alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
The Honorable Juan Vasquez, Judge, United States Tax Court. 1

United States Court of Appeals

FOR THE EIGHTH CIRCUIT

___________

No. 96-4213

___________

Richard K. McGirl and *

Christine M. McGirl, *

*

Appellants, *

* Appeal from the

v. * United States Tax Court

*

Commissioner of Internal * [UNPUBLISHED]

Revenue, *

*

Appellee. *

___________

 Submitted: October 23, 1997

 Filed: November 28, 1997

___________

Before McMILLIAN, FLOYD R. GIBSON and BEAM, Circuit Judges.

___________

PER CURIAM.

Richard K. McGirl and Christine M. McGirl (“appellants”) appeal from

the United States Tax Court’s decision upholding the Commissioner of

1

Internal Revenue’s determination that appellants’ unreported income for the

1989, 1990, and 1991 tax years should not be reduced by the amount of loans

that appellants maintain they
-2-

obtained from a third party; that appellants failed to prove that their

sandwich shop business incurred expenses in excess of those claimed on its

1989, 1990, and 1991 tax returns; and that the underreporting of the

business’s income for those years was due, in part, to fraudulent intent

on the part of Richard K. McGirl. McGirl v. Commissioner, No. 11510-94,

1996 WL 385813 (T.C. July 11, 1996) (memorandum and order). 

Jurisdiction was proper in the tax court based upon Section 6213 of

the Internal Revenue Code (“I.R.C.”). Jurisdiction on appeal is proper

based upon I.R.C. § 7482(a) (1994). The notice of appeal was timely filed

under Rule 13(a) of the Federal Rules of Appellate Procedure. 

The tax court held that appellants failed to meet their burden of

showing that they are entitled to additional deductions and that the

Commissioner’s determination of gross income is incorrect. Slip op. at 14-

15, 23-24. Specifically, the tax court found it “improbable and

unconvincing” that appellants received loans in the amounts that they

sought to characterize as nonincome or incurred business expenses which

were not reflected on the business’s 1989, 1990, and 1991 tax returns. Id.

at 20. Moreover, the tax court held that the Commissioner proved by clear

and convincing evidence that at least some part of appellants’

underpayments were attributable to fraud on the part of Richard K. McGirl.

Id. at 35. 

Having carefully reviewed the record, the parties’ briefs, and the

well-reasoned analysis of the tax court, we conclude that no error of law

or fact appears and that an opinion would lack precedential value. See 8th

Cir. R. 47B. Accordingly, we affirm the judgment of the tax court.

A true copy.

Attest:

 CLERK, U.S. COURT OF APPEALS, EIGHTH CIRCUIT.
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_______________________________________ __ Michigan Supreme Court 

# Order

Lansing, Michigan

January 8, 2008 Clifford W. Taylor, Chief Justice

Michael F. Cavanagh
Elizabeth A. Weaver 135130 Marilyn Kelly Maura D. Corrigan Robert P. Young, Jr. Stephen J. Markman, PEOPLE OF THE STATE OF MICHIGAN, Justices Plaintiff-Appellee,

v SC: 135130 COA: 279440 Saginaw CC: 00-018711-FC STEVENSON DEMONT BELL, Defendant-Appellant.

________________ _______________ __________/

On order of the Court, the application for leave to appeal the September 6, 2007 order of the Court of Appeals is consider ed, and it is DENIED, because we are not persuaded that the questions presented should be reviewed by this Court.

d1217 I, Corbin R. Davis, Clerk of the Mi chigan Supreme Cour t, certify that the foregoing is a true and complete copy of the order entered at the direction of the Court.

January 8, 2008

Clerk
IIB 

113TH CONGRESS 

2D SESSION H. R. 5106 

IN THE SENATE OF THE UNITED STATES 

SEPTEMBER 9, 2014 

Received; read twice and referred to the Committee on Homeland Security and 

Governmental Affairs 

AN ACT 

To designate the facility of the United States Postal Service 

located at 100 Admiral Callaghan Lane in Vallejo, California, as the ‘‘Philmore Graham Post Office Building’’. 

