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8 Aug 2006, 4:23 pm
Some of the observations/conclusion made by the Court: -The same debt vs. equity considerations apply in regard to partnerships as they do in the corporate area; -The debt vs. equity examination should be conducted based on the "all-the-facts-and-circumstances" test of Culbertson, 337 U.S. 733, 742 (1949) (which it is easier for the IRS to prevail under) than applying the sham transaction doctrine (which requires the IRS to show that the taxpayer's characterization is… [read post]
4 Aug 2006, 4:25 pm
Therefore, the majority set aside the election held Dec. 2, 2004, which resulted in 6 votes for and 9 against, Teamsters Local 337; and directed a second election. [read post]
24 Jul 2006, 3:48 am
Rev. 319-337 (2006). [read post]
10 Jul 2006, 4:52 pm
Indeed, as Judge Small (who also decided In re Paschal, 337 B.R. 274, which previewed this issue as discussed here) noted: "Once again, warily, and with pruning shears in hand, the court re-enters the briar patch that is s. 362(c)(3)(A). [read post]
10 Jul 2006, 4:52 pm
Indeed, as Judge Small (who also decided In re Paschal, 337 B.R. 274, which previewed this issue as discussed here) noted: "Once again, warily, and with pruning shears in hand, the court re-enters the briar patch that is s. 362(c)(3)(A). [read post]
16 May 2006, 2:05 pm
In addition to the 337 action, Creative has filed a lawsuit in California seeking both an injunction and damages for willful infringement of the Zen Patent. [read post]
13 Mar 2005, 1:09 am
[JURIST] The Spanish Interior Ministry [official website in Spanish] said Saturday that it had arrested some 41 people, including seven lawyers, for money laundering of some $337 million that may have involved funds from troubled Russian oil company Yukos [corporate website; JURIST Hot Topic news archive]. [read post]
6 Jan 2005, 1:49 am
On December 16, 2004, FANUC Robotics America, Inc. of Rochester Hills, Michigan filed a "Section 337" unfair import complaint at the U.S. [read post]
