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

(Form 5471)

(December 2018)

Department of the Treasury 

Internal Revenue Service

Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations

▶ Attach to Form 5471.

▶ Go to www.irs.gov/Form5471 for instructions and the latest information.

OMB No. 1545-0123

Name of person filing Form 5471 Identifying number

Name of foreign corporation EIN (if any) Reference ID number (see instructions)

a Separate Category (Enter code—see instructions.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶

b If code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) . . . . . . . . . . . . . . ▶

Previously Taxed E&P (see instructions)

Important: Enter amounts in functional 

currency.

(a)

Earnings 

Invested in 

U.S. Property 

(section 

959(c)(1)(A))

(b)

Section 965(a) 

Inclusion (section 

959(c)(1)(A)) 

(c)

Section 

965(b)(4)(A) 

(section 

959(c)(1)(A)) 

(d)

Section 951A 

Inclusion (section 

959(c)(1)(A)) 

(e) 

Earnings 

Invested in 

Excess Passive 

Assets (section 

959(c)(1)(B))

(f)

Subpart F 

Income (section 

959(c)(2)) 

(g) 

Section 965(a) 

Inclusion (section 

959(c)(2)) 

(h)

Section 

965(b)(4)(A)

(section 

959(c)(2)) 

(i) 

Section 951A 

Inclusion (section 

959(c)(2)) 

(j)

Total 

 

1a Balance at beginning of year (see 

instructions)

1b Beginning balance adjustments 

(attach statement)

1c Adjusted beginning balance 

(combine lines 1a and 1b)

2 Reduction for taxes unsuspended 

under anti-splitter rules

3 

 

E&P attributable to distributions of 

previously taxed E&P from lowertier foreign corporation

4 E&P carried over in nonrecognition 

transaction

5 Other adjustments (attach 

statement)

6 Total current and accumulated 

E&P (combine lines 1c through 5)

7 

 

Amounts reclassified to section 

959(c)(2) E&P from section 959(c)

(3) E&P

8 Actual distributions of previously 

taxed income

9 Amounts reclassified to section 

959(c)(1) E&P from section 959(c)

(2) E&P

For Paperwork Reduction Act Notice, see instructions. Cat. No. 49203F Schedule P (Form 5471) (12-2018)
Schedule P (Form 5471) (12-2018) Page 2

Previously Taxed E&P (see instructions) (continued)

Important: Enter amounts in functional 

currency.

(a)

Earnings 

Invested in 

U.S. Property 

(section 

959(c)(1)(A))

(b)

Section 965(a) 

Inclusion (section 

959(c)(1)(A))

(c)

Section 

965(b)(4)(A) 

(section 

959(c)(1)(A))

(d)

Section 951A 

Inclusion (section 

959(c)(1)(A))

(e) 

Earnings 

Invested in 

Excess Passive 

Assets (section 

959(c)(1)(B))

(f)

Subpart F 

Income (section 

959(c)(2))

(g) 

Section 965(a) 

Inclusion (section 

959(c)(2))

(h)

Section 

965(b)(4)(A)

(section 959(c)(2))

(i) 

Section 951A 

Inclusion (section 

959(c)(2))

(j)

Total

10 

 

 

Amounts included as earnings 

invested in U.S. property and 

reclassified to section 959(c)(1) 

E&P (see instructions)

11 Other adjustments (attach 

statement)

12 Balance at beginning of next year 

(combine lines 6 through 11)

Schedule P (Form 5471) (12-2018)
<PAGE>

                                                                    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 Amendment No. 1 to the Annual Report on Form 10-K/A
of Navarre Corporation (the "Company") for the fiscal year ended March 31, 2005,
(the "Annual Report"), I, Eric H. Paulson, President and Chief Executive Officer
of the Company, hereby 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 Annual Report fully complies with the requirements of
                  section 13(a) or 15(d) of the Securities Exchange Act of 1934
                  (15 U.S.C. 78m or 78o(d)); and

         2.       The information contained in the Annual Report fairly
                  presents, in all material respects, the financial condition
                  and results of operations of the Company.


