Agree on the roles of the individuals and the brand names that will be used--never agree to
[section] 846, simply provides that those who conspire to violate the federal drug laws are to be punished to the same degree as they could be for the drug crime they agree to
We have occasionally discovered technical issues relating to how the tax on the return is computed while trying to agree to
the computation on the RAR.
The agreement period may last anywhere from one to three years, and may be renewed if both parties agree to
The buyer, however, would not agree to
the changes until it received a letter directly from the Patterson Town Board stating that the subdivision would not be affected by the new zoning ordinance.
Many of these issues can now be resolved via a cost-sharing agreement under which the related parties can, in advance, agree to
share the development costs commensurate with the benefits to be derived.
* Provide standardized procedures to which the taxpayer and the IRS could agree to
implement into the audit process starting with the initial contact and ending at the post examination critique and to resolve all issues at the lowest possible level.
Perhaps in an attempt to obtain financing in the first place, or to convince a real estate lender to extend more credit than it believes a particular construction project on completion will justify, or to salvage a troubled project, developers will often agree to
guaranty interest payments to lenders.
For example, under the alternative-timing resolution, the Service and the taxpayer may agree to
capitalize certain costs incurred only for the period under examination.
In September 1995, the National Office issued final procedures for Appeals mediations, stating that the test period would begin on October 30, [1995..sup.4] In mid-October, the Chief Counsel's procedures accepting mediation in docketed Tax Court cases became [public..sup.5] At this point, only the Justice Department's Tax Division refuses to agree to
mediation in refund or other tax cases.
The IRS reserves the right to require specifically that an eligible QI agree to
include certain of its branches (to ensure the disclosure of certain U.S.
In some cases third parties may also agree to
compensate an entity based on actual costs or results or to renegotiate or reset prices, even retroactively, if significant changes occur.
Section 1 of the proposed procedure provides that both the taxpayer and Appeals must agree to
Each party has present at the mediation someone with authority to agree to
a final settlement of the case for that party-a crucial aspect of a successful mediation procedure.
At the inception of an examination the IRS and taxpayer will have their best opportunity to agree to
joint objectives including involving the taxpayer in planning the examination, identifying the proper resources (in terms of personnel, tools, and facilities), establishing joint examination objectives, exchanging fundamental information, and committing mutually to resolving substantive issues at the lowest possible level.