alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
T.C. Memo. 2000-4

UNITED STATES TAX COURT

LOY ROBERT BOST III, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 8259-99. Filed January 6, 2000.

Loy Robert Bost III, pro se.

Steven M. Webster, for respondent.

MEMORANDUM OPINION

POWELL, Special Trial Judge: Respondent determined a

deficiency in petitioner’s 1996 Federal income tax in the amount

of $4,434.
- 2 -

1 Section references are to the Internal Revenue Code in

effect for the year in issue, and Rule references are to the Tax

Court Rules of Practice and Procedure.

The issue is whether wages and a pension distribution are

taxable under section 61.1 Petitioner resided in Hickory, North

Carolina, at the time the petition was filed.

Respondent determined that petitioner received wages of

$31,808 and a pension distribution of $1,270 from a so-called

section 401(k) retirement account during 1996, and petitioner has

stipulated these facts. Petitioner raises two arguments. First,

he contends that this Court does not have jurisdiction to resolve

the matter. We have frequently stated that the predicates to our

jurisdiction are that a valid notice of deficiency is mailed to

the taxpayer at his last known address and a timely petition is

filed in this Court. See secs. 6612, 6213, Rule 13; see also

Monge v. Commissioner, 93 T.C. 22, 27 (1989); Pyo v.

Commissioner, 83 T.C. 626, 632 (1984). That jurisdiction is in

personam. See Freytag v. Commissioner, 110 T.C. 35, 39 (1998). 

In this case a valid notice of deficiency was mailed to

petitioner at his last known address, and petitioner timely filed

a petition in this Court. This Court, therefore, has

jurisdiction.

Petitioner’s second argument is that wages or compensation

for labor and the pension distribution are not taxable income. 
- 3 -

This argument is frivolous. See secs. 61, 72, 402(a); see also

Rowlee v. Commissioner, 80 T.C. 1111, 1119-1122 (1983).

Respondent asks that a penalty be imposed under section

6673. That section provides, inter alia, that if it appears to

this Court that “the taxpayer’s position * * * is frivolous or

groundless”, the Court may impose a penalty in an amount not in

excess of $25,000. Sec. 6673(a). This Court cautioned

petitioner at the calendar call and at the trial that the

positions he espoused were frivolous and warned him of the

provisions of section 6673. Petitioner did not heed these

warnings. We therefore award a penalty to the United States

against petitioner in the amount of $1,500. 

An appropriate order and decision 

will be entered.
#### The Hektograph Co. v. Fourl and another.

*(Circuit Court, S. D. New York.*

August 9, 1881.)

Attorney at Law — Lien of.

Where the attorneys for a party withdraw from the case of their own motion, the new attorneys were substituted without prejudice to the existing lien of the original attorneys; but the former attorneys are not entitled to any lien on ultimate recoveries.

Blatchford, C. J.

In this and the nine other cases I think the new attorneys must be substituted, without prejudice, of course, to any existing lien of the former attorneys on papers, but without the imposition or creation of any lien on any future recoveries in favor of the former attorneys in respect to their first services. Whatever might be done in a case where the client, without any reason but his wish, desired to displace his attorneys, I think that as, in this ease, the attorneys withdrew of their own motion, and no special reasons are shown for impressing a lien in their favor on any ultimate recoveries, no such lien should be created as a condition of the substitution.
LERONNIE LEE WALTON,

Appellant,

v.

STATE OF FLORIDA,

Appellee.

IN THE DISTRICT COURT OF APPEAL

FIRST DISTRICT, STATE OF FLORIDA

NOT FINAL UNTIL TIME EXPIRES TO 

FILE MOTION FOR REHEARING AND 

DISPOSITION THEREOF IF FILED

CASE NO. 1D10-6776

_____________________________/

Opinion filed July 14, 2017.

An appeal from the Circuit Court for Duval County.

Mark H. Mahon, Judge.

Andy Thomas, Public Defender, and Pamela D. Presnell, Assistant Public 

Defender, Tallahassee, for Appellant.

Pamela Jo Bondi, Attorney General, and Samuel A. Perrone, Assistant Attorney 

General, Tallahassee, for Appellee.

ON REMAND FROM THE FLORIDA SUPREME COURT

PER CURIAM.

Pursuant to the mandate issued by our supreme court, we reverse and 

remand for a new trial in accordance with Walton v. State, 208 So. 3d 60 (Fla. 

