alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
§ 1.901(m)-8 Miscellaneous. ( a ) *In general.* This section provides guidance on other matters under section 901(m). Paragraph (b) of this section provides guidance on the application of section 901(m) to pre-1987 foreign income taxes. Paragraph (c) of this section provides anti-abuse rules relating to built-in loss assets. Paragraph (d) of this section provides guidance on the interaction of section 901(m) and section 909. Paragraph (e) of this section provides applicability dates.
( b ) *Application of section 901(m) to pre-1987 foreign income taxes.* Section 901(m) and §§ 1.901(m)-1 through 1.901-8 apply to pre-1987 foreign income taxes (as defined in § 1.902-1(a)(10)(iii)) of an applicable foreign corporation.
( c ) *Anti-abuse rule for built-in loss RFAs.* A basis difference with respect to an RFA described in section 901(m)(3)(C)(ii) (*built-in loss RFA*) will not be taken into account for purposes of computing an allocated basis difference for a U.S. taxable year of a section 901(m) payor if any RFA, including an RFA other than built-in loss RFAs, is acquired with a principal purpose of using one or more built-in loss RFAs to avoid the application of section 901(m). Furthermore, a basis difference with respect to a built-in loss RFA will not be taken into account for purposes of the cumulative basis difference exemption or the RFA class exemption under § 1.901(m)-7 if any RFAs, including RFAs other than built-in loss RFAs, are acquired with a principal purpose of avoiding the application of section 901(m).
( d ) *Interaction with section 909.* The amount of a foreign income tax that is disqualified under section 901(m) is determined before applying section 909. However, section 909 may apply to suspend a deduction for the amount of a foreign income tax that is disqualified under section 901(m).
( e ) *Applicability dates.* This section applies to CAAs occurring on or after March 23, 2020. Taxpayers may, however, choose to apply this section before the date this section is applicable provided that they (along with any persons that are related (within the meaning of section 267(b) or 707(b)) to the taxpayer)— ( 1 ) Consistently apply this section, § 1.704-1(b)(4)(viii)( c )( 4 )( v ) through ( vii ), § 1.901(m)-1, and §§ 1.901(m)-3 through 1.901(m)-7 (excluding § 1.901(m)-4(e)) to all CAAs occurring on or after January 1, 2011, and consistently apply § 1.901(m)-2 (excluding § 1.901(m)-2(d)) to all CAAs occurring on or after December 7, 2016, on any original or amended tax return for each taxable year for which the application of the provisions listed in this paragraph (e)(1) affects the tax liability and for which the statute of limitations does not preclude assessment or the filing of a claim for refund, as applicable;
( 2 ) File all tax returns described in paragraph (e)(1) of this section for any taxable year ending on or before March 23, 2020, no later than March 23, 2021; and
( 3 ) Make appropriate adjustments to take into account deficiencies that would have resulted from the consistent application under paragraph (e)(2) of this section for taxable years that are not open for assessment.
[T.D. 9895, 85 FR 16267, Mar. 23, 2020]
p.1 

OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

93) IV-C-5 

Docket Number: 

A-81-21 

Printed 4/14/2008 8:47:02 AM Sheet 93 of 106 
P.2 

^ ,. A-8I-2L 

IV-C-5 

"... ^ 

Mr. W. Bailey Barton 

Director, Environmental Affairs 

Borden, Inc. 

180 East Broad Street 

Columbus, Ohio 43215 

Dear Mr. Barton: 

Please find enclosed the draft report of our January 3, 1985 meeting to 

discuss Incinerator operations under the vinyl chloride standard. Information presented during the meeting on incinerator operations and bypass 

occurrences at Borden's EDC/VC and PVC facility in Geismar, Louisiana have 

been summarized in the meeting report. Please take this opportunity to 

review the draft report for any inaccuracies or confidential business 

information and contact us within 2 to 3 days if such information is noted. 

Your prompt attention to this request 1s necessary to facilitate decision 

making on this issue. 

We appreciate your assistance in our data gathering efforts. If you 

have any questions or requests for revisions, please call Ms. Karen Fidler 

of Radian at (919) 541-9100 or me at (919) 541-5671. 

Sincerely, 

Robert E. Rosensteel 

Section Chief 

Chemicals and Petroleum Branch 

Emission Standards and 

Engineering Division 

cc: Chris Lunn, Borden/Geismar Plant 

OAQPS/ESED/SDB: WFDimmick, rm 1043, NCM, 541-5578 

(Radian/KKFidler/ibunn/541-9100/01-23-85) 
P.3 

Pending Confidential 

The following Information is located in the confidential 

files of the Director, Emission Standards and Engineering 

Division, Office of A1r Quality Planning and Standards, U.S. 

Environmental Protection Agency, Research Triangle Park, 

North Carolina. This Information is confidential, pending 

final determination by the Administrator, and is not available for public Inspection. 

