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

###### Internal Revenue Service 

# AGENCY:

Internal Revenue Service (IRS), Treasury. 

# ACTION:

Notice of meeting.

# SUMMARY:

                        An open meeting of the Taxpayer Advocacy Panel Notice Improvement Issue Committee will be                               ( print page 39379)                            conducted. The Taxpayer Advocacy Panel is soliciting public comments, ideas and suggestions on improving customer service at the Internal Revenue Service.                     

# DATES:

The meeting will be held Thursday, September 10, 2009. 

# FOR FURTHER INFORMATION CONTACT:

Sallie Chavez at 1-888-912-1227, or 954-423-7979. 

# SUPPLEMENTARY INFORMATION:

Notice is hereby given pursuant to section 10(a)(2) of the Federal 

                    Advisory Committee Act, 5 U.S.C. App. (1988) that an open meeting of the Taxpayer Advocacy Panel Notice Improvement Issue Committee will be held Thursday, September 10, 2009, at 2 p.m. Eastern Time via telephone conference. The public is invited to make oral comments or submit written statements for consideration. Due to limited conference lines, notification of intent to participate must be made with Sallie Chavez. For more information please contact Ms. Chavez at 1-888-912-1227 or 954-423-7979, or write TAP Office, 1000 South Pine Island Road, Suite 340, Plantation, FL 33324, or post comments to the Web site:                     *http://www.improveirs.org.*

The agenda will include various IRS issues. 

                        Dated:                         *July 30, 2009.*

Shawn F. Collins, 

Acting Director, Taxpayer Advocacy Panel.

[FR Doc. E9-18781 Filed 8-5-09; 8:45 am] 

BILLING CODE 4830-01-P
§ 25.2513-3 Revocation of consent. ( a ) ( 1 ) With respect to gifts made after December 31, 1981, or before January 1, 1971, if the consent to the application of the provisions of section 2513 for a calendar year was effectively signified on or before the 15th day of April following the close of the calendar year, either spouse may revoke the consent by filing in duplicate a signed statement of revocation, but only if the statement is filed on or before such 15th day of April. Therefore, a consent that was not effectively signified until after the 15th day of April following the close of the calendar year to which it applies may not be revoked.
( 2 ) With respect to gifts made after December 31, 1970, and before January 1, 1982, if the consent to the application of the provisions of section 2513 for a calendar quarter was effectively signified on or before the 15th day of the second month following the close of such calendar quarter, either spouse may revoke the consent by filing in duplicate a signed statement of revocation, but only if the statement is filed on or before such 15th day of the second month following the close of such calendar quarter. Therefore, a consent that was not effectively signified until after the 15th day of the second month following the close of the calendar quarter to which it applies may not be revoked.
( b ) Except as provided in paragraph (b) of § 301.6091-1 of this chapter (relating to hand-carried documents), the statement referred to in paragraph (a) of this section shall be filed with the internal revenue officer with whom the gift tax return is required to be filed, or with whom the gift tax return would be required to be filed if a return were required.
[T.D. 7238, 37 FR 28730, Dec. 29, 1972, as amended by T.D. 7910, 48 FR 40375, Sept. 7, 1983]
EX-10.67



 





EXHIBIT 10.67




AMENDMENT NO. 2

TO

THE NORTH AMERICAN COAL CORPORATION

VALUE APPRECIATION PLAN FOR YEARS 2000 TO 2009

(AS AMENDED AND RESTATED AS OF JANUARY 1, 2005)




     The Compensation Committee of the Board of Directors of The North American Coal Corporation
(the “Company”), hereby adopts this Amendment No. 2 to The North American Coal Corporation Value
Appreciation Plan for Years 2000 to 2009 (the “Plan”), effective as of January 1, 2000. Words and
phrases used herein with initial capital letters that are defined in the Plan are used herein as so
defined.



