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Moreover, we doubt whether a TAM will--or should--be issued when a Generic Legal Advice memorandum is pending (or where the Associate or Assistant Chief Counsel anticipates that a question raised in the TAM process will be considered in a subsequent Generic Legal Advice memorandum).
The court also ordered the NYC Department of Buildings to show cause why an order should not be issued permanently enjoining the NYC Department of Buildings from issuing temporary c/os.
The petition requesting a ban of the use of phthalates in soft vinyl toys has still not been officially addressed, although a CHAP Report issued last year remains the Commission's policy.
No permits were issued for new industrial construction in January or February in Sault Ste.
Centel Communications: In 1989, the Tax Court held that warrants were not issued in connection with services; see Centel Communications, 92TC 612 (1989).
In the wake of that hearing, the IRS issued new case management procedures that are designed to speed up the process and increase consistency.
It is worth noting, however, that the promoters of the investment fund may still profit, because they might receive a placement fee at the time of issue and, in some cases, might participate in the agent commission that was received when the business was originally issued.
As of December 1994, the IRS had issued eight comprehensive market manuals, with the remaining manuals to be issued in 1996.
Although the final COI regulations provide for a 40% COI safe harbor, the regulations do not specify a minimum level of propriety interest that must be issued to satisfy the COI requirement.
approach being used to implement mandatory e-filing: (1) reach out to affected taxpayers before the mandate was issued, (2) use a phased-in implementation, (3) permit more time to test new systems, and (4) make guidance on securing waivers a higher priority.
Issued in March, with technical corrections in August, rules expand the types of material events to be reported, and shorten the time in which 8-Ks must be filed, to four business days from five or fifteen days.
It is expected that New Shares issued under the Entitlement Offer to eligible shareholders will be quoted on a deferred settlement basis on June 8 with normal trading for all New Shares issued under the Offer expected to commence as soon as practicable after that date.
In November, the IRS and Treasury Department issued final and temporary regulations providing a simplified procedure for automatically obtaining extensions of time to file certain returns.
In other words, if covered opinions cannot assume that the business purpose of a transaction is to secure tax benefits, and if the only potential profitability expected to arise from a transaction is the tax benefits, then no covered opinion may be issued.
91-10, Accounting for Special Assessments and Tax Increment Financing Entities, discusses whether a property owner should record an obligation for special assessments levied by municipalities or for debt issued by TIFEs.