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If the transferor has substantial assets other than the claim, it seems reasonable to assume no corporation would be willing to acquire all of its properties in the dim hope of collecting a claim for refund of taxes.
from Brown Corpus
Some Related Sentences
If and transferor
If it were not for judicial development of certain exceptions, this section would prohibit a suit for refund by an acquiring corporation for taxes paid by a transferor corporation, even though the reorganization meets the requirements of section 381(a).
If section 444AA does not apply, an accounting period of the transferor company ends with the day of the transfer.
If section 444AA applies, an accounting period of the transferor company ends immediately before the transfer, and the transferor also has an accounting period covering the instant of the transfer ( except for the purposes of calculating the equalisation provision for tax purposes ).
If and has
If Wilhelm Reich is the Moses who has led them out of the Egypt of sexual slavery, Dylan Thomas is the poet who offers them the Dionysian dialectic of justification for their indulgence in liquor, marijuana, sex, and jazz.
If any one of them has any power to veto the Secretary General's decisions the nature of the organization will have changed.
If this new Bible does not increase in significance by repeated readings throughout the years, it will not survive the ages as has the King James Version.
If this capacity had not failed them, they would see that their enemy has made a disastrous miscalculation.
If the new Soviet series has followed the general pattern of previous Russian tests, the shots were roughly half fission and half fusion, meaning a fission yield of 30 to 40 megatons thus far.
If the superintendents do not receive more cooperation from Handlers, it has been suggested that licensed Judges also be qualified to judge this Class.
If your state has no provisions for the numbering of pleasure boats, you must apply for a number from the U.S. Coast Guard for any kind of boat with mechanical propulsion rated at more than 10 horsepower before it can be used on Federal waterways.
If we manage to keep track of a Bombus queen after she has left her feeding place, we may discover the snug little hideout which she has fixed up for herself when she woke up from her winter sleep.
If cell Af has not previously been assigned as the information cell of a form in the text-form list, it is now assigned as the information cell of Af.
If of the founders of glottochronology Swadesh has escaped our steady plodding, and Lees has repudiated his own share in the founding, that is no reason why we should swerve.
If the patient can perceive figure kinesthetically when he cannot perceive it visually, then, it would seem, the sense of touch has immediate contact with the spatial aspects of things in independence of visual representations, at least in regard to two dimensions, and, as we shall see, even this much spatial awareness on the part of unaided touch is denied by the authors.
If the distant patron of the suburban branch has been frightened away from downtown by traffic problems, however, the city store can only pressure the politicians to do something about the highways or await the completion of the federal highway program.
If she has not had such experiences, the female's normal adolescent degree of indecision will be compounded.
If the change, at first sight, seems minor, we may recall that it took the Italian painters about two hundred years to make an analogous change, and the Italian painters, by universal consent, were the most brilliant group of geniuses any art has seen.
If Barnett doesn't call a special session in 1961, it will be the first year in the last decade that the Legislature has not met in regular or special session.
If the church has followed the plan of cultivation of prospects and carried through a program of membership preparation as outlined earlier in this book, the process of assimilation and growth will be well under way.
If and substantial
If this woman had delayed until after 11:20 to start her shopping, she would have had little time in which to prepare the substantial meal that was eaten at dinner in those days.
If we add to these contacts with friendly members the `` contacts with an organization of the church '' ( 11.2 per cent of the cases ), then a substantial two thirds of all recruitment is through friendly contact.
If there is a substantial difference between characters ' ranks, the conflict is generally over before the weaker character can react.
If we examine only funds that have survived to the present, we will overestimate past returns because many of the worst-performing funds have not survived, and the observed association between fund youth and fund performance suggests that this bias may be substantial.
If the user has built up a substantial charge, the discharge can jump around the door's edge or pass through the door itself ( dielectric breakdown ).
If the court finds that presented evidence is not sufficient to support the charges or that a motion to render a judgment without substantial consideration of a case is submitted in violation of the requirements stipulated by the Criminal Procedure Code of Georgia, it shall return the case to the prosecution.
If the lex loci arbitri has been ignored, but there was no real and substantial connection between the place of arbitration and the agreement made by the parties, a court in which enforcement is sought may well accept the tribunal's decision.
" I do not refer to real estate, or to personal property or to cold cash, but rather to that in life which tends to make these tangible substances count for most in the daily lives of people, namely, goodwill, fellowship, mutual sympathy and social intercourse among a group of individuals and families who make up a social unit … If he may come into contact with his neighbor, and they with other neighbors, there will be an accumulation of social capital, which may immediately satisfy his social needs and which may bear a social potentiality sufficient to the substantial improvement of living conditions in the whole community.
If the IRS determines that a third-party intermediary firm's worker previously treated as self-employed should have been classified as an employee, the IRS assesses substantial back taxes, penalties and interest on that third-party intermediary company, though not directly against the worker or the end client.
If most of the time the substantial portion of the references aggregate into clusters, and if the shape of this system of clusters can be well predicted, then it can be used for speed optimization.
If such an earthquake were to occur, Fialko's study stated, it would result in substantial damage to Palm Springs and a number of other cities in San Bernardino, Riverside and Imperial counties in California, and Mexicali municipality in Baja California.
If, for example, potential business class customers will pay a large price differential only if economy class seats are uncomfortable while economy class customers are more sensitive to price than comfort, airlines may have substantial incentives to purposely make economy seating uncomfortable.
If there is the potential for a substantial harm to occur that is permanent in nature, such as the execution of a death penalty or the deportation of a person who could face torture, then the author of the complaint can request that it be greeted with Urgency.
If there is a " substantial change " in the database which would be qualified as a " substantial new investment ", a new protection period is granted for the resulting database.
If a substantial amount of matter far from the center of the galaxy that is not emitting light in the mass-to-light ratio of the central bulge is assumed, the rotation curves can be explained.
If finished, the castle would have been able to host two substantial households and their followers, for example the king and queen, or the king, queen and a prince and his own wife.
If a reasonable person in the defendant's position would apprehend the substantial certainty of the consequences of his actions, whether the defendant intended to inflict the injuries is immaterial.
If this happened, it would make Molineux one of the largest stadiums in England providing there are few relocations or substantial expansions by other clubs in the meantime.
If substantial envenomation occurs, symptoms will generally occur within minutes and progress rapidly.
If seeking returns, it is advisable to get to the box office in the early morning hours, as there is invariably a substantial queue.
Heche's first substantial role was in a segment of the 1996 made-for-cable anthology film If These Walls Could Talk, in which she played a college student contemplating an abortion.
If substantial numbers of ONS staff are unwilling to relocate, the loss of skilled individuals could have a severe impact on a range of statistics.
If, for instance, we compare this system with that of Valentinus, we discover at once so much agreement in essential features as to assure us of the substantial identity of the foundation of the two systems ; but the Valentinian system contains several things derived from Greek philosophy, whereas that which we have described can be explained from purely Oriental sources.