2016).
2

REVERSED and REMANDED.

 B.L. THOMAS, C.J., WETHERELL and JAY, JJ., CONCUR.
Exhibit 15.2

Consent of Independent Registered Public Accounting Firms

We consent to the incorporation by reference in the registration statements on Form F-3 (No. 333-199023-02) of Unilever PLC and on Form F-3 (No. 333-199023)
of Unilever N.V. of our report dated 3 March 2015, with respect to the consolidated balance sheets of Unilever Group (Unilever N.V. and Unilever PLC, together with their subsidiaries) as of 31 December 2014, and the related consolidated
income statement, consolidated statement of comprehensive income, consolidated changes in equity, and consolidated cash flows for the year ended 31 December 2014, and all related financial statement schedules, and the effectiveness of internal
control over financial reporting as of 31 December 2014, which report appears in the 31 December 2014 annual report on Form 20-F of Unilever N.V.



|                       |  |  |  |                       
|---------------------- |  |  |  | ----------------------
|KPMG LLP               |  |  |  | KPMG Accountants N.V. 
|London, United Kingdom |  |  |  | Amsterdam, Netherlands
|                       |  | 
|6 March 2015           |  |  |  |
O RDER

- 1 IN THE SUPREME COURT OF THE STATE OF MONTANA

Supreme Court No. DA 22

- 0 342

STATE OF MONTANA

,

Plaintiff and Appellee,

v.

JEREMY HOLMQUIST,

Defendant and Appellant

.

___________________________________________________ ______________

ORDER

_______________ ___________________________________________________

Upon consideration of Appellant’s motion for extension of time, and

good cause appearing,

IT IS HEREBY ORDERED that Appellant is granted an extension

of time to and including February 29 , 202 4 , within which to prepare, file,

and serve Appellant’s opening brief on appeal.

Electronically signed and dated as indicated below.

Electronically signed by:

Mike McGrath

Chief Justice, Montana Supreme Court

February 1 2024

02/01/2024

Case Number: DA 22-0342
Exhibit 32.1


   CERTIFICATION PURSUANT TO RULE 13a-14(b) OF THE EXCHANGE ACT AND 18 U.S.C.
 SECTION 1350, AS ENACTED PURSUANT TO SECTION 906 OF THE SARBANES-OXLEY ACT OF
                                      2002

         In connection with the filing of Zunicom, Inc. and Subsidiaries (the
"Company") Quarterly Report on Form 10-Q for the period ending March 31, 2006 as
filed with the  Securities  and  Exchange  Commission  on the date  hereof  (the
"Report"),I,  William Tan, President and Chief Executive Officer of the Company,
certify, pursuant to Rule 13a-14(b) of the Exchange Act and 18 U.S.C. (SS) 1350,
as enacted 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 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/ William Tan
--------------------
William Tan
President and Chief Executive Officer
(principal executive officer)

May 12, 2006




























                                    32.1-1
#### Commonwealth vs. George Nassar.

February 15, 2008.

*Practice, Criminal,*New trial.

George Nassar appeals from the denials, by a single justice of this court, of his motion to reopen proceedings on his motion for leave to appeal from the denial of his postconviction motion for a new trial, and of his motion for reconsideration. We affirm the judgment.

In 1967, Nassar was convicted of murder in the first degree. This court affirmed the conviction after plenary review. *Commonwealth*v. *Nassar,*354 Mass. 249 (1968), cert. denied, 393 U.S. 1039 (1969). In 1982, Nassar filed a pro se motion for a new trial, which was denied by a judge in the Superior Court. He filed in the county court a one-sentence “motion for leave to appeal,” which indicated that Nassar intended to appeal but did not state any grounds for doing so or identify any “new and substantial question” warrant*1032ing this court’s attention. G. L. c. 278, § 33E (gatekeeper provision). He also requested appointment of counsel, but no counsel was appointed at that time. On November 1, 1983, there having been no activity in the case for over six months, the county court issued a notice that the matter would be dismissed unless good cause was shown not to do so. Nassar did not respond, and so the matter was dismissed on November 22, 1983.

*Claudia Leis Bolgen*for the defendant.

*Kenneth E. Steinfield,*Assistant District Attorney, for the Commonwealth.