Enclosure, dated January 15, 1985, from K. K. Fidler, Radian Corporation, to 

L. B. Evans, EPA:CPB. This 40-page trip report (January 3, 1985) contains 

pending confidential information.
§ 157.6694-1 Section 6694 penalties applicable to tax return preparer. ( a ) *In general.* For general definitions regarding section 6694 penalties applicable to preparers of tax returns or claims for refund for tax under section 5891 of the Internal Revenue Code see § 1.6694-1 of this chapter.
( b ) *Effective/applicability date.* Paragraph (a) of this section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.
[T.D. 9436, 73 FR 78462, Dec. 22, 2008]
### TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03
- 15
- 00015
- CR

Ronald Lee Verdi, Jr., Appellant

v. The State of Texas, Appellee

FROM THE 391ST DISTRICT COURT OF TOM GREEN COUNTY, NO. D
- 11
- 0505
- SA, THE HONORABLE TH OMAS J. GOSSETT, JUD GE PRE SIDING

O R D E R F O R C L E R K T O P R O V I D E A P P E L L A T E R E C O R D TO A P P E L L A N T

PER CURIAM

Appellant’s court

- appointed counsel has filed a motion to withdraw supported by a brief concluding that the instant appeal i s frivolous and without merit. See Anders

v. California , 386 U.S. 738, 744 (1967). Appellant’s counsel has certified to the Court that he provided copies of the motion and brief to appellant, advised appellant of his right to examine the appellate record and file a pro se response, and supplied appellant with a form motion for pro

se access to the appellate record. See Kelly v. State , 436 S.W.3d 313, 319

- 20 (Tex. Crim. App. 2014). Appellant has timely filed the motion requesting access to the appellate record with this Court. Appellant’s pro se motion is granted in part

. We hereby direct the clerk of the trial court to provide a copy of the reporter’s record and clerk’s record to appellant, and toprovide written verification to this Court of the date and manner in which the appellate record

was provided, on or before July 3, 2015

. See id. at 321. Appellant’s brief is due 120 days from the date he receives the record. The remainder of the relief requested is denied.

It is ordered on June 23, 2015.
B efore Chief Justice Rose, Justices Goodwin and Field

Do Not Publish
```

[Congressional Bills 103th Congress]
[From the U.S. Government Publishing Office]
[S. Res. 263 Agreed to Senate (ATS)]

103d CONGRESS
  2d Session
S. RES. 263

 To express the sense of the Senate condemning the cruel and tortuous 
                 practice of female genital mutilation.

_______________________________________________________________________

                   IN THE SENATE OF THE UNITED STATES

           September 21 (legislative day, September 12), 1994

Mr. Reid submitted the following resolution; which was referred to the 
                     Committee on Foreign Relations

           September 27 (legislative day, September 12), 1994

             Committee discharged; considered and agreed to

_______________________________________________________________________

                               RESOLUTION

 
 To express the sense of the Senate condemning the cruel and tortuous 
                 practice of female genital mutilation.

Whereas the Senate recognizes the importance of traditions and ritual rites of 
        passage in the cultures of all nations;
Whereas such traditions and rites should not impede or violate the human rights 
        of any person;
Whereas the practice of female genital mutilation of girls and young women under 
        the age of 18 represents an act of cruelty and a basic violation of a 
        person's human rights;
Whereas the aftereffects of female genital mutilation include shock, infection, 
        psychological scarring, hemorrhaging, and death;
Whereas the practice of female genital mutilation represents a threat to the 
        health of girls and young women who undergo the procedure; and
Whereas the Government of Egypt should be commended for the recent arrest and 
        detention of 2 men who performed circumcision on a 10-year-old girl 
        while she was bound and arranged for the filming of the tortuous 
        procedure for the Cable News Network: Now, therefore, be it
    Resolved, That it is the sense of the Senate that the practice of 
female genital mutilation of girls and young women under the age of 18 
by any nation or individual is condemned, and that the Government of 
Egypt and that all other governments that aggressively and 
appropriately decry, prevent, and deter this practice through education 
and other means be, and they hereby are, commended by the United States 
Senate.
                                 <all>
```
THE THIRTEENTH COURT OF APPEALS

13-24-00215-CV

De Leon Aircraft Maintenance Professional and Christopher De Leon, individually

v.

Luis Gutierrez and Sergio Gutierrez

On Appeal from the

County Court at Law No. 9 of Hidalgo County, Texas

Trial Court Cause No. CL-19-5452-I

JUDGMENT

THE THIRTEENTH COURT OF APPEALS, having considered this cause on 

appeal, concludes the judgment of the trial court should be reversed and the cause 

remanded to the trial court. The Court orders the judgment of the trial court REVERSED 

and REMANDED for further proceedings consistent with its opinion. Costs of the appeal 

are adjudged against appellees.

