26 1.22 1.04 0.917 1.96 2.5

6/7/2013 0.80 0.37 1.16

6/8/2013 0.68 0.26 0.94

6/18/2013 0.89 0.76 1.65 1.25 0.917 2.17 2.5

Line 4 

(CWPB 3) GF (#/T) PF (#/T) TF (#/T)

 Secondary (Roof 

monthly avg.) 

 Primary 

(Stack) Total Limit

01/03/13 0.35 0.24 0.59

01/04/13 0.29 0.19 0.48

01/16/13 0.26 0.26 0.53 0.53 0.917 1.45 2.5

02/05/13 0.45 0.35 0.8

02/06/13 0.79 0.48 1.27

02/19/13 0.61 0.68 1.29 1.12 0.917 2.04 2.5

03/06/13 0.51 0.32 0.83

03/07/13 0.51 0.22 0.74

03/20/13 0.73 0.56 1.29 0.95 0.917 1.87 2.5

04/02/13 0.62 0.54 1.16

04/03/13 0.45 0.29 0.74

04/18/13 0.50 0.09 0.59 0.83 0.917 1.75 2.5

05/09/13 0.51 0.18 0.69

05/10/13 0.50 0.32 0.82

05/17/13 0.49 0.22 0.71 0.74 0.917 1.66 2.5

06/07/13 0.79 0.36 1.15

06/08/13 0.74 0.19 0.93

06/18/13 0.89 0.32 1.21 1.10 0.917 2.01 2.5

Line 5 

(CWPB 1)

Quarterly 

Sampling GF (#/T) PF (#/T) TF (#/T)

 Secondary (Roof 

monthly avg.) 

 Line 5 

(Stack) Total Limit

3/7/2013 1.03 0.70 1.74

3/20/2013 0.25 0.28 0.53

3/21/2013 0.18 0.16 0.34 0.87 0.086 0.96 1.2
4/2/2013 0.63 0.52 1.15

4/3/2013 0.66 0.65 1.30

4/18/2013 0.50 0.62 1.11

4/24/2013 0.31 0.41 0.72 1.07 0.086 1.16 1.2
#### § 1.673(c)-1 Reversionary interest after income beneficiary's death.

The subject matter of section 673(c) is covered in paragraph (b) of § 1.673(a)-1.
§ 1.304-3 Acquisition by a subsidiary. ( a ) If a subsidiary acquires stock of its parent corporation from a shareholder of the parent corporation, the acquisition of such stock shall be treated as though the parent corporation had redeemed its own stock. For the purpose of this section, a corporation is a parent corporation if it meets the 50 percent ownership requirements of section 304(c). The determination whether the amount received shall be treated as an amount received in payment in exchange for the stock shall be made by applying section 303, or by applying section 302(b) with reference to the stock of the issuing parent corporation. If such distribution would have been treated as a distribution of property (pursuant to section 302(d)) under section 301, the entire amount of the selling price of the stock shall be treated as a dividend to the seller to the extent of the earnings and profits of the parent corporation determined as if the distribution had been made to it of the property that the subsidiary exchanged for the stock. In such cases, the transferor's basis for his remaining stock in the parent corporation will be determined by including the amount of the basis of the stock of the parent corporation sold to the subsidiary.
( b ) Section 304(a)(2) may be illustrated by the following example:
Example. Corporation M has outstanding 100 shares of common stock which are owned as follows: B, 75 shares, C, son of B, 20 shares, and D, daughter of B, 5 shares. Corporation M owns the stock of Corporation X. B sells his 75 shares of Corporation M stock to Corporation X. Under section 302(b)(3) this is a termination of B's entire interest in Corporation M and the full amount received from the sale of his stock will be treated as payment in exchange for this stock, provided he fulfills the requirements of section 302(c)(2) (relating to an acquisition of an interest in the corporations).
SUPREME COURT OF THE STATE OF NEW YORK

Appellate Division, Fourth Judicial Department

1219 

CA 13-02141 

PRESENT: SMITH, J.P., CENTRA, FAHEY, LINDLEY, AND WHALEN, JJ. 

 

INCREDIBLE INVESTMENTS LIMITED, ON ITS OWN AND 

ON BEHALF OF ONE NIAGARA, LLC, 

PLAINTIFF-RESPONDENT, 

V ORDER

PAUL GRENGA, INDIVIDUALLY, AND AS PRESIDENT OF 

WHITESTAR DEVELOPMENT CORP., AND AS CLAIMED 

CURRENT MANAGER OF ONE NIAGARA, LLC, WHITESTAR 

DEVELOPMENT CORP., DEFENDANTS-APPELLANTS,

ET AL., DEFENDANT. 

(APPEAL NO. 1.) 

 

LAW OFFICE OF RALPH C. LORIGO, WEST SENECA (JON F. MINEAR OF COUNSEL),

FOR DEFENDANTS-APPELLANTS. 

SANDERS & SANDERS, CHEEKTOWAGA (HARVEY P. SANDERS OF COUNSEL), FOR

PLAINTIFF-RESPONDENT. 

 

Appeal from an order of the Supreme Court, Niagara County

(Timothy J. Walker, A.J.), entered March 8, 2013. The order, among

other things, granted plaintiff’s motion for partial summary judgment

and denied defendants’ cross motion for summary judgment. 

It is hereby ORDERED that said appeal is unanimously dismissed

without costs (see Loafin’ Tree Rest. v Pardi [appeal No. 1], 162 AD2d

985, 985). 

