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Reports of United States Tax Court, V. 141, July 1, 2013, to December 31, 2013

Author : Government Publications Office
Publisher : Government Printing Office
Page : 608 pages
File Size : 17,6 MB
Release : 2015-02-15
Category :
ISBN : 9780160926464

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Volume of the United States Tax Court Reports containing case abstracts and opinions of the court regarding cases between July 1, 2013 December 31, 2013. Cases in each volume are listed in the prefatory table. The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to "constitute Tribunals inferior to the Supreme Court. “The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule”).” Contents 8 Findings of Fact 8 Background 8 John Hancock’s History9 Investment Process and Review10 Leasing10 LILO and SILO Transactions 10 Basic Structure 15 History 17 Due Diligence 18 The Hoosier Transaction 19 The LILO Test Transactions 20 OBB LILO20 Lease and Sublease23 End of Sublease Term25 SNCB 2 and SNCB 5 Lot 1 LILO Transactions25 Lease and Sublease28 End of Sublease Term 28 The SILO Test Transactions 29 TIWAG29 Lease and Sublease33 End of Sublease Term35 Two Dortmund Transactions35 Lease and Sublease38 End of Sublease39 SNCB SILO39 Grant and Subgrant42 End of Subgrant Term 43 Tax Returns, Notices of Deficiency, and Trial 43 Procedural History48 Trial 53 Opinion 53 Burden of Proof53 Principal Place of Business54 Leveraged Lease Transactions54 Frank Lyon58 LILO and SILO Litigation 77 The Test Transactions 78 Economic Substance79 Objective Inquiry88 Subjective Inquiry89 Substance Over Form91 OBB and SNCB LILO Transactions110 SILO Test Transactions 145 Interest Deductions 147 Original Issue Discount 149 Transaction Expenses 149 Conclusion NOTE: NO FURTHER DISCOUNTS FOR ALREADY REDUCED SALE ITEMS. Keywords: tax court reports, reports of the united states tax court, u.s. tax court reports, united states tax court reports, united states tax court, u.s. tax court, tax court

American Art Directory

Author : Florence Nightingale Levy
Publisher :
Page : 1160 pages
File Size : 15,88 MB
Release : 1917
Category : Art
ISBN :

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Firepit Barbecue

Author : Ross Dobson
Publisher : Allen & Unwin
Page : 384 pages
File Size : 29,38 MB
Release : 2022-04-14
Category : Cooking
ISBN : 1761063472

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Expert tips and easy recipes for creating delicious food on your firepit barbecue. Fire up the firepit and let's get barbecuing. As an experienced chef and food writer - and a dab hand with the barbie tongs - Ross Dobson knows a thing or two about cooking with fire. In this book his recipes are especially tailored to creating great meals on a firepit with a simple grill or hotplate. Ross shares tips on the best wood to use, foolproof instructions to tame the flame and make the heat last, advice on how to prepare food for the grill, marinades for tenderising and adding flavour, plus ideas for delicious butters, salsas, dips and breads. Over 90 recipes, for chicken, fish, pork, beef, lamb, vegetarian meals and vegetables, are simple to prepare, fun to cook and perfect for your firepit barbecue... Whether it's fragrant chicken parcels for a healthy midweek family dinner, whole trout with lemon and dill for Sunday lunch, or spicy beef kebabs for a cruisy Friday night feast with friends. That's cooking with fire!

Library List

Author : National Agricultural Library (U.S.)
Publisher :
Page : 172 pages
File Size : 30,22 MB
Release : 1968
Category : Agriculture
ISBN :

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Newsweek

Author :
Publisher :
Page : 1054 pages
File Size : 36,16 MB
Release : 1961
Category :
ISBN :

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Jeff Wall and the Concept of the Picture

Author : Naomi Merritt
Publisher : Routledge
Page : 324 pages
File Size : 20,61 MB
Release : 2020-12-30
Category : Photography
ISBN : 1000182703

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This book grapples with fundamental questions about the evolving nature of pictorial representation, and the role photography has played in this ongoing process. These issues are explored through a close analysis of key themes that underpin the photography practice of Canadian artist Jeff Wall and through examining important works that have defined his oeuvre. Wall’s strategic revival of ‘the picture’ has had a resounding influence on the development of contemporary art photography, by expanding the conceptual and technical frameworks of the medium and introducing a self-reflexive criticality. Naomi Merritt brings a new and original contribution to the scholarship on one of the most significant figures to have shaped the course of contemporary art photography since the 1970s and shines a light on the multilayered connections between photography and art. This book will be of interest to scholars in the history of photography, art and visual culture, and contemporary art history.

Picture Perception in Animals

Author : Joel Fagot
Publisher : Psychology Press
Page : 464 pages
File Size : 48,1 MB
Release : 2013-06-17
Category : Psychology
ISBN : 113495137X

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Animal researchers commonly present pictures to their subjects, usually birds or monkeys, in order to infer how natural objects are perceived and conceptualised, or to discover the brain mechanisms underlying these abilities. This unique book questions the premise of this experimental approach and asks whether or not pictures can be considered as ecologically valid and realistic stimuli for animals. Leading researchers in comparative psychology and neuroscience address such questions as: "Can animals recognise objects of scenes in pictures despite variations in viewpoints?; "How do animals perceive faces?" and "Is there an equivalence, in animals' minds, between pictures and the objects they represent?". The result is an authoritative and cutting-edge survey of current knowledge in the field, which underlines the advantages, limits and risks of using pictures to infer cognitive abilities or brain mechanisms in animal studies. Picture Perception in Animals will be essential reading for comparative psychologists, anthropologists, and neuroscientists working in picture perception.

Big Picture, Small Screen

Author : John Hill
Publisher : Indiana University Press
Page : 284 pages
File Size : 32,91 MB
Release : 1996
Category : Art
ISBN : 9781860200052

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This work features contributions from academics and media professionals who ask: what is the history of involvement between film and television in the US, Europe, Britain and Ireland; what are the sources of television finance for film; and what are the consequences for the type of film made?