Section 1




     The first sentence of Section 5.2(a) of the Plan is hereby amended in its entirety to read as
follows:



     “Each Participant’s interest in his VAP Account under this Plan shall vest at the rate of 20
percent for each year during which a Participant remains in the continuous employ of the Company or
a Subsidiary following the January 1st of the year in which a Participant is first
credited with a VAP Target Amount under the Plan; provided however, that a Participant’s interest
in his VAP Account shall become immediately 100 percent vested in the event (i) of such
Participant’s death or Disability while employed by the Company or a Subsidiary; (ii) such
Participant remains in the continuous employ of the Company or a Subsidiary through December 31,
2015 or (iii) of such Participant’s termination of employment with the Company or a Subsidiary at
or after age 55 with at least 10 years of service or at or after age 65 (i.e., retirement).”






1
#### Dominic J. Carilli *v.*Pension Commission of the City of Hartford

Decided May 20, 1964

It is ordered that the parties in the above entitled action appear by their counsel before the Supreme Court of Errors on June 2, 1964, at 10 a.m., then and there to show cause why the reservation should be entertained.
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.

§ 301.6316-1 Payment of income tax in foreign currency. Subject to the provisions of §§ 301.6316-3 to 301.6316-5, inclusive, that portion of the income tax which is attributable to amounts received by a citizen of the United States in nonconvertible foreign currency may be paid in such currency— ( a ) For any taxable year beginning on or after January 1, 1955, and before January 1, 1964, if such amounts— ( 1 ) Are disbursed from funds made available to a foundation or commission established in a foreign country pursuant to an agreement made under the authority of section 32(b) of the Surplus Property Act of 1944, as amended (50 U.S.C. App. 1641(b)(2)), or reestablished under the authority of the Mutual Educational and Cultural Exchange Act of 1961, as amended (22 U.S.C. 2451);
( 2 ) Constitute either a grant made for authorized purposes of the agreement or compensation for personal services performed in the employ of the foundation or commission;
( 3 ) Are at least 75 percent of the entire amount of the grant or compensation; and
( 4 ) Are treated as income from sources without the United States under the provisions of sections 861 to 864, inclusive, and §§ 1.861-1 to 1.864, inclusive, of this chapter (Income Tax Regulations); and
( b ) For any taxable year beginning on or after January 1, 1964, if such amounts— ( 1 ) Are disbursed from funds made available either to a foundation or commission, established pursuant to an agreement made under the authority of section 32(b) of the Surplus Property Act of 1944, as amended, or to a foundation or commission established or continued pursuant to an agreement made under the authority of the Mutual Educational and Cultural Exchange Act of 1961, as amended; or are paid from grants made to such citizen, or to a foundation or an educational or other institution, under the authority of the Mutual Educational and Cultural Exchange Act of 1961, as amended, or section 104 (h), (j), (k), (o), or (p) of the Agricultural Trade Development and Assistance Act of 1954, as amended (7 U.S.C. 1704 (h), (j), (k), (o), (p));
( 2 ) Constitute either a grant made for a purpose authorized under any such agreement or law, or compensation for personal services performed in the employ of any organization engaged in administering any program or activity pursuant to any such agreement or law;
( 3 ) Are at least 70 percent of the entire amount of the grant or compensation; and
( 4 ) Are treated as income from sources without the United States under the provisions of sections 861 to 864, inclusive, and §§ 1.861-1 to 1.864, inclusive, of this chapter (Income Tax Regulations).
§ 31.3132-1 Recapture of credits. ( a ) *Recapture of erroneously refunded credits.* Any amount of credits for qualified family leave wages under section 3132, including any increase to the amount of the credits under sections 3132(d), 3132(e), and 3133, that are treated as overpayments and refunded or credited to an employer under section 6402(a) or 6413(b) and to which the employer is not entitled, resulting in an erroneous refund to the employer, shall be treated as an underpayment of the taxes imposed under section 3111(b) and so much of the taxes imposed under section 3221(a) as are attributable to the rate in effect under section 3111(b), as applicable, and may be assessed and collected by the Secretary in the same manner as the taxes.