June 17, 2005
                                      By /s/ James Gilbertson
                                         ----------------------------------
                                             James Gilbertson
                                             Vice President and
                                             Chief Financial Officer
EXHIBIT 32.1

CERTIFICATIONS PURSUANT TO 

SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

(18 U.S.C. SECTION 1350)

 
| *1.* | The Quarterly Report on Form 10-QSB of the Company for the quarter ended June 30, 2006, as filed with the Securities and Exchange Commission (the “Report”) fully complies with the requirements of Section 13(a) or Section 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 result of operations of the Company. |
|----|-----------------------------------------------------------------------------------------------------------------------------------------------------|

A signed original of this written statement required by Section 906 has been provided to the Company and will be retained by the Company and furnished to the Securities and Exchange Commission or its staff upon request. 
|   |   |                                                                                                                                                                                                              |
|--------|--------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|   |
|   | By:    | /s/ Clark Wilson                                                                                                                                                                                                  |
|   |   | Clark Wilson                                                                                                                                                                                                      |
|   |   | President and Chief Executive OfficerAugust 14, 2006     By:/s/ Daniel Allen  Daniel Allen  Vice President and Chief Financial OfficerAugust 14, 2006
 

  |
<TABLE> <S> <C>

<ARTICLE> 6

<S>                             <C>
<PERIOD-TYPE>                   3-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-START>                             APR-01-1999
<PERIOD-END>                               JUN-30-1999
<INVESTMENTS-AT-COST>                            1,000
<INVESTMENTS-AT-VALUE>                               0
<RECEIVABLES>                                        0
<ASSETS-OTHER>                                       0
<OTHER-ITEMS-ASSETS>                                 0
<TOTAL-ASSETS>                                       0
<PAYABLE-FOR-SECURITIES>                         1,000
<SENIOR-LONG-TERM-DEBT>                              0
<OTHER-ITEMS-LIABILITIES>                            0
<TOTAL-LIABILITIES>                                  0
<SENIOR-EQUITY>                                  1,000
<PAID-IN-CAPITAL-COMMON>                             0
<SHARES-COMMON-STOCK>                            1,000
<SHARES-COMMON-PRIOR>                            1,000
<ACCUMULATED-NII-CURRENT>                            0
<OVERDISTRIBUTION-NII>                               0
<ACCUMULATED-NET-GAINS>                              0
<OVERDISTRIBUTION-GAINS>                             0
<ACCUM-APPREC-OR-DEPREC>                         1,000
<NET-ASSETS>                                         0
<DIVIDEND-INCOME>                                    0
<INTEREST-INCOME>                                    0
<OTHER-INCOME>                                       0
<EXPENSES-NET>                                       0
<NET-INVESTMENT-INCOME>                              0
<REALIZED-GAINS-CURRENT>                             0
<APPREC-INCREASE-CURRENT>                            0
<NET-CHANGE-FROM-OPS>                                0
<EQUALIZATION>                                       0
<DISTRIBUTIONS-OF-INCOME>                            0
<DISTRIBUTIONS-OF-GAINS>                             0
<DISTRIBUTIONS-OTHER>                                0
<NUMBER-OF-SHARES-SOLD>                              0
<NUMBER-OF-SHARES-REDEEMED>                          0
<SHARES-REINVESTED>                                  0
<NET-CHANGE-IN-ASSETS>                               0
<ACCUMULATED-NII-PRIOR>                              0
<ACCUMULATED-GAINS-PRIOR>                            0
<OVERDISTRIB-NII-PRIOR>                              0
<OVERDIST-NET-GAINS-PRIOR>                           0
<GROSS-ADVISORY-FEES>                                0
<INTEREST-EXPENSE>                                   0
<GROSS-EXPENSE>                                      0
<AVERAGE-NET-ASSETS>                                 0
<PER-SHARE-NAV-BEGIN>                                0
<PER-SHARE-NII>                                      0
<PER-SHARE-GAIN-APPREC>                              0
<PER-SHARE-DIVIDEND>                                 0
<PER-SHARE-DISTRIBUTIONS>                            0
<RETURNS-OF-CAPITAL>                                 0
<PER-SHARE-NAV-END>                                  0
<EXPENSE-RATIO>                                      0


