In essence, Bankers Trust argued that the board's liens did not survive the foreclosure sale and are extinguished if there are no excess proceeds
from the sale to pay the past due common charges due.
All the proceeds
" could have been defined as (1) all the proceeds
attributable to Target's D business, (2) all the proceeds
attributable to Target's D business plus those proceeds
attributable to F-Sub's D business,(7) (3) all the proceeds
attributable to both Target's C and D businesses, or (4) all of the proceeds
attributable to Target's C and D businesses plus those proceeds
attributable to F-Sub's C and D businesses.
AFC then went out to their capital sources who provide mezzanine financing, and was able to raise an additional $3 million in proceeds
priced at 9.
None of the proceeds
of A's IRA will be includible in C's gross income if C timely rolls them over into his own IRA.
Unlike the policy underlying domestic equitable sharing, there is no statutory or regulatory authority by which the United States can insist that a foreign country use shared property or proceeds
in any particular manner or allocate them to any particular government component.
However, as the investigation continues, the potential for asset seizures greatly decreases as the subject spends the proceeds
, launders the money, and hires attorneys to defend civil and criminal lawsuits.
However, receipt of the proceeds
was in dispute and therefore not recognizable until later.
Street's daughter (co-administrator of the estate) contested the wife's claim to any portion of the life insurance proceeds
on the grounds that the decedent was the sole owner of the policies and had specifically named his estate as beneficiary.
This downgrade is a result of the CBO's insufficient ability to generate interest and principal proceeds
to fully pay interest and principal on the A-2 notes going forward.
from a sales transaction into escrow does not guarantee that a cash-basis taxpayer can use installment reporting.
Cash basis taxpayers still may deduct points on home improvement loans under section 461(a)(2) if they carefully substantiate that the points represent interest prepaid with funds that are not loan proceeds
6045(f) was added to the Code by Section 1021 of the Taxpayer Relief Act of 1997 (TRA '97) and requires the information reporting of gross proceeds
paid in the course of a trade or business to attorneys in connection with legal services.
must be invested in specialized small business investment companies (SSBICs), which are partnerships or corporations authorized by the Small Business Administration to invest in small businesses owned by minority groups and economically disadvantaged individuals.
The downgrade is the result of undercollateralization and limited interest revenues, combined with the diversion of principal proceeds
to the interest due on the second priority senior notes.
In a reversal from its previous positions in letter rulings, the IRS--in as-yet-unnumbered Technical Advice Memorandum (TAM)--has ruled that proceeds
from the sale of unallocated shares held in an employee stock ownership plan's (ESOP's) suspense account resulting from the sale of company stock will be considered earnings and will not constitute Sec.