§16

Based on our resolution of the third issue for decision infra, we need not decide whether petitioner’s assertion is correct, and we do not address this issue further.

Although we are doubtful petitioner was an insider subject to liability under section 16(b) of the Exchange Act during 2000, we need not decide the point .

37 In ruling on the parties’ cross-motions, the District Court rejected the Stroms’ argument that each option vesting date should be considered a “purchase” for purposes of applying section 16(b) of the Exchange Act, holding instead that the acquisition date of the options constitutes the purchase date.

We hold that it is subject to tax.

After applying section 165(h)(2), the total theft loss amount allowable is $113 .

We hold that such a remedy is a form of “injunctive relief” within the meaning of section 16 of the Clayton Act.

(cid:16)042 school in Miami. Estralla Delgado Parker Vanini, Mr. Parker's daughter, resided at the home for six months in 2003 while she attended high school in Miami. Mr. Parker and his wife used the home as their residence throughout 2003, 2004 and 2005 when they came to Miami. Finally, Blanca A. Gonzalez, the family's personal maid, resided at the home throughout 2003, 2004, and 2005. Mr. Parker and his family as well as Ms. Gonzalez were given full access to and use ofthe premises for person

Respondent determined petitioner was liable for an accuracy-relatedpenalty of$52,536 under section 16This other income is a determination ofcancellation ofindebtedness income argued in the alternative by respondent.

quish all rights and ownership to the defendant's property. IT IS THEREFORE ORDERED that the defendant's/respondent's property of $152,016.00 (ONE HUNDRED AND FIFTY-TWO THOUSAND AND SIXTEEN DOLLARS) in United States Currency be forfeited pursuant to sec. 16-19-80, Code of Laws of South Carolina (1976), as amended. GCSO gave petitioner a form that explained the consent form. Also on this date, the $1,259 in cash that had been seized from Mrs. Hackworth's purse and the $12,000 in cash that had bee

ed with knowledge of the law."). Petitioners' argument is in no way analogous to the "inequitable and absurd" result in Rod Warren Ink, where the PHC would have been required to declare income it never actually received if not for the departure from section 16.5(e). In the - 75 - instant case, if the alleged theft losses were proven and claimed in the year of discovery, the partnerships would not have to declare income in a previous year that was never actually received. Petitioners are not seek

- 7 - Petitioner further argues that the stock purchased from the option exercise was nontransferable and subject to a substantial risk of forfeiture because petitioner was subject to section 16(b) for a period of 2 years under the lockup agreement. Respondent argues that, upon exercise of the stock option, petitioner recognized compensation income under section 83. Respondent counters that the shares were not subject to section 83(c)(3) when petitioner exercised the option on September 7, 1994,

The lockup agreement further provided: Should I sell these shares I agree that such sale will be subject to Section 16b of The Securities Act of 1934 (Disgorgement of Insider Short-Swing Profits) and further I will be subject to any additional damages incurred by Polyphase Corporation, its directors or shareholders.

The SEC stated in pertinent part: The functional equivalence of derivative securities and their underlying equity securities for section 16 purposes requires that the acquisition of the derivative security be deemed the significant event, not the exercise.

rallel treatment for federal income tax purposes”, while the Commissioner states that “a section 17 corporation * * * is a form of the tribe. It is part of the organizational structure of the tribe just as much as is a tribal government formed under section 16”. Uniband’s rationale actually works against it, since, as we held above, Uniband has failed to show that it possesses TMBCI’s sovereign immunity. Moreover, Uniband’s rationale is faulty because it mistakes the effect (sharing TMBCI’s sove

The Court of Appeals, however, found that the preliminary injunction ordered by the District Court was tantamount to an indirect divestiture which was not a remedy available to private plaintiffs under section 16 of the Clayton Act.

14 hereof, to transfer or assign all or any part of its interest in this Partnership to an affiliated entity; * * * in the event either Partner assigns its - 12 - interest hereunder the provisions of Section 16, shall continue to apply to the assignor, as well as to the assignee, and the interest held by the assignee shall be subject to repurchase as provided in Section 19 hereof, upon the breach of Section 16 by the assignor, the assignee [or] their Affiliates. The General Partnership’s Acquis

Said plantation to be eighty (80) acres." The 80 acres was further described in the R&D agreement as follows: The plantation will be located within the larger tract of land described as follows: the Southeast quarter of the Northwest quarter and the Southwest quarter of Section 16, Township 5 South, Range 16 East, San Bernardino Base and Meridan.

