While not binding upon the IRS, an agreement by the parties to the transaction as to the consideration being paid for the covenant
should be helpful in defending the treatment of the remaining consideration as attributable to the business goodwill.
By comparing the covenants
with ancient (Hittite) treaties, George Mendenhall enhanced knowledge of the historical and structural elements of the covenant
(Law and Covenant
in Israel and the Ancient Near East, 1955), and Johannes Pedersen explored the anthropological dimension of covenant
making (Israel: Its Life and Culture, in various editions).
Discuss potential covenant
breaches with your banker as soon as possible.
In a recent case, the Jolly Anglers pub in Reading was sold with a restrictive covenant
which meant its license was surrendered.
In three states--Louisiana, Arizona, and Arkansas--a couple who chooses to marry may choose a covenant
marriage, which consists of a legally enforceable agreement between the spouses to adopt a more binding form of marriage than available under typical "no-fault" divorce statutes.
At a minimum, debt covenant
violations cause issues between the borrower and the lending institution, a relationship that is vital to the livelihood of most businesses.
was formally reaffirmed in March, but the summer ceremony was chosen as "an appropriate occasion for the churches to publicly recommit to the gospel values of the New Covenant
," said Stephen Allen, the PCC's associate secretary for Justice Ministries, and responsible for the church's healing and reconciliation programs.
This tale would have the Covenant
emerge, fully-formed, from the tortured head of Archibald Johnston of Wariston, sweep Scotland in a wave of millenarian enthusiasm, and be foisted on England through the device of the Solemn League and Covenant
Weir finds covenants
and covenantal thinking suffused throughout the life of early New England.
With Black America had just become the first title by an African American book publisher to reach the No.
Founded in 1999 in Dallas, Texas, by Phil and Cindy Waugh, a Baptist minister and his church-worker wife, the Covenant
Marriage Movement organization grew by 2006 to claim fifty thousand couples and sixty-five cooperating ministries.
This was especially important for the children of the covenant
and the children of parents who had not subscribed to the covenant
TEI believes, however, that the proposed restrictive covenant
provisions are overbroad, going beyond the government's legitimate concern about reversing the results in the Fortino and Manrell decisions.
Adding such a well-established company like Covenant
Security to our organization fulfills one of our strategic goals, said Steve Jones, Allied Universal CEO.
He argued that the idea of a covenant
between the Lord and Israel was a late creation innovated in the seventh century BCE, and influenced by the prophets before that time (6).