Efficiency has been a significant part of Oliver T's
success over the past several years.
355 doesn't otherwise apply, or (3) S distributes T's
stock to its shareholders in a Sec.
The owner, Minneapolis-based Buca Inc., parent company of Buca di Beppo, sold the Vinny T's
chain to Bertucci's Corp.
The group then moved on to perform Stop from their debut album, which really pleased the dedicated Plain White T's
fans among the increasingly vivacious crowd.
Thus, if T is a corporate subsidiary of a selling affiliated group, there may be little if any additional taxable gain to the selling group from the deemed asset sale if the selling parent's basis in T stock is proximate in value to the tax basis of T's
Effect: The election out will be effective for T's
transfers to B in 2006 and for all future transfers to be made by T to B, unless and until T terminates the election out.
As a result of applying the two de minimis rules, slightly over 8% of T's
total receipts were reclassified from non-DPGR to DPGR ($85,000/ $1,045,000).
outside basis in S2 is not reduced by the $25,500 not used.
6672, for T's
failure to pay over more than $1 million in payroll taxes that T had collected from its employees.
P wants to divest itself of T's
In this case, absent T's
decision to transfer, by means of trustee-to-trustee transfers, each daughter's one-half interest in A's IRA X to her beneficiary IRA, as described above, distributions of A's entire IRA would have to be made over B's remaining life expectancy in accordance with Regs.
This election allows P to obtain a stepped-up basis in T's
assets under Sec.