</TABLE>
### D ISTRICT 

### C OURT 

### O F 

### A PPEAL 

### O F 

### T HE 

### S TATE 

### O F 

### F LORIDA

F OURTH D ISTRICT

MARCEL A. WRIGHT

, Appellant,

v.

STATE OF FLORIDA

, Appellee

.

No. 4D 17

- 3685

[ October 25, 2018 ]

Appeal of order denying rule 3.850 motion from the Circuit Court for

the Seventeenth Judicial Circuit, Broward County ; Paul L. Backman

, Judge; L.T. Case No. 10

- 7746 CF10A

.

Marcel A. Wright, Defuniak Springs, pro se.

Pamela Jo Bondi, Attorney General, Tallahassee, and Heidi Bettendorf,

Assistant Attorney General, West Palm Beach, for appe llee.

P ER C URIAM

.

Affirmed.

G ERBER

, C.J., M AY and D AMOORGIAN

, JJ., concur.

* * *

Not final until disposition of timely filed motion for rehearing.
Summary Description of Non-Management Director Compensation



 EXHIBIT 10.1 
 NON-MANAGEMENT DIRECTOR COMPENSATION SUMMARY 
 Effective July 1, 2006, as described in detail below, our
non-management directors (“Outside Directors”) will be compensated as follows: 
  

	1.	Cash Retainer: 

 Board Meetings. Each Outside
Director will receive an annual retainer of $20,000 and a per-meeting attendance fee of $750 per meeting. The Chairman of the Board will also receive an additional $20,000 annual retainer. 
 Committee Meetings. Members of the Audit Committee will receive a per meeting attendance fee of $1,000; the Chairman of the Audit Committee will
also receive a $12,000 annual retainer. 
 Members of the Compensation Committee and Nominating & Corporate Governance Committee will
receive a per meeting attendance fee of $500; the Chairman of the Compensation Committee will also receive a $6,000 annual retainer. 
  

	2.	Equity Grants 

 As part of the compensation for
Outside Directors, it is the intent that each Outside Director will receive an annual restricted stock award for 750 shares of company common stock. In 2005, each Outside Director received a restricted stock award for 2,000 shares, 1,000 shares that
vested during 2005, and the remaining 1,000 shares that will vest equally during 2006 and 2007. Accordingly, for the years 2006 and 2007, the annual restricted stock award to Outside Directors will equal 250 shares.
947 A.2d 195

#### James GREEN a/k/a Theodore Hill, Appellant v. COMMONWEALTH of Pennsylvania, Department of Corrections, State Correctional Institution at Pittsburgh, Records Office, Appellee.

Supreme Court of Pennsylvania.

May 29, 2008.

*ORDER*

PER CURIAM.

AND NOW, this 29th day of May, 2008, the Order of the Commonwealth Court is AFFIRMED and the Application for Appointment of Counsel is DENIED.
**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




In
      connection with the Quarterly Report of Interlink Global Corporation (the
      "Company") on Form 10-QSB for the period ended March 31, 2006, as filed
      with the Securities and Exchange Commission on the date hereof (the
      "Report"), We, Anastasios N. Kyriakides, Chairman of the Board and Chief
      Executive Officer, and Bill Rodriguez, Chief Financial 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
      to our knowledge:




a)
      The
      Report fully complies with the requirements of Section 13(a) or 15(d) of the
      Securities Exchange Act of 1934; and b) The information contained in this
      Report fairly presents, in all material respects, the financial condition
      and results of operations of the Company.