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


SSpencer on DSK3TPTVN1PROD with BILLS
2 

HR 5106 RFS

1 SECTION 1. PHILMORE GRAHAM POST OFFICE BUILDING. 

2 (a) DESIGNATION.—The facility of the United States 

3 Postal Service located at 100 Admiral Callaghan Lane in 

4 Vallejo, California, shall be known and designated as the 

5 ‘‘Philmore Graham Post Office Building’’. 

6 (b) REFERENCES.—Any reference in a law, map, reg7 ulation, document, paper, or other record of the United 

8 States to the facility referred to in subsection (a) shall 

9 be deemed to be a reference to the ‘‘Philmore Graham 

10 Post Office Building’’. 

Passed the House of Representatives September 8, 

2014. 

Attest: KAREN L. HAAS, 

Clerk. 


SSpencer on DSK3TPTVN1PROD with BILLS
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UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

- and -

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

CERTIFICATE OF SERVICE 

I, Alain B. Francoeur, do declare and state as follows: 

1. I am employed at Prime Clerk LLC (“Prime Clerk”), the claims and noticing agent

for the debtors in the above-referenced chapter 11 bankruptcy cases.

2. On April 25, 2019, at my direction and under my supervision, employees of Prime

Clerk caused the following documents to be served via First Class Mail on the Court Service List 

attached hereto as Exhibit A:

 Order Authorizing Centerview Partners LLC to File Certain Confidential Information

Under Seal in Connection with the Applications of the Official Committee of

Unsecured Creditors for Authority to Retain and Employ Centerview as Investment

Banker [Docket No. 1661]

 Order Granting Application for Admission of Attorney Pro Hac Vice

[Docket No. 1692]

 Order Granting Application for Admission of Attorney Pro Hac Vice

[Docket No. 1694]

Case: 19-30088 Doc# 1768 Filed: 04/30/19 Entered: 04/30/19 13:10:58 Page 1 of

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3. I declare under penalty of perjury under the laws of the United States of America, that

the foregoing is true and correct and that if called upon as a witness, I could and would competently 

testify thereto. 

Executed this 30th day of April 2019, at New York, NY. 

Alain B. Francoeur 

SRF 32534

Case: 19-30088 Doc# 1768 Filed: 04/30/19 Entered: 04/30/19 13:10:58 Page 2 of

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Exhibit A 

Case: 19-30088 Doc# 1768 Filed: 04/30/19 Entered: 04/30/19 13:10:58 Page 3 of

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Exhibit A

Court Service List

Served via First Class Mail

NAME ADDRESS 1 ADDRESS 2 ADDRESS 3 

Federal Energy Regulatory Commission Attn: General Counsel 888 First St NE Internal Revenue Service Centralized Insolvency Operation 2970 Market St John A. Vos 1430 Lincoln Avenue Office of the United States Attorney for the Northern District of California Attn: Bankruptcy Unit Federal Courthouse 450 Golden Gate AvePG&E Corporation Attn: President or General Counsel 77 Beale Street P.O. Box 77000 Placer County Office Of The Treasurer-Tax Collector Attn: Robert Kanngiesser 2976 Richardson Drive U.S. Nuclear Regulatory Commission Attn: General Counsel U.S. NRC Region IV 1600 E. Lamar Blvd. 

In re: PG&E Corporation, et al.

Case No. 19‐30088 (DM) Page 1 of 1

Case: 19-30088 Doc# 1768 Filed: 04/30/19 Entered: 04/30/19 13:10:58 Page 

4
#### Henry J. Anderson, as Receiver, etc., Respondent, v. Gates Sherwood and another, Appellants.

Order affirmed, without costs. Opinion by

Bradley, J.
[Federal Register Volume 75, Number 104 (Tuesday, June 1, 2010)]
[Notices]
[Page 30416]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-13030]


-----------------------------------------------------------------------

DEPARTMENT OF HOMELAND SECURITY

Federal Emergency Management Agency

[Internal Agency Docket No. FEMA-1915-DR; Docket ID FEMA-2010-0002]


South Dakota; Amendment No. 1 to Notice of a Major Disaster 
Declaration

AGENCY: Federal Emergency Management Agency, DHS.

