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Absence Of Oath Rendered Petition Invalid
July 15, 2025
Petitioner filed a petition...in the Trial Court challenging tax assessments against him. Petitioner failed to timely sign his petition under penalty of perjury. The Trial Cour...

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Downstairs Merger Of Holding Company Satisfies "COBE"
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ACQ is a holding company for subsidiaries engaged in a variety of businesses. T is engaged in business as a partner in a partnership (PS). T has outstanding "d" share...
"Qualified Tangible Property" Must Have A Situs On "The Site"
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G possessed an ownership interest in GDC LLC, which in turn owned an 80 percent interest in HSC LLC On April 10, 2014, HS LLC transferred t...
Valid Notice Of Deficiency Was Not Issued
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On January 23, 2023, the I.R.S. issued petitioner a Notice of Deficiency for tax year 2020. Petitioner's last known address when the No...
Can An "All-Stock" Acquisition Constitute A "Qualified Stock Purchase?"
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Royal Gold, Inc., ("RGLD"), a domestic subchapter C corporation, recently announced it had entered into an agreement to acquire Sandstorm Gold, Ltd., ("SAND"...