of the Act in light of the actual relationship between the affiliated entities. In addition, the adjudicative officer may determine that financial relationships of the applicant other than those described in this paragraph constitute special circumstances that would make an award unjust. (g) An applicant that participates in a proceeding primarily on behalf of one or more other persons or entities that would be ineligible is not itself eligible for an award.

proceeding primarily on behalf of one or more other persons or entities that would be ineligible is not itself eligible for an award. [47 FR 610, Jan. 6, 1982, as amended at 54 FR 53051, Dec. 27, 1989]

(a) FindingCongress recognizes the enduring importance of United States institutions of higher education worldwide— (1) for their potential for shaping positive leadership and new educational models in host countries; and (2) for their emphasis on teaching universally recognized rights of free inquiry and academic freedom. (b

which gain on a sale of the stock would have been assigned (without regard to section 904(d)(2)(A)(iii)(III)). For purposes of §1.904-4(c)(2)(ii)(A), any such loss allocated to passive income shall be allocated (prior to the application of §1.904-4(c)(2)(ii)(B)) to the group of passive income to which

(1) TTB F 5110.25. Except when a letterhead application or letterhead notice procedure is allowed under this subpart, the proprietor must amend the operating permit by submitting an amended form TTB F 5110.25, Application for Operating Permit Under 26 U.S.C. 5171(d). If the changes only affect parts or pages of the application for an operating

entirety, only if— (1) partition in kind of such property among the estate and such co-owners is impracticable; (2) sale of the estate's undivided interest in such property would realize significantly less for the estate than sale of such property free of the interests of such co-owners; (3) the benefit to the estate of a sale of such property free of the interests of co-owners outweighs the detriment

(a) Tax exempt organizations—(1) Trade secrets, patents, processes, styles of work, or apparatus. An organization whose application for tax exemption is open to public inspection under section 6104(a)(1)(A) and §301.6104(a)-1 may in writing request the withholding of information

) [Reserved] §1.469-3T   Passive activity credit (temporary). (a) Computation of passive activity credit. (b) Credits subject to section 469. (1) In general. (2) Treatment of credits attributed to qualified progress expenditures. (3) Special rule for partners and S corporations shareholders. (4) Exception for pre-1987 credits. (c

Cross-reference. See §1.108(i)-1 and §1.108(i)-2 for rules relating to the acceleration of deferred OID deductions. (d) Examples. The application of this section is illustrated by the following examples. Unless

)", amendment was executed by repealing subsec. (b) to reflect the probable intent of Congress in view of catchline for section 211 of Pub. L. 101–382 which read "Repeal of termination date on duty-free treatment under the Act".

contract or permit terminates, regardless of any rights others acquire later under the provisions of the general land laws; and (2) Use and occupy the described lands to the extent necessary for fulfillment of the contract or permit. (b) Users of the lands covered by your materials sales contract or free use permit who acquire their rights later than the date BLM designated the tract for mineral materials disposal will be subject to

(15) Transient gas overtemperature, and number of overtemperature occurrences. (16) Transient engine overtorque, and number of overtorque occurrences. (17) Maximum engine overtorque for turbopropeller and turboshaft engines incorporating free power turbines. (18) For engines to be used in supersonic aircraft, engine rotor windmilling rotational r.p.m.

(d) Separate Motions for Separate Judgments. A moving party who seeks relief from more than one judgment must file a separate motion covering each judgment. (As amended Pub. L. 94–426, §2(3), (4), Sept. 28, 1976, 90 Stat. 1334; Apr. 28, 1982, eff. Aug. 1, 1982; Apr

(a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in a taxable year of the domestic shareholder beginning after December 31, 1964, which is attributable to accumulated profits of the first-tier corporation for a taxable year beginning before January 1, 1976, in which the first-tier corporation was a less developed country corporation (as defined in 26 CFR

be licensed to operate a unicom on the assigned frequency. (c) At an airport where only one unicom may be licensed, eligibility for new unicom licenses is restricted to State or local government entities, and to nongovernmental organizations (NGOs) that are authorized to apply for the license by a State or local government entity whose primary mission is the provision of public safety services. All applications submitted by NGOs must be accompanied by a new

beneficial interests or participations in indebtedness are offered? A-3: In these cases, the owners of the undivided beneficial interests or participations are not subject to this reporting requirement. Instead, the trustee, record owner, or person acting in a similar capacity is treated as the lender for purposes of this reporting requirement and is the party required to report. For purposes of both section 6050J and the applicable penalty provisions, only one return and one statement must be

for $5 million or more in taxes on distilled spirits during the prior calendar year. For the purpose of determining whether the proprietor is subject to this requirement, the proprietor must use the total amount of tax liability on distilled spirits incurred under this part and parts 26 and 27 of this chapter (gross tax liability). Gross tax liability includes the distilled spirits tax on all taxable withdrawals of spirits and taxable importations of spirits, as well as tax on spirits brought into

(a) Establishment and maintenance of account—(1) General rule. With respect to any taxable year beginning after December 31, 1969, any taxpayer who: (i) Has a farm net loss (as defined in section 1251(e)(2) and in paragraph (b) of §1.1251-3) for such a

(a) The airplane must be demonstrated in flight to be free from any vibration and buffeting that would prevent continued safe flight in any likely operating condition. (b) Each part of the airplane must be demonstrated in flight to be free from excessive vibration under any appropriate speed and power conditions up to VDF/MDF