There was no further activity for over twenty years, until 2006, when Nassar filed his motion to reopen the proceedings.1 The single justice did not err or abuse his discretion by denying that motion or the subsequent motion for reconsideration. Nassar claimed in his motion that he was unable, in 1983, to show good cause not to dismiss the matter because at that time, he was incarcerated in the Federal prison in Leavenworth, Kansas, without access to Massachusetts legal materials.2 However, he was returned to Massachusetts in December, 1983,3 but did not seek to reopen the matter or inquire as to its status at that time, or at any time thereafter for over twenty years. We perceive no error or abuse of discretion in declining to reopen the proceedings after such a long period of inaction.

*Judgment affirmed.*

1

Also in 2006, Nassar filed a second motion for a new trial in the Superior Court. That motion is still pending.

2

Nassar also claims, for the first time on appeal, that he did not receive the 1983 notice that the matter was to be dismissed. That claim, which is inconsistent with the arguments presented to the single justice, is not properly before us. In any event, even if he did not receive the notice, he did nothing for over twenty years to pursue his proposed appeal or to inquire as to the status of his motion. In these circumstances, Nassar was not entitled to have the proceedings reopened.

3

Nassar and other inmates successfully challenged their transfer to the Federal prison system in a civil action commenced in 1981. See *Blake*v. *Commissioner of Correction,*390 Mass. 537 (1983), *S.C.,*403 Mass. 764 (1989).
ALD-023 NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

___________

No. 13-3601

___________

UNITED STATES OF AMERICA

v.

JEFFREY RIGGINS,

Appellant

____________________________________

On Appeal from the United States District Court

for the Eastern District of Pennsylvania

(D.C. Crim. No. 2-06-cr-00700-001)

District Judge: Honorable Juan R. Sanchez

____________________________________

Submitted for Possible Summary Action 

Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6

October 31, 2013

Before: RENDELL, FISHER and GREENAWAY, JR., Circuit Judges

(Opinion filed: November 21, 2013)
2

_________

O P I N I O N

_________

PER CURIAM

Jeffrey Riggins appeals the District Court’s order denying his motion to correct a 

clerical error in his criminal judgment. For the reasons below, we will summarily affirm 

the District Court’s order.

Riggins was convicted in 2007 of twenty-five counts of possession of cocaine base 

with intent to distribute as well as one count of possession of a firearm by a convicted 

felon in violation of 18 U.S.C. § 922(g). He was sentenced to 432 months in prison. 

Because Riggins had at least three previous convictions for serious drug offenses or 

violent felonies, he was subject to a mandatory minimum sentence of fifteen years in 

prison for the § 922(g) conviction pursuant to 18 U.S.C. § 924(e). On direct appeal, we 

affirmed Riggins’s conviction and sentence. United States v. Riggins, 319 F. App’x 180 

(3d Cir. 2009).

In July 2013, Riggins filed a motion pursuant to Fed. R. Crim. P. 36 to correct a 

purported clerical error in his criminal judgment. He argued that the judgment was 

inaccurate because it failed to refer to the sentencing enhancement under § 924(e). The 

District Court determined that the absence of a reference to § 924(e) was not an error that 

required correction. It denied the motion, and Riggins filed a notice of appeal.

Under Rule 36, a District Court may correct a clerical error in a judgment at any 

time. The purported error here does not involve a failure to accurately record an action or 
3

statement by the District Court. See United States v. Bennett, 423 F.3d 271, 277-78 (3d 

Cir. 2005). Riggins has not alleged that the sentence on the criminal judgment does not 

reflect the sentence imposed by the District Court at sentencing. Because there was no 

clerical error to be corrected, the District Court did not err in denying Riggins’s Rule 36 

motion.

Summary action is appropriate if there is no substantial question presented in the 

appeal. See Third Circuit LAR 27.4. For the above reasons, as well as those set forth by 

the District Court, we will summarily affirm the District Court’s order. See Third Circuit 

I.O.P. 10.6.
Form of Letter Agreement



 Exhibit 10.3 
 Mattersight Corporation 
 200 S. Wacker Drive 

Chicago, IL 60606 
 December 19, 2011 
  

 
  

 
 This letter agreement confirms certain
understandings between Mattersight Corporation (“Mattersight”) and             (the “Series B Stockholder”), holder of
            shares of 7% Series B Convertible Preferred Stock, par value $0.01 per share (the “Series B Preferred Stock”). 