( b ) *Advance credit amounts erroneously refunded.* The determination of any amount of credits erroneously refunded as described in paragraph (a) of this section must take into account any amount of credits advanced to an employer under the process established by the Internal Revenue Service in accordance with section 3132(b)(3)(B) and 3132(g)(6).
( c ) *Third party payors.* For purposes of this section, employers against whom an erroneous refund of the credits under section 3132 (including any increases in those credits under section 3133) can be assessed as an underpayment of the taxes imposed under section 3111(b) and so much of the taxes imposed under section 3221(a) as are attributable to the rate in effect under section 3111(b), as applicable, include persons treated as the employer under sections 3401(d), 3504, and 3511, consistent with their liability for the section 3111(b) or 3221(a) taxes against which the credit applied, and also include those persons' common law employer clients that remain subject to all provisions of law applicable to employers with respect to the payment of wages or compensation, as applicable.
( d ) *Applicability date.* This section applies to all credit refunds under section 3132 (including any increases in those credits under section 3133) advanced or paid on or after September 8, 2021.
[T.D. 9978, 88 FR 48124, July 26, 2023]
§ 20.2056A-10 Surviving spouse becomes citizen after QDOT established. ( a ) *Section 2056A estate tax no longer imposed under certain circumstances.* Section 2056A(b)(12) provides that a QDOT is no longer subject to the imposition of the section 2056A estate tax if the surviving spouse becomes a citizen of the United States and the following conditions are satisfied— ( 1 ) The spouse either was a United States resident (for the definition of resident for this purpose, see § 20.2056A-1(b)) at all times after the death of the decedent and before becoming a United States citizen, or no taxable distributions are made from the QDOT before the spouse becomes a United States citizen (regardless of the residency status of the spouse); and
( 2 ) The U.S. Trustee(s) of the QDOT notifies the Internal Revenue Service and certifies in writing that the surviving spouse has become a United States citizen. Notice is to be made by filing a final Form 706-QDT on or before April 15th of the calendar year following the year in which the surviving spouse becomes a United States citizen, unless an extension of time for filing is granted under section 6081.
( b ) *Special election by spouse.* If the surviving spouse becomes a United States citizen and the spouse is not a United States resident at all times after the death of the decedent and before becoming a United States citizen, and a tax was previously imposed under section 2056A(b)(1)(A) with respect to any distribution from the QDOT before the surviving spouse becomes a United States citizen, the estate tax imposed under section 2056A(b)(1) does not apply to distributions after the spouse becomes a citizen if— ( 1 ) The spouse elects to treat any taxable distribution from the QDOT prior to the spouse's election as a taxable gift made by the spouse for purposes of section 2001(b)(1)(B) (referring to adjusted taxable gifts), and for purposes of determining the amount of the tax imposed by section 2501 on actual taxable gifts made by the spouse during the year in which the spouse becomes a citizen or in any subsequent year;
( 2 ) The spouse elects to treat any previous reduction in the section 2056A estate tax by reason of the decedent's unified credit (under either section 2010 or section 2102(c)) as a reduction in the spouse's unified credit under section 2505 for purposes of determining the amount of the credit allowable with respect to taxable gifts made by the surviving spouse during the taxable year in which the spouse becomes a citizen, or in any subsequent year; and
( 3 ) The elections referred to in this paragraph (b) are made by timely filing a Form 706-QDT on or before April 15th of the year following the year in which the surviving spouse becomes a citizen (unless an extension of time for filing is granted under section 6081) and attaching notification of the election to the return.
[T.D. 8612, 60 FR 43550, Aug. 22, 1995]
UNPUBLISHED

UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

No. 21-2319

STARSHA M. SEWELL,

Plaintiff - Appellant,

v.

WESTAT, INC.,

Defendant - Appellee.

Appeal from the United States District Court for the District of Maryland, at Greenbelt. 

Timothy J. Sullivan, Magistrate Judge. (8:20-cv-01895-TJS)

Submitted: March 29, 2022 Decided: March 31, 2022

Before HARRIS, QUATTLEBAUM, and HEYTENS, Circuit Judges.