Entered: February 6, 2015 Frances E. Cafarell

Clerk of the Court
Exhibit 10.19


    
      

    

    Exhibit
      10.19

    


    MARINE
      PRODUCTS

    


    FIRST
      AMENDMENT TO

    2001
      EMPLOYEE STOCK INCENTIVE PLAN

    AND

    2004
      STOCK INCENTIVE PLAN

    


    Marine
      Products Corporation (the "Company"), a corporation organized under the laws
      of
      the State of Delaware, by resolution of its Board of Directors has adopted
      this
      First Amendment to its 2001 Employee Stock Incentive Plan and the 2004 Stock
      Incentive Plan (the "Plans"), effective as of July 25, 2006.

    


    1.    Each
      of
      the Plans is hereby amended to the extent necessary to provide as
      follows:

    


    If
      the
      outstanding shares of common stock of Marine Products Corporation (the
“Company”) are changed into or exchanged for a different number or kind of
      shares or other securities of the Company by reason of any recapitalization,
      reclassification, stock split, stock dividend, combination or subdivision of
      the
      common stock of the Company, or similar transaction involving the outstanding
      equity interests in the Company (each, a “Change in Capitalization”), then,
      subject to any required action by the stockholders of the Company, the number
      and kind of shares of Company stock underlying each stock option, restricted
      stock award, or other equity award (and, where applicable, the exercise price
      per share) shall be proportionately and equitably adjusted for any increase
      or
      decrease in the number of issued shares of the Company resulting from a Change
      in Capitalization, such adjustments to be effected in the manner reasonably
      determined by the Committee. Notwithstanding the foregoing, no fractional shares
      shall be issued in making the foregoing adjustments. This provision shall be
      effective immediately upon adoption by the Board of Directors and apply to
      all
      currently outstanding equity awards under each of the Plans.

    


    2.    All
      provisions of the Plans remain in effect except to the extent superseded by
      the
      foregoing.

     

    IN
      WITNESS WHEREOF, the Board has caused this Plan to be executed by a duly
      authorized officer of the Company as of the date set forth above.

     

                            MARINE
      PRODUCTS
      CORPORATION

     

    


     

                            By: 
       /s/ Ben M.
      Palmer                               


                                                                    
      Chief Financial Officer and Treasurer
##### 



Exhibit 32

Pursuant to section 906 of the
Sarbanes-Oxley Act of 2002 (subsections (a) and (b) of
Section 1350, Chapter 63 of Title 18, United States
Code), each of the undersigned officers of Potash Corporation of
Saskatchewan Inc. (the Company), does hereby
certify, to such officers knowledge, that:

The Quarterly Report on Form 10-Q for the
quarter ended September 30, 2003 (the
Form 10-Q), of the Company fully complies with
the requirements of section 13(a) or 15(d) of the
Securities Exchange Act of 1934 and information contained in the
Form 10-Q fairly presents, in all material respects, the
financial condition and results of operations of the Company.

Dated: November 6, 2003



| |                                          
| | -----------------------------------------
| | /s/ WILLIAM J. DOYLE                     
| |                                          
| | William J. Doyle                         
| | President and Chief Executive
    Officer

Dated: November 6, 2003



| |                                          
| | -----------------------------------------
| | /s/ WAYNE R. BROWNLEE                    
| |                                          
| | Wayne R. Brownlee                        
| | Senior Vice President, Treasurer,
    and
| | Chief Financial Officer                  

The foregoing certification is being furnished as
an exhibit to the Form 10-Q pursuant to
Item 601(6)(32) of Regulation S-K, section 906 of
the Sarbanes-Oxley Act of 2002 (subsections (a) and (b) of
Section 1350, Chapter 63 of Title 18, United States
Code) and, accordingly, is not being filed as part of the
Form 10-Q.
<TABLE> <S> <C>
                                           
<ARTICLE>                                       5
                                                 
<S>                                               <C>
<PERIOD-TYPE>                                   9-mos
<FISCAL-YEAR-END>                               Dec-31-1998
<PERIOD-END>                                    Sep-30-1998
<CASH>                                                 7,971,365
<SECURITIES>                                                   0
<RECEIVABLES>                                            191,289
<ALLOWANCES>                                                   0
<INVENTORY>                                                    0
<CURRENT-ASSETS>                                               0
<PP&E>                                                         0
<DEPRECIATION>                                                 0
<TOTAL-ASSETS>                                        15,557,384
<CURRENT-LIABILITIES>                                          0
<BONDS>                                                        0
<PREFERRED-MANDATORY>                                          0
<PREFERRED>                                                    0
<COMMON>                                                       0
<OTHER-SE>                                            13,153,136
<TOTAL-LIABILITY-AND-EQUITY>                          15,557,384
<SALES>                                                        0
<TOTAL-REVENUES>                                       3,648,552
<CGS>                                                          0
<TOTAL-COSTS>                                                  0
<OTHER-EXPENSES>                                       2,486,353
<LOSS-PROVISION>                                          17,173
<INTEREST-EXPENSE>                                        98,487
<INCOME-PRETAX>                                        1,046,539
<INCOME-TAX>                                                   0
<INCOME-CONTINUING>                                    1,046,539
<DISCONTINUED>                                                 0
<EXTRAORDINARY>                                                0
<CHANGES>                                                      0
<NET-INCOME>                                           1,046,539
<EPS-PRIMARY>                                                  0
<EPS-DILUTED>                                                  0
        
 

</TABLE>