The closing of the ADS offering and the ordinary
share private placement taking place as part of the global offering will be conditioned on each other.
1221(a) is property held primarily for sale to customers in the ordinary
course of business--the type of property, according to the Tax Court, that Long had sold.
But if the ordinary
man and woman on the street, at home or in their cars swallow the bait and vote for her, what does that matter?
As a result, BAPCPA's revised version of the ordinary
course of business defense applies to the case.
From the beginning of his career Yusuf was interested not only in registering the poetic glow in the ordinary
and the common, but also in portraying the seemingly insignificant.
Training costs must be capitalized only in the unusual circumstances where the training is intended primarily to obtain future benefits significantly beyond those traditionally associated with the training provided in the ordinary
course of a taxpayer's trade or business.
And I can remember, as well, standing on the corner of 52nd Street and Third Avenue on a spring afternoon, six feet from a large citizen gouging the pavement with a jackhammer, and thinking about the Ramones, amazed at the preconscious acuity with which I had translated the pneumatic slap of the hammer into eighth notes and wondering what part, if any, of the pleasures and dangers of the ordinary
world might rightly be considered "natural."
Burnbrae Limited, which is indirectly wholly owned by a trustee of a settlement under which Mellon has a life interest, holds 16,000,000 ordinary shares, representing 17.86 percent of the ordinary
share capital of the company.
Rather, as previously noted, business prudence in the surrounding circumstances determines the ordinary
and necessary nature of the expense.
Regulations section 1.162-2 adds a reasonableness criterion to the ordinary
and necessary business expense: An expense should be reasonable in amount in relation to its purpose.
Among the most confusing and frequently litigated defenses to a preference claim is the ordinary
course of business defense.