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: This notice amends the notice of a major disaster declaration 
for the State of South Dakota (FEMA-1915-DR), dated May 13, 2010, and 
related determinations.

DATES: Effective Date: May 24, 2010.

FOR FURTHER INFORMATION CONTACT: Peggy Miller, Recovery Directorate, 
Federal Emergency Management Agency, 500 C Street, SW., Washington, DC 
20472, (202) 646-3886.

SUPPLEMENTARY INFORMATION: The notice of a major disaster declaration 
for the State of South Dakota is hereby amended to include the 
following area among those areas determined to have been adversely 
affected by the event declared a major disaster by the President in his 
declaration of May 13, 2010.

Moody County for Public Assistance.
(The following Catalog of Federal Domestic Assistance Numbers (CFDA) 
are to be used for reporting and drawing funds: 97.030, Community 
Disaster Loans; 97.031, Cora Brown Fund; 97.032, Crisis Counseling; 
97.033, Disaster Legal Services; 97.034, Disaster Unemployment 
Assistance (DUA); 97.046, Fire Management Assistance Grant; 97.048, 
Disaster Housing Assistance to Individuals and Households In 
Presidentially Declared Disaster Areas; 97.049, Presidentially 
Declared Disaster Assistance--Disaster Housing Operations for 
Individuals and Households; 97.050 Presidentially Declared Disaster 
Assistance to Individuals and Households--Other Needs; 97.036, 
Disaster Grants--Public Assistance (Presidentially Declared 
Disasters); 97.039, Hazard Mitigation Grant.)

W. Craig Fugate,
Administrator, Federal Emergency Management Agency.
[FR Doc. 2010-13030 Filed 5-28-10; 8:45 am]
BILLING CODE 9111-23-P
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EXHIBIT B 

COMPENSATION BY CATEGORY FOR SERVICES RENDERED 

BY DELOITTE & TOUCHE LLP FOR THE PERIOD 

JANUARY 29, 2019 THROUGH MAY 31, 2019 

Categories Hours Fees 

2018 NDT Audit Services 88.6 $19,031.00 

2019 Audit Services 1,423.1 $340,092.00 

Accounting Consultations 8.8 $6,688.00 

California Wildfires 29.7 $20,963.00 

New Accounting Standards 91.9 $35,363.00 

Non-Working Travel 16.0 $5,495.00 

Other Audit-Related Services 97.6 $29,122.00 

Other Outside of Engagement Scope 20.4 $11,307.00 

Post Bankruptcy Matters 331.5 $193,539.00 

Preparation of Fee Applications 24.0 $4,800.00 

Fees Category Subtotal : 2,131.6 $666,400.00 

Case: 19-30088 Doc# 4156-2 Filed: 10/07/19 Entered: 10/07/19 16:14:43 Page 1

of 1
**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 Amended Quarterly Report of All State Properties Holdings, Inc. (the "Company") on Form 10-Q/A for the three months ended March 31, 2019 as filed with the Securities and Exchange Commission on the date hereof (the "report"), I, Joseph C. Passalaqua, Principal Executive Officer of the Company, certify, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 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 this Report fairly presents, in all material respects, the financial condition and results of operations of the Company. 

 

Dated this 14th day of May 2020.