Affirmed by unpublished per curiam opinion.

Starsha M. Sewell, Appellant Pro Se. Thomas Strong, VENABLE, LLP, Baltimore, 

Maryland, for Appellee.

Unpublished opinions are not binding precedent in this circuit.
2

PER CURIAM:

Starsha M. Sewell appeals the magistrate judge’s order dismissing on res judicata 

grounds the civil action Sewell filed in June 2020.*

 On appeal, we confine our review to 

the issues raised in the informal brief. See 4th Cir. R. 34(b). Because Sewell’s informal 

brief does not challenge the basis for the magistrate judge’s disposition, she has forfeited 

appellate review of the appealed-from order. See Jackson v. Lightsey, 775 F.3d 170, 177 

(4th Cir. 2014) (“The informal brief is an important document; under Fourth Circuit rules, 

our review is limited to issues preserved in that brief.”). Accordingly, we affirm the 

magistrate judge’s order. We dispense with oral argument because the facts and legal 

contentions are adequately presented in the materials before this court and argument would 

not aid the decisional process.

AFFIRMED

* The parties consented to the exercise of jurisdiction by the magistrate judge. 28 

U.S.C. § 636(c).
#### UNITED STATES of America, Appellee, v. James Brian WRIGHT, Appellant.

No. 01-3813.

United States Court of Appeals, Eighth Circuit.

Submitted May 27, 2002.

Decided June 7, 2002.

Before McMILLIAN, MORRIS SHEPPARD ARNOLD, and BYE, Circuit Judges.

PER CURIAM.

James Brian Wright, who originally pleaded guilty to impersonating a federal officer, appeals the sentence of 8 months imprisonment and 6 months supervised release imposed upon revocation of his original supervised release term. Mr. Wright’s original offense of conviction — carrying a maximum prison term of 3 years, *see*18 U.S.C. § 912 — constituted a Class E felony, *see*18 U.S.C. § 3559(a)(5). Thus, we conclude that the 8-month prison sentence was proper. *See*18 U.S.C. § 3583(e)(3) (authorizing not more than 1 year imprisonment upon revocation of supervised release if offense that resulted in term of supervised release was other than Class A, B, C, or D felony). The 6-month supervised release sentence was unauthorized, however, to the extent that, when combined with the 8-month prison sentence, it exceeded 1 year. *See*18 U.S.C. § 3583(b)(3) (authorizing not more than 1 year supervised release for Class E felony), (h) (when supervised release is revoked and defendant is required to serve term of imprisonment that is less than maximum term of imprisonment authorized under subsection (e)(3), court may require that defendant be placed on term of supervised release after imprisonment, length of which shall not exceed term of supervised release authorized by statute for offense that resulted in original term of supervised release, less any term of imprisonment that was imposed upon revocation).

Accordingly, we vacate the sentence and remand for resentencing with instructions for the district court to reduce the supervised release term to no more than 4 months, and we affirm in all other respects. *See United States v. Guzman-Bruno,*27 F.3d 420, 423 (9th Cir.) (vacating sentence and remanding to district court for limited purpose of setting term of supervised release within statutorily permitted range, because term imposed exceeded statutorily authorized term and constituted plain error), *cert. denied,*513 U.S. 975, 115 S.Ct. 451, 130 L.Ed.2d 360 (1994). We grant counsel’s motion to withdraw.
## Checklist use by Front D oor P hoto's is recomemded by DJI for the

Phantom 2 and the Inspire 1.

Preflight Checklist for the DJI Phantom 2 Vision: Preflight Checklist 1) Remote Controller, smart battery, Range Extender, and s martphone are fully charged

. 2) Propellers are mounted correctly. 3) Gimbal clamp has been removed. 4) Damping absorbers are in good condition, not broken, or worn. 5) Anti

- Drop kits have been mounted correctly. 6) Camera lens cap has been removed. 7) Micro

-SD card has been inserted if necessary. 8) Gimba l is functioning as normal. 9) Motors can start and are functioning as normal 10) DJI VISION App can connect to the camera.



