Fundamentally, TEI does not agree that a presumption that tax positions will be detected and examined should give rise to a correlative presumption, under all circumstances, that the taxing authority will assert a sustainable, contrary position and, as a result, that no benefit should be provided for the tax position unless the enterprise satisfies
a "probable" level of confidence.
In luncheon meats, Oscar Mayer satisfies
the demand for variety with a chicken "Variety-pak.
The Thunder 9585V satisfies
the business need for high performance, high availability storage.
the "subordination of capital" requirement.
The following sample questionnaire may be used by corporations in determining whether the members of, or nominees to, the corporation's compensation committee (or to the subcommittee that administers its performance-based compensation arrangements) satisfies
Contributions in excess of the exclusion allowance set forth in section 403(b)(2) to a plan that satisfies
the requirements of section 403(b) are also considered plan defects.
Law enforcement - Acme Packet Net-Net satisfies
law enforcement requirements, such as CALEA, by supporting transparent session replication and routing of signaling messages and media flows to law enforcement agencies.
In Situation 1, A is covered by an HDHP, a health FSA and an HRA that pay or reimburse medical expenses incurred before A satisfies
the minimum annual deductible under Sec.
A distribution is considered necessary" if it satisfies
the following requirements:
Employer C's athletic equipment and apparel stores line of business, therefore, has its own separate management and thus satisfies
the requirement of Treas.
Honeywell's proposal satisfies
all of the competition concerns and serves the best interests of all stakeholders," Michael Bonsignore said.
The Service ruled that the acquirer's contribution of the target assets to the subsidiary does not prevent the transaction from qualifying as a D reorganization, provided the transaction otherwise satisfies
applicable D reorganization requirements.
7491(a)(1), provided that the taxpayer satisfies
A partnership, S corporation or PSC to change automatically to a natural-business year that satisfies
the 25%-gross-receipts test, regardless of whether such year results in more income deferral than its present tax year;
In Compaq, the court stated that a transaction satisfies
the business-purpose requirement when it has a nontax purpose.