 

s/Joseph C. Passalaqua

Joseph C. Passalaqua

Certification of Principal Financial Officer

 

A signed original of this written statement required by Section 906 of the Sarbanes-Oxley Act of 2002 ("Section 906"), or other document authenticating, acknowledging, or otherwise adopting the signature that appears in typed form within the electronic version of this written statement required by Section 906, has been provided to All State Properties Holdings, Inc., and will be retained All State Properties Holdings, Inc. and furnished to the Securities and Exchange Commission or its staff upon request.
48503/0814

553253 1 Case No. 19-30088-DM

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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000

SAN FRANCISCO, CA 

94111

UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC GAS & ELECTRIC COMPANY,

Debtors,

☐Affects PG&E Corporation

☐Affects Pacific Gas and Electric Company

☒Affects both Debtors

All papers shall be filed in the Lead Case, 

No. 19-30088 (DM)

Case No.: 19-30088-DM

Chapter 11

CERTIFICATE OF SERVICE 

DATE: August 14, 2019

TIME: 9:30 am

PLACE: Courtroom 17

450 Golden Gate Avenue, 16th Fl.

San Francisco, California

JUDGE: Hon. Dennis Montali

RELATED DOCKET NO: 3091

I, Violet Rajkumar, do declare and state as follows:

I am employed in San Francisco in the State of California. I am more than eighteen years old 

and not a party to this action. My business address is Greene Radovsky Maloney Share & Hennigh 

LLP, One Front Street, 32nd Floor, San Francisco, California 94111-4106.

1. I certify that on August 7, 2019, I caused a true and correct copy of each of the 

EDWARD J. TREDINNICK (#84033)

GREENE RADOVSKY MALONEY 

 SHARE & HENNIGH LLP

One Front Street, 32nd Floor

San Francisco, California 94111

Telephone: (415) 981-1400

Facsimile: (415) 777-4961

E-mail: etredinnick@greeneradovsky.com

Attorneys for Creditor,

City and County of San Francisco

Case: 19-30088 Doc# 3413 Filed: 08/07/19 Entered: 08/07/19 13:21:40 Page 1 of

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48503/0814

553253 2 Case No. 19-30088-DM

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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000

SAN FRANCISCO, CA 

94111

following documents to be served via e-mail on the Standard Party Email Service List attached hereto 

as Exhibit A.

OBJECTION OF THE CITY AND COUNTY OF SAN FRANCISCO TO DEBTORS’ 

MOTION PURSUANT TO 11 USC §§105(a) AND 502(c) FOR ESTABLISHMENT 

OF WILDFIRE CLAIMS ESTIMATION PROCEDURES.

2. A true and correct copy of the each of the above documents to be served via First Class 

Mail to the parties on the Standard Parties Service List attached hereto as Exhibit B.

3. I certify that on August 7, 2019, I caused a true and correct copy of each of the above 

documents to be served via Email to the parties on the Core/2002 Email Service List attached hereto 

as Exhibit C.

4. I certify that on August 7, 2019, I caused a true and correct copy of each of the above 

documents to be served via First-Class Mail to the parties on the Core/2002 First-Class Mail Service 

List attached hereto as Exhibit D.

I declare under penalty of perjury under the laws of the United States of America, that 

the foregoing is true and correct and that if called upon as a witness, I could and would testify thereto.

Executed on August 7, 2019, at San Francisco, California.

/s/ Violet Rajkumar

Violet Rajkumar

Case: 19-30088 Doc# 3413 Filed: 08/07/19 Entered: 08/07/19 13:21:40 Page 2 of

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**Exhibit 31.1**

**Certificationof the Chief Executive Officer****Pursuant to****Rules 13a-14(a) and 15d-14(a) underthe Exchange Act**

I,Paul Pluschkell, certify that:

1.    I have reviewed this quarterly report on Form 10-Qof HyperFeed Technologies, Inc.;

2.    Based on my knowledge, this report does notcontain any untrue statement of a material fact or omit to state a materialfact necessary to make the statements made, in light of the circumstances underwhich such statements were made, not misleading with respect to the periodcovered by this report;

3.    Based on my knowledge, the financialstatements, and other financial information included in this report, fairlypresent in all material respects the financial condition, results of operationsand cash flows of the registrant as of, and for, the periods presented in thisreport;

4.    The registrant’s other certifying officerand I are responsible for establishing and maintaining disclosure controls andprocedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e))for the registrant and have:

(a)          designed such disclosure controls andprocedures, or caused such disclosure controls and procedures to be designedunder our supervision, to ensure that material information relating to theregistrant, including its consolidated subsidiary, is made known to us byothers within those entities, particularly during the period in which thisreport is being prepared;