We further order this decision certified below for observance.

July 31, 2024
# Exhibit 3

USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 1 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 2 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 3 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 4 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 5 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 6 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 7 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 8 of 12

# Enclosure A

USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 9 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 10 of 12

# Enclosure B

USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 11 of 12USCA Case #11-1131 Document #1330427 Filed: 09/19/2011 Page 12 of 12
| (logo) NTS NATIONAL

TAX SEARCH, LLC | 130 S. Jefferson, Suite 300

Chicago, IL 60661

312-233-6440 |
|--------------------------------------|--------------------------------------------------------------|

 

 

REPORT ON ASSESSMENT OF COMPLIANCE WITH APPLICABLESECURITIES AND EXCHANGE COMMISSION’S REGULATION AB SERVICING CRITERIA

 

 

For the calendar year ending December 31, 2016, National TaxSearch, LLC has been a Tax Service Vendor for **Wells Fargo Bank** (the“Servicer”).

 

National Tax Search, LLC (“NTS”) is responsible forassessing compliance as of December 31, 2016 and for the period from January 1,2016 through December 31, 2016 (the “Reporting Period”) with the servicingcriteria set forth in Title 17, Section 229.1122(d) of the Code of FederalRegulations (the “CFR”). NTS has used the servicing criteria communicated toNTS by the Servicer to assess compliance with the applicable servicingcriteria. Only servicing criteria 1122 (d) (l)(ii), 1122 (d)1(iv), 1122(d)2(ii), 1122 (d)2(v), 1122(d)2(vi), 1122(d)(4)(xi), and 1122(d)(4)(xii) (the“Applicable Servicing Criteria”) are applicable to the activities NTS performswith respect to the transactions covered by this report. NTS has determinedthat the remaining servicing criteria set forth in Item 1122 (d) of the SECRegulation AB are not applicable to the activities it performs with respect tothe transactions covered by this report. The transactions covered by thisreport include all tax payments made on behalf of the Servicer using NTS’s TaxQsystem (the “Platform Transactions”).

 

NTS, as a vendor, has assessed its compliance with theApplicable Servicing Criteria for the Reporting Period and has concluded thatNTS has complied, in all material respects, with the Applicable ServicingCriteria as of December 31, 2016 and for the Reporting Period with respect tothe Platform Transactions taken as a whole.

 

Plante & Moran, PLLC, an independent registered publicaccounting firm, has issued an attestation report on the assessment ofcompliance with the Applicable Servicing Criteria as of December 31, 2016 andfor the Reporting Period as set forth in this assertion.

 

National Tax Search, LLC, as Vendor to Servicer

 

 

/s/ Lori D. Eshoo

Lori D. Eshoo, President/CEO

January 23, 2017
#### § 20.6601-1 Interest on underpayment, nonpayment, or extensions of time for payment, of tax.

For regulations concerning interest on underpayments, etc., see § 301.6601-1 of this chapter (Regulations on Procedure and Administration).
## State of N ew York Su p reme C ou rt, A p p ellate Division Third J u dicial Dep artment Decided and Entered: July 2, 2015 519945

________________________________ In the Matter of JONATHAN RUSSO, Petitioner, v MEMORANDUM AND JUDGMENT ANTHONY J. ANNUCCI, as Acting Commissioner of Corrections and Community Supervision, Respondent.

________________________________ Calendar Date: May 5, 2015 Before: McCarthy, J.P., Garry, Rose and Devine, JJ.

__________ Jonathan Russo, New York City, petitioner pro se. Eric T. Schneiderman, Attorney General, Albany (Peter H. Schiff of counsel), for respondent.

__________ Proceeding pursuant to CPLR article 78 (transferred to this Court by order of the Supreme Court, entered in Albany County) to review a determination of respondent which found petitioner guilty of violating certain prison disciplinary rules. Following a tier III disciplinary hearing, petitioner was found guilty of assaulting staff, refusing a direct order, violent conduct, interfering with an employee and refusing a frisk procedure. According to the misbehavior report, petitioner was ordered to assume a pat-frisk position on the wall and, when a correction officer asked if he had something in his mouth, petitioner turned and punched the correction officer in the face. The determination of guilt was affirmed upon administrative appeal and this CPLR article 78 proceeding ensued.-2- 519945

We confirm. The detailed misbehavior report, together with various reports and corroborating testimony from other correction officers, provide substantial evidence to support the determination of guilt (see Matter of Sital v Fischer, 73 AD3d 1348, 1348 [2010], lv denied 15 NY3d 707 [2010]). Petitioner's remaining contentions, including that the Hearing Officer should have assessed his mental health status, are raised for the first time "and this Court 'ha[s] no discretionary authority or interest of justice jurisdiction' to review unpreserved issues in such special proceedings" (Matter of Reed v Artus, 39 AD3d 1056, 1057 [2007], quoting Matter of Khan v New York State Dept. of Health, 96 NY2d 879, 880 [2001]). McCarthy, J.P., Garry, Rose and Devine, JJ., concur.