Code Section 16-920 (Suppl., 2004) this Judgment shall become effective to dissolve the bonds of matrimony thirty (30) days after the docketing of this Judgment unless either party applies for a Stay with the Superior Court or the Court of Appeals of the District of Columbia, and FURTHER PROVIDED, that the Court reserves jurisdiction for the entry of th

Section 16.004(a) of the Texas Civil Practice and Remedies Code provides: “A person must bring suit on [specified] actions not later than four years after the day the cause of actions accrues.” Actions on “debt” are among those subject to section 16.004(a). Tex. Civ. Prac. & Rem. Code § 16.004(a)(3) (2013). Texas Civil Practice and Remedies Code §

* * * Section 16 of the City deeds of trust addresses the use of insurance proceeds paid for the damage or destruction of the Building. That section provides: - 7 - [*7] If any building or improvements erected on the Property is [sic] damaged or destroyed by an insurable cause, Trustor shall, at its cost and expense, repair or restore said buildings and

states that each party has sought legal counsel and advice regarding the agreement, including its tax consequences. The parties worked though several drafts before reaching a final agreement. Mr. Greenberg, NCA's attorney, drafted the first version. Paragraph 5.e. ofthat version provided: In consideration ofthe payment due under Secti

states that each party has sought legal counsel and advice regarding the agreement, including its tax consequences. The parties worked though several drafts before reaching a final agreement. Mr. Greenberg, NCA's attorney, drafted the first version. Paragraph 5.e. ofthat version provided: In consideration ofthe payment due under Secti

states that each party has sought legal counsel and advice regarding the agreement, including its tax consequences. The parties worked though several drafts before reaching a final agreement. Mr. Greenberg, NCA's attorney, drafted the first version. Paragraph 5.e. ofthat version provided: In consideration ofthe payment due under Secti

states that each party has sought legal counsel and advice regarding the agreement, including its tax consequences. The parties worked though several drafts before reaching a final agreement. Mr. Greenberg, NCA's attorney, drafted the first version. Paragraph 5.e. ofthat version provided: In consideration ofthe payment due under Secti

luding the following: - 6 - [*6] Article XVI Transfer ofMembership Interest 16.1 A Member shall not voluntarily assign, gift, sell, transfer, pledge or otherwise encumber its Interest, or any portion thereof, or any other rights ofa Member without complying with the terms ofthis Operating Agreement, including without limitation, the provisions of Section 16.5 ofthis Operating Agreement.

luding the following: - 6 - [*6] Article XVI Transfer ofMembership Interest 16.1 A Member shall not voluntarily assign, gift, sell, transfer, pledge or otherwise encumber its Interest, or any portion thereof, or any other rights ofa Member without complying with the terms ofthis Operating Agreement, including without limitation, the provisions of Section 16.5 ofthis Operating Agreement.

Congress in section 280E has set an illegality under Federal law as one trigger to preclude a taxpayer from deducting expenses incurred in a medical marijuana dispensary business. Olive v. Commissioner, 139 T.C. at 39. This is true even if the business is legal under State law. M. Petitioners contend that the application ofsection 280E res

On May 11, 2006, WW Ranch sold a conservation easement on its section 16 and 18 parcels to AFW for $487,500 (ofwhich $144,500 was supplied by NRT).

On May 11, 2006, WW Ranch sold a conservation easement on its section 16 and 18 parcels to AFW for $487,500 (ofwhich $144,500 was supplied by NRT).

On May 11, 2006, WW Ranch sold a conservation easement on its section 16 and 18 parcels to AFW for $487,500 (of which $144,500 was supplied by NRT).

The transaction with - 29 - [*29] Associated Enterprises, Ltd., discussed infra section 16 is an example ofthe use ofa credit line t finance access to the offshore funds.

Among the enumerated items of deductible personal interest is qualified esidence interest. Sec. 163(h)(2)(D). Qualified residence interest is any intere t which is paid or accrued during the. taxable year on acquisition indebtedness secuted by any qualified residence ofthe taxpayer and interest paid or accrued dur'ng the taxable year o

The transaction with - 29 - [*29] Associated Enterprises, Ltd., discussed infra section 16 is an example ofthe use ofa credit line t finance access to the offshore funds.

Petitioners argue that Diogenes' contributions to the xélan 419 plan and the Millennium plan satisfy the requirements ofsection 16 and are thus deductible under section 162(a).

16-7-16 (LexisNexis 2009) provides: "Notwithstanding any other provision of this chapter, a corporation sole may not be formed or incorporated under this chapter after May 3, 2004." !I - 38 - Respondent further contends that Biblical Church's organizing documents set it up as a "tax-hostile" entity, showing that petitioners had no intention o

Section 16 3 (h) (3) (A) defines the term "qualified residence interest" as interest paid or accrued on aelquisition indebtedness or home equity indebtedness with respect to any qualified residence of the taxpayer . The aforementioned indebtedness must be an obligation of the taxpayer and not an obligation of,another . See Golder v . Commissioner,

Employer Contributi ns to Pension or Profit-Sharing Plans An employer's contribut ons t > pension or profit-sharing plans are not deductible and resection 404 unless they are deductible under section 16 2 as ordinary and necessary expenses .

