were also signed between Yerevan medical center Surb Astvatsamayr and Saint Petersburg childrens hospitals N1 and N19, as well as between Yerevan medical center Grigor Narekatsi and Saint Petersburg maternity home N17.
issued between 1946 and 2013,1 find evidence that memoranda
are increasingly significant, measurable outputs of executive action.
of Understanding concern the cooperation between the two counties in the fields of education, energy and desalination and waste water treatment and reuse, while the Agreement concerns the cooperation on legal affairs.
Avoid writing memoranda
using the question-and-answer format because reading it is tedious, and the opposing attorney likely will challenge the fraud examiner on why he or she asked a particular question but not another.
Although the issuance of these two memoranda
seems to indicate the IRS's willingness to challenge these types of transactions based on multiple statutory and judicial theories, the sustainability of such challenges in a court has yet to be determined.
During the President s meeting with the Emir of the State of Qatar, the Ministers accompanying the President of the Republic signed, on behalf of the Republic of Cyprus, one Agreement and three Memoranda
When the two KPMG memoranda
were not produced, the IRS brought a summons enforcement action in district court.
of May 21, 2003, designating the Secretary of the Army as Executive Agent for the Office of Reconstruction and Humanitarian Assistance, and June 16, 2003, providing for the exercise of that responsibility in support of the CPA, are modified accordingly.
All transactional documents, including agreements, contracts, instruments and schedules and, if the taxpayer's participation in the transaction was promoted, solicited or recommended by any other party, all material received from that other party or that party's adviser(s); --All internal documents or memoranda
used by the taxpayer in the decisionmaking process, including information presented to the taxpayer's board of directors; and --All opinions and memoranda
that provide a legal analysis of the item, whether prepared by the taxpayer or its tax professional.
The Court then examined the landlord's attorney's application and concluded that the hours expended in preparing post trial memoranda
In two of the four offering memoranda
, Vintech also included an "independent accountant's report" (IAR) prepared by the firm, which said the firm had reviewed the forecasted income tax basis statements of income, expense, partners' capital and cash flow for each of the years included in the forecasts.
We also recommend that the memoranda
be published (subject to the standard redaction procedures).
Sequa asserted that the memoranda
were protected from disclosure by the attorney-client privilege and the work-product doctrine.