For this reason, the national office should use the version of the facts developed by the examination team when advising it, and stop the time-consuming practice of issuing
two TAMs--one based on the examination team's facts and one based on the taxpayer's facts.
It must be concluded that lenders issuing
mortgage loans in New York have a legal obligation not to close the loan unless there is a final certificate of occupancy or, if a temporary certificate of occupancy is in effect, that enough money is held in escrow to insure the outstanding work can be completed and paid for within the time set forth in the temporary certificate of occupancy.
cards instantly increases customer service, card sales and revenue, and eliminates current card issuance costs.
These COI regulations are designed to prevent changes in market value from causing an otherwise tax-free transaction to become a taxable transaction in which the target shareholders are subject, by reason of a binding contract, to the economic fortunes of the issuing
corporation as of the date the binding contract is entered into by the relevant parties.
She asked whether LMSB anticipates issuing
standard information document requests (IDRs) to request taxpayers' section 404 documentation.
Similarly, for those running a life insurance company, a primary focus must be on issuing
profitable new business.
Increasing comprehension on the part of the lending institutions has made them more amenable to viewing environmental concerns as a manageable issue, within the context of a transaction, and not as an automatic impediment to issuing
I now believe the FASB wasted a lot of time and effort issuing
statements that merely extracted AICPA literature.
They note that issuing
stock for less than its current market value, as happens when an employee stock option is exercised, dilutes the value of the other stockholders' holdings.
The IRS and Treasury Department anticipate issuing
temporary and proposed regulations under [section] 1.
37 is important for tax practitioners issuing
written advice that is not a covered opinion.
First, we are uncertain whether the IRS has made the case for mandatory e-filing and, more important, for issuing
the guidance in the form of immediately effective temporary regulations (albeit for returns filed in 2006).
Specialists will meet with the taxpayer before issuing
IDRs to ensure that they are clear and the information being requested is appropriate.