16 (1)'(1), (3) . Petitioner claimed,self- employed health'insur nce :deductions of $1,.574'and $1,991 for 2001 and 2002,-respec ively . Respondent has made no adjustment to petitioner's claim d $1,574 self-employed health insuranc e deduction for 2001, a though it should have been limited to' $1,468 .80 (60 percent of $2,448) Petitioner has n

Section 16 of the permanent stipulation provided that petitioner was to receive all interest in his general contracting business: Business Interests Of The Parties. Respondent [petitioner] is awarded all interest in rental real estate standing in his sole name and all interest in Tuck Builders. Section 19 of the permanent stipulation allocated real

st. 760 Ill. Comp. Stat. Ann. 5/4.11 (West 1992)." In this respect, the Illinois Trusts and Trustees Act does not grant the power to sue on behalf of a trust to a director, a fiduciary, or any other legal representative. See Restatement, Trusts 2d, sec. 16A (1959) ¹4 For purposes of the Ill. Trusts and Trustees Act, see 760 Ill. Comp. Stat. Ann. 5/1 (West 1992), a "trust" means a trust created by agreement, declaration or other written instrument. 760 Ill. Comp. Stat. Ann. 5/2(1) (West 1992). Th

power to sue in a representative capacity on behalf of a trust); (continued...) - 16 - and Trustees Act does not grant the power to sue on behalf of a trust to a director, a fiduciary, or any other legal representative. See Restatement, Trusts 2d, sec. 16A (1959) ("The officers and directors of a corporation, although they are fiduciaries, are not trustees."). In the present case, Adorno Asset has failed to provide the Court with the documentary evidence necessary to support its contention that

The complaint alleged that the purpose of the action was to recover on behalf of the class of employees unpaid overtime compensation, liquidated damages, attorney's fees, and costs under section 16(b) of the Fair Labor Standards Act of 1938, ch.

c. 2703 and added provisions to 25 U.S.C. sec. 2718 authorizing appropriation of necessary funds for operation of the NIGC for fiscal years beginning Oct. 1, 1991 and 1992. In 1992, the Federal Indian Statutes: Technical Amendments, Pub. L. 102-497, sec. 16, 106 Stat. 3255, 3261 (1992), current version at 25 U.S.C. sec. 2703 (Supp. 2000), struck out the words "or Montana" following the word "Wisconsin" in 25 U.S.C. sec. 2703(7)(E). In 1997, the Department of the Interior and Related Agencies App

The class action complaint requested relief for unpaid overtime compensation and liquidated damages in an amount equal - 5 - to the unpaid overtime compensation under section 16(b) of the Fair Labor Standards Act of 1938 (FLSA), ch.

The complaint alleged that the purpose of the action was to recover on behalf of the class of employees unpaid overtime compensation, liquidated damages, attorney's fees, and costs under section 16(b) of the Fair Labor Standards Act of 1938, ch.

16.10.310 (Lexis 2000), and which is secured by petitioners’ fishing permit in order “to satisfy past due federal tax obligations that may result in the execution on and involuntary transfer of [that permit]”. Alaska Stat. sec. 16.10.310(a)(1)(A)(iii) (Lexis 2000). 15Assuming arguendo that we had found that the word “assets” as used in sec. 10

16.051 (West 1997), which allegedly governs challenges to the validity of a durable power of attorney, expired prior to the issuance of the notice of deficiency. Counsel for both parties appeared at the hearing and presented oral argument on the pending motion. During the hearing, counsel for respondent argued that the applicable statute of li

678 (1969); and (3) cases dealing with section 16(b) of the Securities and Exchange Act of 1934 (currently codified at 15 U.S.C.

Although section 865 does not provide a definition of franchise, section 1253(b)(1) defines it for purposes of section 16(...continued) allocate any portion of the sale price to the franchise agreements.

Specifically, Section 16 lost $2,600; Section 18 lost $3,500; Section 20 lost $65,973.87; Section 21 lost $22,000 and Section 23 lost $37,816.60.

Under the heading of “Nonassignability”, section 16.03(A) stated: None of the benefits, payments, proceeds or claims of any Participant shall be subject to any claim of any creditor of any Participant and, in particular, the same shall not be subject to attachment or garnishment or other legal process by any creditor of any Participant, nor shall any Participant have any right to alienate

16.6013-5(b), Income Tax Regs. Factors to be considered are: (i) Whether the spouse claiming relief significantly benefitted from the grossly erroneous items attributable to the culpable spouse, Estate of Krock v. Commissioner, 93 T.C. 672, 677 (1989); and (ii) whether the spouse claiming relief has been deserted by or divorced or separated fr