## Preflight Checklist for the Inspire 1: Preflight Checklist 1) Check that all parts are in good condition. Do not fly with aging or damaged parts. 2) Remote controller, intelligent Flight Battery and mobile device are all fully charged. 3) Propellers are mounted correctly and secure. 4) Lens is clear. 5) Micro

-SD card has been inserted, it necessary. 6) Gimbal is functioning as normal. 7) Gimbal is correctly attached to the aircraft. 8) Motors can start and are functioning as normal. 9) The DJI Pilot app can connect to the camera and all firmware has been updated to the latest version.
###### 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.

#### § 301.7424-2 Intervention.

If the United States is not a party to a civil action or suit, the United States may intervene in such action or suit to assert any lien arising under title 26 of the United States Code on the property which is the subject of such action or suit. The provisions of section 2410 of title 28 of the United States Code (except subsection (b)) and of section 1444 of title 28 of the United States Code shall apply in any case in which the United States intervenes as if the United States had originally been named a defendant in such action or suit. If the application of the United States to intervene is denied, the adjudication in such civil action or suit shall have no effect upon such lien.

[T.D. 7305, 39 FR 9951, Mar. 15, 1974]
Exhibit 32.2



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 of Covalent Group, Inc. (the Company) on Form 10-Q for the period ending March 31, 2005 as filed with the Securities
and Exchange Commission on the date hereof (the Report), I, Lawrence R. Hoffman, Executive Vice President, General Counsel and Chief Financial Officer of the Company, certify, pursuant to 18 U.S.C. § 1350, as adopted pursuant to
§ 906 of the Sarbanes-Oxley Act of 2002, that:



(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/ Lawrence R. Hoffman                                                                             
|Lawrence R. Hoffman Executive Vice President, General Counsel, Secretary and Chief Financial Officer



May 16, 2005



The foregoing certification is being furnished solely pursuant to Section 906 of the
Sarbanes-Oxley Act of 2002 (Section 1350 of Chapter 63 of Title 18 of the United States Code) and is not being filed as part of the Report or as a separate disclosure document.
Amendment To Duke Energy Corp Executive Cash Balance Plan



 Exhibit 10.18.5 
  
 AMENDMENT TO 
 DUKE ENERGY CORPORATION 
 EXECUTIVE CASH BALANCE PLAN 
  
 The Duke Energy Corporation Executive Cash Balance Plan (the “Plan”) is amended, effective as of December 1, 2006, as follows: 

	 	1.	Section 2.16 of the Duke Energy Corporation Executive Cash Balance Plan I is hereby superseded and replaced in its entirety as set forth below: 

 “2.16 “Retirement Cash Balance Plan” means the Duke Energy Retirement Cash Balance Plan as in effect on October 3, 2004, without giving effect
to amendments adopted thereafter.” 

	 	2.	The last sentence of Section 4.4 of the Duke Energy Corporation Executive Cash Balance Plan II is hereby deleted in its entirety. 


	 	3.	The first two sentences of Section 6.1 of the Duke Energy Corporation Executive Cash Balance Plan II are hereby deleted and replaced in their entirety with the following:


 “A Participant whose Company employment terminates on or after December 31, 2006 will receive, or will begin to receive,
payment of his vested Make Whole Account and his vested Supplemental Account, if any, as soon as administratively feasible following the month in which the Participant’s employment terminates.” 

	 	4.	Except as explicitly set forth herein, the Plan will remain in full force and effect. 

 This amendment has been approved and signed by an authorized officer of Duke Energy Corporation as of the date specified above. 
  

			
	DUKE ENERGY CORPORATION
		
	 By:
	 	 /S/    CHRISTOPHER C.
ROLFE        

		 	Christopher C. Rolfe
		 	Group Executive and Chief
		 	Administrative Officer