§621 — Repealed. Pub. L. 101–508, title XI, § 11801(a)(28), Nov. 5, 1990, 104 Stat. 1388–521]

on 382(l)(3)(A)(i) to apply solely from the perspective of individuals who are shareholders (as determined under the attribution rules of section 382(l)(3)(A)) of the loss corporation.14 In practical terms, our conclusion dictates that we sustain respondent’s determination in this case, even though we disagree with his interpretation of the statute.

Norberg.was in actual or constructive receipt of property of decedent and thus "as statutory executor.within the meaning of section 2203, was the proper person to whom to issue the notice of deficiency pursuant to section 6212 (b) (31) and the proper party to bring the instant case pursuant to Tax Court Rule 60(a)".

32 occurred, the relevant limitations period was two years. Id. at 45. After the underlying conduct occurred, but before the plaintiff in the case filed suit, Congress changed the limitations period to require that a plaintiff bring the action within 90 days after receiving a right-to-sue letter from the Equal Employment Opportunity Com

DEC’s postconceptual review decision “is not a permit” but “intended to provide potential applicants with a binding decision from the department as to the general acceptability of a proposed project or any component or issue specified.” Id. subdiv. (j). 8 [*8] intended to build a power plant on that portion of the property, nev

In the deficiency case the oprowskis filed their deficiency suit in the only court authorized under section 621 (a) to hear such suits--i.e., this Court.

§621 [sic], the Americans with Disabilities Act, the Family and Medical Leave Act of 1993, or any other Federal, state or local statute, regulation or ordinance prohibiting employment discrimination. Petitioner was a resident of California when she executed the release. Petitioners’ legal fees were based on a contingency-fee agreement with their at

Whether Kanter Is Liable for Section 621(c) Increased Interest for 1978, 1979, 1980 Through 1984, and 1986, and 1987, and 1988 OPINION For the year at issue, section 6621(c), increased the interest rate due on a deficiency to 120 percent of the statutory rate (established under section 6601) on any underpayment of tax that exceeds $1, 000 attributable to "tax motivat d transac

§621 et seq.) or the fed- eral Americans with Disabilities Act (42 U.S.C. §12101 et seq.) or similar state or local statutes, or other- wise and all claims in tort or contract related to Employee's employment or to any acts or omissions of the Company involving Employee. THE RELEASE AND WAIVER SET FORTH IN PARAGRAPH 8 OF THIS AGREEMENT OR OTHERWISE

§ 621 et seq.” (ADEA). The April 23 letter invites settlement but threatens litigation “under the ADEA and any other theories that are meritorious.” By counsel, Boehringer responded to the April 23 letter with a letter of its own, dated - 4 - May 1, 1992, denying any grounds for an ADEA claim but allowing for further discussion. Following one or m

re modification of judgment of dissolution must be construed against James Little because his advisers drafted it. Cal. Civil Code sec. 1654 (West 1985); 2 Restatement, Contracts 2d, sec. 206 (1981); 4 Williston, A Treatise on the Law of Contracts, sec. 621 (3d ed. 1961). We disagree. An agreement is construed against its - 20 - drafters only to resolve ambiguities in the agreement. Williston, supra. The stipulation re modification of judgment of dissolution clearly states that the payments at

plaint alleging sex discrimination. Petitioner based her discrimination allegations on the following: 1.1 [Title VII of] The Civil Rights Act of 1964 as amended, 42 USC Sec. 2000 e-16(c); The Age Discrimination in Employment Act, as amended, 29 USC Sec. 621, et seq.; The Civil Rights Attorneys Fee Act of 1976, as amended, 42 USC Sec. 1988; 39 USC Sec. 409, and application thereof by the courts, permitting judicial review of final decisions of the U.S. Postal Service; - 5 - Petitioner's complaint