/s/
      Anastasios N. Kyriakides


***Anastasios
      N. Kyriakides,***


***Chairman
      of the Board, and Chief Executive Officer***






/s/
      Bill
      Rodriguez


***Bill
        Rodriguez, Chief Financial Officer***
 
 ***August
        27, 2007***
UNPUBLISHED

UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

No. 18-4659

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

DARRELL TYKWAN ATKINSON, a/k/a Da Da,

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of North Carolina, at 

Wilmington. James C. Dever III, District Judge. (7:16-cr-00120-D-5)

Submitted: April 30, 2019 Decided: August 7, 2019

Before KING, THACKER, and QUATTLEBAUM, Circuit Judges.

Affirmed by unpublished per curiam opinion.

G. Alan DuBois, Federal Public Defender, Eric Joseph Brignac, Chief Appellate 

Attorney, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Raleigh, North Carolina, 

for Appellant. Robert J. Higdon, Jr., United States Attorney, Jennifer P. May-Parker,

Assistant United States Attorney, Kristine L. Fritz, Assistant United States Attorney, 

OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for 

Appellee.

Unpublished opinions are not binding precedent in this circuit.
2

PER CURIAM:

Darrell Tykwan Atkinson sold heroin while serving a term of supervised release, 

resulting in a 24-month sentence for distributing a controlled substance, plus a 

consecutive 24-month revocation sentence for violating his supervision. On appeal from 

his revocation judgment, Atkinson contends that the revocation sentence violates the 

Double Jeopardy Clause. For the reasons that follow, we affirm.

We review double jeopardy challenges de novo. United States v. Schnittker, 807 

F.3d 77, 81 (4th Cir. 2015). Nevertheless, on settled issues of law, it is well established 

“that one panel [of this court] cannot overrule a decision issued by another panel” unless 

“the [prior panel] decision rests on authority that subsequently proves untenable.” United 

States v. Williams, 808 F.3d 253, 261 (4th Cir. 2015) (internal quotation marks omitted).

In United States v. Woodrup, 86 F.3d 359 (4th Cir. 1996), we held that “the 

Double Jeopardy Clause does not prohibit the government from criminally prosecuting 

and punishing an offense which has formed the basis for revocation of a term of 

supervised release.” Id. at 363. In urging us to depart from Woodrup, Atkinson 

highlights changes to the Sentencing Guidelines and statutory sentencing factors that 

have occurred since 1996. These changes, however, simply provide no basis for us to 

conclude that the reasoning in Woodrup is no longer sound. Likewise, the Supreme 

Court’s recent decision in United States v. Haymond, 139 S. Ct. 2369 (2019), does not 

undermine Woodrup. Thus, we reject Atkinson’s assertion that his revocation sentence 

runs afoul of the Double Jeopardy Clause.
3

Accordingly, we affirm the judgment of the district court. 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
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

###### National Park Service

# AGENCY:

National Park Service, Interior.

# ACTION:

Public Notice. 

# SUMMARY:

Public notice is hereby given that the National Park Service proposes to award a temporary concession contract authorizing the operation of carriage rides, horse camp, day use parking, facilities and services for the public at Acadia National Park, Maine for a term not to exceed October 31, 2001.

# DATES:

March 22, 2001.

# ADDRESSES:

National Park Service, Concession Management Program, Boston Support Office, 15 State Street, Boston MA 02109-3572, Telephone (617) 223-5209.

# SUPPLEMENTARY INFORMATION:

This temporary concession contract is being awarded to Mr. Edward Winterberg, Seal Harbor, Maine. It is necessary to award the contract in order to avoid interruption of visitor services.

This action is issued pursuant to 36 CFR 51.24(a). This is not a request for proposals and no prospectus is being issued at this time. The Secretary intends to issue a competitive solicitation of offers for a long-term operator to begin in 2002. You may be placed on a mailing list for receiving information regarding the competitive solicitation by sending a written request to the above address.

