Memorandum-to-the-File Re: Contingent Liabilities in a Section 351 Transfer Case Facts: An accrual basis taxpayer Charles Cho engages in a Section 351 transaction with the newly-formed Patten Corporation. In the transaction‚ Cho transferred his gas station to Patten‚ in exchange for the stock of Patten and assumption of the contingent environmental liabilities. The land underneath the gas station has potential environmental problems but Cho did not take any remediation to fix environmental problems
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ORGAN DONATION INTRODUCTION Organ donation is the donation of biological tissue or an organ of the human body‚ from a living or dead person to a living recipient in need of a transplantation. Transplantable organs and tissues are removed in a surgical procedure following a determination‚ based on the donor ’s medical and social history‚ of which are suitable for transplantation. Such procedures are termed allotransplantations‚ to distinguish them from xenotransplantation‚ the transfer of animal
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1. The purpose of this memorandum is to discuss and reflect upon my experiences as a leader with leadership to date. 2. Firstly‚ the characteristics that encompass who I am as a leader today are as follows: conviction‚ integrity‚ consistency‚ direction‚ and empathy. The traits represent facets of leadership by which I extend my command climate and philosophy of credibility and trust. Altogether‚ my philosophy and characteristics encapsulate and reinforce who I am as a leader today. 3. Moreover
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Cohort: Baltic Ocean Team: Baltic Petrels (B2) Team Members: Anesha Agarwal‚ Ana Avelar‚ Nicholas Baladis‚ Clifford Chow‚ Joseph McGovern‚ Rachit Parekh Memorandum – CML19 AOG To: VP of Operations As of January 13‚ 19:30h aircraft CML19 (Boeing 767) has been designated AOG due to a failure in the support assembly (part of the thrust reverser). As a result‚ flight SCL-MIA 067 scheduled for 21:55h will have to be canceled. We have conducted a thorough analysis of all viable strategies‚ and have concluded
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Memorandum To: Senior Management‚ JMZ Adventure Ecotours From: IT Department‚ JMZ Adventure Ecotours Date: 4/20/2013 Re: Information Security Risk Assessment Findings The IT department was recently given the task of performing an information security risk assessment in order to help guide management in prioritizing their approach to mitigating security risks for JMZ Adventure Ecotours. This memo will show the results of that analysis; identifying the greatest IT vulnerabilities and risks within
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Memorandum Date: October 18‚ 2016 To: Candie Cardigan‚ CARDWARE Inc. From: Robyn Broadwater Re: NEGLIGENCE _____________________________________________________________________________ With this memorandum we would like to convey about the new sweater line of cardwares‚ Meaning of the terms utilized by the Restatement is critical. The word "purpose" is used all through the Restatement to imply that the performer covers the results of his or her demonstration or trusts those outcomes are significantly
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MEMORANDUM To: S. Partner‚ C.P.A. From: Nicole J. Badalamenti‚ J. Accountant Date: August 27‚ 2012 Subject: Mr. B. Potato I FACTS Mr. B. Potato‚ a wealthy real estate investor‚ recently purchased a house on a parcel of land for $400‚000. The house was appraised at a value of $300‚000 and the land had an appraised value of $100‚000. Mr. Potato plans to tear down the house and replace it with a new house worth $1‚500‚000 with the intentions of living in
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-versus - PETER PASCUAL Defendant-Appellant‚ x-----------------------------------x MEMORANDUM Defendant-appellant‚ Peter Pascual‚ through counsel‚ in compliance with the Honorable Court’s order‚respectfully submits this Memorandum Prefatory Statement Plaintiff-appellee RAUL GERONIMO and ANNA GERONIMO in the instant case claims‚ with the lower Court’s sanction‚ that there should be an annulment of
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MEMORANDUM To: Scott Haddock‚ Supervising Attorney From: Bob Barker‚ Super Senior Paralegal Re: Paige Turner Our file No.: 12095 Public school searches Date: June 6‚ 2013 I. Issues 1. The issue is whether public school officials have the authority to perform strip searches of students in suspicion of hiding illegal drugs. 2. The issue is whether public school districts can perform random drug screening of students who participate in school athletic programs
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Organ Donation Speech by: Jason Caldwell Good morning‚ my presentation is going to be on the positive aspects of organ donation. First‚ I will explain the background and history of organ donation. Second‚ I will explain the importance of being an organ donor‚ and finally I will talk about the scientific importance of organ donation in our future. Back in the 1950’s‚ the very idea that an organ could be transplanted from one human being to another must have seemed like science fiction. It became
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