The survey included various duties principal must perform with participants indicating the degree to which they found various duties satisfying
. The final survey instrument was pilot tested for ease of use using a small group of principals in the northwest Ohio area via email correspondences.
The leader's responsibility is to find ways of satisfying
their peoples values, in addition to getting people aligned to organizational values.
Hence, enterprises will have far more difficulty satisfying
a "probable" standard in respect of their uncertain state and foreign tax positions.
To qualify for a waiver, a taxpayer must attach a statement to each late return for which a waiver is requested agreeing to cooperate with the IRS upon request in determining and satisfying
the taxpayer's tax liability for that tax year.
The Act also provides a safe harbor method for satisfying
the ACP Test applicable to employer matching contributions.
On the other hand, if C retains sufficient B assets to continue to actively conduct B, its contribution of some of the assets to S should not prevent C from satisfying
the active trade or business requirement.
[sections] 1.162-27(h)(3) treats such previously approved plans and agreements as satisfying
the requirements of Treas.
The 3% QNEC counts toward satisfying
the minimum allocation gateway for cross-testing purposes.
Also, Griffin pointed out he would go out of business if he did not pay the taxes, arguably satisfying
the "direct and proximate" adverse consequences requirement.
IES Industries is thus significant, because it helps taxpayers identify the types of activities that the courts consider important in satisfying
the economic-substance and business-purpose tests.
The IRS and Treasury have not clarified whether a person receiving a substantially nonvested profits interest without satisfying
the three requirements will be treated as receiving a capital (rather than a profits) interest.
7491(c) will prevent the Service from presenting no evidence on penalties against individuals in court, Higbee clarifies that satisfying
the burden-of-production standard appears to require the IRS simply to produce enough evidence to connect the taxpayer's behavior, inadequate evidence, etc., with the particular addition to tax or penalty statute.
this standard will satisfy the language of the statute and the temporary regulations.
However, the discovery test contains two elements; only in developing the new heating element have both been met, thus satisfying
the discovery test.
The IRS has not easily accepted debt instruments as satisfying
the qualified interest requirement.