The Series B Stockholder and Mattersight hereby agree as follows: 
  

	 	1.	The Series B Stockholder, solely in his capacity as a holder of Series B Preferred Stock, waives any claim he may have against Mattersight to receive any mandatory cash
distributions or payments solely as a result of the sale of Mattersight’s Integrated Contact Solutions Business Unit. 

  

	 	2.	The Series B Stockholder acknowledges and consents to the terms of the Purchase and Settlement Agreement (the “Purchase and Settlement Agreement”) to
be entered into by Mattersight with certain other holders of Series B Preferred Stock (the “TCV Entities”), including the purchase by Mattersight of all Series B Preferred Stock of Mattersight held by the TCV Entities.


  

	 	3.	Mattersight has informed the Series B Stockholder that Mattersight is contemplating a tender offer expected to commence in the first quarter of 2012 for up to 200,000
shares of Series B Preferred Stock at a cash purchase price of $8.60 per share, plus accrued and unpaid dividends. The Series B Stockholder hereby informs Mattersight that he will not tender his Series B Preferred Stock and agrees not to participate
in the proposed tender offer. 

  








	 	4.	The Series B Stockholder agrees that all information provided to him in connection with his consideration of the matters described in this letter, including the
Purchase and Settlement Agreement, the proposed tender offer and any information related thereto, is confidential, and the Series B Stockholder agrees to preserve the confidentiality of such information and agrees not to use any such information for
any purpose other than for considering the agreements set forth in this letter. 

 * * * 

 

			
	Very truly yours,
	
	MATTERSIGHT CORPORATION
		
	By:	 	 
	Name: Kelly D. Conway
	Title: President and Chief Executive Officer

  

			
	Agreed and Accepted:
UN PUBLISHED
UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 23
- 1985

In re: JOEY LAMONT BRUNSON , Petitioner.

On Petition for Writ of Mandamus to the United States District Court for the District of South Carolina , at Columbia . ( 3:14

- cr - 00604

- JFA

- 18 )

Submitted : October 19 , 2023 Decided: October 23, 2023

Before KING and WYNN , Circuit Judges , and TRAXLER , Senior Circuit Judge

.
Petition denied by un published per curiam opinion

. Joey Lamont Brunson, Petitioner Pro Se.
Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 23-1985 Doc: 6 Filed: 10/23/2023 Pg: 1 of 22 PER CURIAM : Joey Lamont Brunson petitions for a writ of mandamus, alleging that the district court has unduly delayed acting on his 28 U.S.C. § 22 55 motion. He seeks an order from this court directing the district court to act. Our review of the district court’s docket reveals that the district court recently granted the Government’s motion for summary judgment and d enied Brunson relief on his § 2 255 motion. Accordingly , because the district court has recently decided Brunson’s case, we deny the mandamus petition as moot

. To the extent that Brunson seeks recusal of the district court judge in this mandamus petition, we conclude that Brunson’s con clusory assertions of bias are insufficient to warrant recusal. See Belue v. Leventhal , 640 F.3d 567, 572

- 73 (4th Cir. 2011). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this cour t and argument would not aid the decisional process.
PETITION DENIED USCA4 Appeal: 23-1985 Doc: 6 Filed: 10/23/2023 Pg: 2 of 2
---

CERTIFICATION
 
 I, Christian Lown, certify that:
 
 1. I have reviewed this report on Form 10-K and all
        reports on Form 10-D required to be filed in respect of the period covered by this report on Form 10-K of SLM Student Loan Trust 2013-3 (the “Exchange Act periodic reports”);
 
 2. Based on my knowledge, the Exchange Act periodic
        reports, taken as a whole, do not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with
        respect to the period covered by this report;
 
 3. Based on my knowledge, all of the distribution,
        servicing and other information required to be provided under Form 10-D for the period covered by this report is included in the Exchange Act periodic reports;
 
 4. Based on my knowledge and the servicer compliance
        statements required in this report under Item 1123 of Regulation AB, and except as disclosed in the Exchange Act periodic reports, the servicer and administrator have fulfilled their obligations under the servicing agreement and administration
        agreement, as applicable, in all material respects; and
 
 5. All of the reports on assessment of compliance with
        servicing criteria for asset-backed securities and their related attestation reports on assessment of compliance with servicing criteria for asset-backed securities required to be included in this report in accordance with Item 1122 of Regulation
        AB and Exchange Act Rules 13a-18 and 15d-18 have been included as an exhibit to this report, except as otherwise disclosed in this report. Any material instances of noncompliance described in such reports have been disclosed in this report on Form
        10-K. In giving the certifications above, I have reasonably relied on information provided to me by the following unaffiliated party: Deutsche Bank National Trust Company, as indenture trustee.
 