(b)         evaluated the effectiveness of theregistrant’s disclosure controls and procedures and presented in this reportour conclusions about the effectiveness of the disclosure controls andprocedures, as of the end of the period covered by this report based on suchevaluation;

(c)          disclosed in this report any change inthe registrant’s internal control over financial reporting that occurred duringthe registrant’s most recent fiscal quarter that has materially affected, or isreasonably likely to materially affect, the registrant’s internal control overfinancial reporting; and

5.    The registrant’s other certifying officerand I have disclosed, based on our most recent evaluation of internal controlover financial reporting, to the registrant’s auditors and the audit committeeof registrant’s board of directors (or persons performing the equivalentfunctions):

(a)          all significant deficiencies andmaterial weaknesses in the design or operation of internal control overfinancial reporting which are reasonably likely to adversely affect theregistrant’s ability to record, process, summarize and report financialinformation; and

(b)         any fraud, whether or not material,that involves management or other employees who have a significant role in theregistrant’s internal control over financial reporting.

Date: May 9,2006
|        | /s/ Paul  Pluschkell                   |
|--------|----------------------------------------|
|   | Paul Pluschkell                        |
|   | President and  Chief Executive Officer |

 

----
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                    Document headings vary by document type but may contain                    the following:                  
                -                       the agency or agencies that issued and signed a document                    
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                -                       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 Education

# FOR FURTHER INFORMATION CONTACT:

                        Sara Strizzi, U.S. Department of Education, 1244 Speer Boulevard, Suite 201, Denver, CO 80204-3514.                         *Telephone:*                         (303) 346-0924 or by                         *e-mail: sara.strizzi@ed.gov*.                    

If you use a TDD, call the FRS, toll free, at 1-800-877-8339.

## VIII. Other Information

*Accessible Format:*                         Individuals with disabilities can obtain this document                               ( print page 1041)                            and a copy of the application package in an accessible format (e.g., braille, large print, audiotape, or computer diskette) on request to the program contact person listed under                         **FOR FURTHER INFORMATION CONTACT**                         in section VII of this notice.                    

*Electronic Access to This Document:*                         You can view this document, as well as all other documents of this Department published in the                         **Federal Register,**                         in text or Adobe Portable Document Format (PDF) on the Internet at the following site:                         *http://www.ed.gov/​news/​fedregister*. To use PDF you must have Adobe Acrobat Reader, which is available free at this site.                    

# Note:

                            The official version of this document is the document published in the                             **Federal Register.**                             Free Internet access to the official edition of the                             **Federal Register**                             and the Code of Federal Regulations is available on GPO Access at:                             *http://www.gpoaccess.gov/​nara/​index.html*.                        

Dated: January 4, 2010.

Kevin Jennings,

Assistant Deputy Secretary for Safe and Drug-Free Schools.

[FR Doc. 2010-130 Filed 1-7-10; 8:45 am]

BILLING CODE 4000-01-P
* 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.

IN THE UNITED STATES COURT OF APPEALS

FOR THE FIFTH CIRCUIT

 

No. 04-40107

Conference Calendar

 

UNITED STATES OF AMERICA,

Plaintiff-Appellee,

versus

DAVID OLMEDO-PACHECO, also known as

Richard Vela-Pacheco,

Defendant-Appellant.

--------------------

Appeal from the United States District Court

for the Southern District of Texas

USDC No. M-03-CR-421-1

--------------------

Before HIGGINBOTHAM, DAVIS, and PICKERING, Circuit Judges.

PER CURIAM:*

Appealing the Judgment in a Criminal Case, David OlmedoPacheco concedes that the arguments raised are foreclosed by

circuit precedent but seeks to preserve them for further review. 

The Government has moved for summary affirmance in lieu of filing

an appellee’s brief. The motion is GRANTED, and the judgment of

the district court is AFFIRMED.

United States Court of Appeals

Fifth Circuit

F I L E D

August 18, 2004

Charles R. Fulbruge III

Clerk