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The further they are in time from the acquisition, the less likely it is they relate
to economic events that existed before the acquisition.
A belief is reasonable only if it is based on the facts and law in existence at the time the tax return including the item is filed and relates
solely to the taxpayer% chances of success on the merits.
emphasis added), the only detailed guidance relates
to the safe harbor provisions.
The amendment provides that the proposed amendments to eliminate from any obligations on the part of EOP Operating Limited Partnership to provide holders of such securities or any prospective investor with information specified in Rule 144A(d)(4) of Securities Act of 1933, as amended, will relate
solely to the 6.
In addition, the proposed regulations require that there be maintained financial and other documents filed with a foreign government entity, independent commission, or financial institution that relate
to transactions between the reporting corporation and the foreign related party.
For this provision to apply, however, a course must relate
to maintaining or improving skills required by the employee's job (rather than meeting the minimum skill level required for the job); further, the education itself must not qualify the individual for a new trade or business.
NSC first asserted that the Supreme Court's opinion in Lincoln Savings imposed, as a necessary condition for the capitalization of any costs, a requirement that the costs relate
to the creation or improvement of a separate and distinct asset.
Expenditures incurred after the point that the product or property (or component of the product or property) meets its basic design spedifications related to function and performance level generally will not qualify as research and experimental expenditures under section 174 unless the expenditures relate
to modifications to the basic design specifications for the purpose of curing significant defects in design, obtaining significant cost reductions or achieving significantly enhanced function or performance level.
6 million (pre-tax) and relate
primarily to (1) stock option grant measurement date errors from December 1996 through February 2001 ($17.