Dated: December 22, 2000.

Chrysandra L. Walter,

Acting Regional Director, Northeast Region.

[FR Doc. 01-4082  Filed 2-16-01; 8:45 am]

BILLING CODE 4310-70-M
EXHIBIT 32

                            CERTIFICATION PURSUANT TO
                             18 U.S.C. SECTION 1350,
                             AS ADOPTED PURSUANT BY
                  SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002


         In connection with the Quarterly Report of Eat at Joe's,  Ltd., on Form
10-QSB for the quarter  ending June 30,  2005 as filed with the  Securities  and
Exchange Commission on the date hereof (the "REPORT"),  the undersigned,  Joseph
Fiore, Chief Executive Officer and Principal  Accounting Officer of the Company,
certify,  pursuant to 18 U.S.C.  ss.1350,  as adopted pursuant to ss. 906 of the
Sarbanes-Oxley Act of 2002, that to the best of my knowledge and belief:

         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 result of
                  operations of the Company.

Date: August 15, 2005


/s/ Joseph Fiore
Joseph Fiore
CEO, CFO, Chairman, Secretary, Director
(Principal Executive & Accounting Officer)


A signed  original of this written  statement  required by 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
has been  provided  to the  Company  and will be  retained  by the  Company  and
furnished to the Securities and Exchange Commission or its staff upon request.
IN THE COURT OF CRIMINAL APPEALS

OF TEXAS

LUIS RODOLFO LOPEZ, §

APPELLANT §

§

VS § APPEAL NO. 05-13-01137-CR

§ FILED IN state of texas, ^^ | „OURT OF CRIMINAL APPEALS

FEB 23 2315

motion for an extension of time „ , n

ADe/ Acosta, Clerk

COMES NOW, Luis Rodolfo Lopez, the Appellant herein, and

timely request a 45 day extension of time to prepare and tile a

Petition for Discretionary Review. In support thereof, Appellant

would show:

I

On February 12, 2015, Appellant received a copy of the

February 2, 2015, Court Opinion delivered by the Dallas Court

of appeals at the prison mail room.

II

Appellant is proceeding pro se and will require all tne

time he can muster in preparing his Petition in the Prison Law

Library.

Appellant prays the Court will grant.him at least 45 days

preparation and filing timeRPPPlUPfl III Luis Rodolfo Lop

^..Jr^"'"^*"' *•» Polunsky Unit

COURTOFGRffJJINALAPPEALS 3872 Fm 350 south

FEB 19 2015

iuis RodolfoLopez, ft1874821

Livingston, Texas 77351
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 Indian Affairs

# AGENCY:

Bureau of Indian Affairs, Interior.

# ACTION:

Notice of approved Tribal-State Compact. 

# SUMMARY:

                        Pursuant to Section 11 of the Indian Gaming Regulatory Act of 1988 (IGRA), Pub. L. 100-497, 25 U.S.C. § 2710, the Secretary of the Interior shall publish, in the                         **Federal Register,**                         notice of approved Tribal-State Compacts for the purpose of engaging in Class III gaming activities on Indian lands. The Deputy Assistant Secretary—Indian Affairs, Department of the Interior, through his delegated authority, has approved the Tribal-State Compact between the Coushatta Tribe of Louisiana and the State of Louisiana, which was executed on December 11, 2000, except for Section 12(C) which has been disapproved pursuant to the severability clause in Section 2(F).                    

# DATES:

This action is effective February 12, 2001.

# FOR FURTHER INFORMATION CONTACT:

George T. Skibine, Director, Office of Indian Gaming Management, Bureau of Indian Affairs, Washington, DC 20240, (202) 219-4066.

Dated: January 25, 2001.

James H. McDivitt,

Deputy Assistant Secretary—Indian Affairs (Management).

[FR Doc. 01-3611  Filed 2-8-01; 12:29 pm]

BILLING CODE 4310-02-M