ADJUDGED that the determination is confirmed, without costs, and petition dismissed.

ENTER:

Robert D. Mayberger Clerk of the Court
#### § 20.2206-1 Liability of life insurance beneficiaries.

With respect to the right of the district director to collect the tax without regard to the provisions of section 2206, see § 20.2205-1.
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<FISCAL-YEAR-END>                              DEC-31-1998
<PERIOD-START>                                 JAN-01-1998
<PERIOD-END>                                   MAR-31-1998
<EXCHANGE-RATE>                                1
<CASH>                                         1,547,088
<SECURITIES>                                   0
<RECEIVABLES>                                  1,350,307
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<TOTAL-ASSETS>                                 2,897,395
<CURRENT-LIABILITIES>                          420,200
<BONDS>                                        0
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</TABLE>
Document Headings

                    Document headings vary by document type but may contain                    the following:                  
                -                       the agency or agencies that issued and signed a document                    
                -                       the number of the CFR title and the number of each part                      the document amends, proposes to amend, or is directly                      related to                    
                -                       the agency docket number / agency internal file number                    
                -                       the RIN which identifies each regulatory action listed in                      the Unified Agenda of Federal Regulatory and Deregulatory                      Actions                    

                    See the                                          Document Drafting Handbook                                        for more details.                  

###### Department of the Interior

###### Bureau of Land Management

          - [AA-9346, AA-9353, AA-9361, AA-9379, AA-9880; LLAK-962000-L14100000-HY0000-P]

# AGENCY:

Bureau of Land Management, Interior.

# ACTION:

Notice of decision approving lands for conveyance.

# SUMMARY:

As required by 43 CFR 2650.7(d), notice is hereby given that an appealable decision approving the conveyance of surface and subsurface estates for certain lands pursuant to the Alaska Native Claims Settlement Act will be issued to Calista Corporation for 30.48 acres located southeasterly of the Native village of Emmonak, Alaska. Notice of the decision will also be published four times in the Anchorage Daily News.

# DATES:

The time limits for filing an appeal are:

1. Any party claiming a property interest which is adversely affected by the decision shall have until September 4, 2009 to file an appeal.

2. Parties receiving service of the decision by certified mail shall have 30 days from the date of receipt to file an appeal.

Parties who do not file an appeal in accordance with the requirements of 43 CFR Part 4, Subpart E, shall be deemed to have waived their rights.

# ADDRESSES:

A copy of the decision may be obtained from:

Bureau of Land Management, Alaska State Office, 222 West Seventh Avenue, #13, Anchorage, Alaska 99513-7504.

# FOR FURTHER INFORMATION CONTACT:

                        The Bureau of Land Management by phone at 907-271-5960, or by e-mail at                         *ak.blm.conveyance@ak.blm.gov.*                         Persons who use a telecommunication device (TTD) may call the Federal Information Relay Service (FIRS) at 1-800-877-8330, 24 hours a day, seven days a week, to contact the Bureau of Land Management.                    

Dina L. Torres,

Land Transfer Resolution Specialist, Resolution Branch.

[FR Doc. E9-18714 Filed 8-4-09; 8:45 am]

BILLING CODE 4310-JA-P
§ 1.678(a)-1 Person other than grantor treated as substantial owner; general rule. ( a ) Where a person other than the grantor of a trust has a power exercisable solely by himself to vest the corpus or the income of any portion of a testamentary or inter vivos trust in himself, he is treated under section 678(a) as the owner of that portion, except as provided in section 678(b) (involving taxation of the grantor) and section 678(c) (involving and obligation of support). The holder of such a power also is treated as an owner of the trust even though he has partially released or otherwise modified the power so that he can no longer vest the corpus or income in himself, if he has retained such control of the trust as would, if retained by a grantor, subject the grantor to treatment as the owner under sections 671 to 677, inclusive. See section 671 and §§ 1.671-2 and 1.671-3 for rules for treatment of items of income, deduction, and credit where a person is treated as the owner of all or only a portion of a trust.
( b ) Section 678(a) treats a person as an owner of a trust if he has a power exercisable solely by himself to apply the income or corpus for the satisfaction of his legal obligations, other than an obligation to support a dependent (see § 1.678(c)-1 subject to the limitation of section 678(b). Section 678 does not apply if the power is not exercisable solely by himself. However, see § 1.662(a)-4 for principles applicable to income of a trust which, pursuant to the terms of the trust instrument, is used to satisfy the obligations of a person other than the grantor.