 [Signature Page Follows]
 
 
 Date:  March 29, 2019
 
 /s/ CHRISTIAN LOWN Christian LownPresident and Chief Financial Officer (Senior Securitization Officer)Navient Funding, LLC
UN PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 21

- 6867

DARRELL L. GOSS

,

Plaintiff

- Appellant

,

v.

SCOTT S. HARRIS, U.S. Supreme Court Clerk

,

Defendant

- Appellee

.

Appeal from the United States District Court for the District of South Carolina

, at Charleston

. Bruce H. Hendricks, District Judge. ( 2:21

- cv

- 00218

- BHH )

Submitted : September 14, 2021 Decided: September 20, 2021

Before THACKER and RICHARDSON, Circuit Judges, and TRAXLER, Senior Circuit Judge

.

Affirmed by un published per curiam opinion

.

Darrell L. Goss , Appellant Pro Se.

Unpublished opinions are not binding precedent in this circuit.2 PER CURIAM:

Darrell L. Goss appeals the district court’s order adopting the recommendation of

the magistrate judge and dismissing his 42 U.S.C. § 1983 civil action . We have reviewed

the record and find no reversible error. Accordingly, we affirm for the reasons stated by

the district court. Goss v. Harris , No. 2:21

- cv

- 00218

- BHH (D.S.C. May 5, 2021).

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
```

[Congressional Bills 114th Congress]
[From the U.S. Government Publishing Office]
[S. 955 Introduced in Senate (IS)]

114th CONGRESS
  1st Session
                                 S. 955

  For the relief of Vichai Sae Tung (also known as Chai Chaowasaree).

_______________________________________________________________________

                   IN THE SENATE OF THE UNITED STATES

                             April 15, 2015

Ms. Hirono (for herself and Mr. Schatz) introduced the following bill; 
  which was read twice and referred to the Committee on the Judiciary

_______________________________________________________________________

                                 A BILL

 
  For the relief of Vichai Sae Tung (also known as Chai Chaowasaree).

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

SECTION 1. PERMANENT RESIDENCE.

    Notwithstanding any other provision of law, for purposes of the 
Immigration and Nationality Act (8 U.S.C. 1101 et seq.), Vichai Sae 
Tung (also known as Chai Chaowasaree) shall be held and considered to 
have been lawfully admitted to the United States for permanent 
residence as of the date of the enactment of this Act upon payment of 
the required visa fees.

SEC. 2. REDUCTION OF NUMBER OF AVAILABLE VISAS.

    Upon the granting of permanent residence to Vichai Sae Tung (also 
known as Chai Chaowasaree), as provided in this Act, the Secretary of 
State shall instruct the proper officer to reduce by the appropriate 
number during the current fiscal year the total number of immigrant 
visas available to natives of the country of the alien's birth under 
section 203(a) of the Immigration and Nationality Act (8 U.S.C. 
1153(a)).
                                 <all>
```
Lexter Kossie#700661

William McConnell Unit

3001 South Emily Drive

Beeville, Texas 78102

April 26, 2015

Texas Court of Criminal Appeals

P.O. BOX 12308, Capitol Station

Austin, Texas 78711

RE: WR NOs. 10,978-01 thru 10,978-16

Tr.Ct.NOs. 679887-A thru 679887-K

185th District Court - Harris County

tofl% -0\l07l03,.0*7,06^-3

CM idt nc r*o'«. -1^77-^ s3^

APR 29 2015

Dear Clerk:

Recently I have been cited for abuse of the writ. In

order for me to show that the claims I intend to raise in my

subsequent writ are not barred by Sec 4 I am requesting the

docket sheet of all the writs mentioned above with a list of

all of the claims presented in each of those application. With

out a list of all of the claims I cannot show that the claims

I intend to raise have not been raised before in those prior

applications.

Thank you for any consideration given in this matter.

cc:File

Sincerely,

^ZZ&'fl&^L^

Lexfcli? Kennon Kossie