of property ownership are held at all times from the acquisition date until the transfer date by an EAT that is not the taxpayer or a disqualified person.
of the property's ownership is held by a person (the EAT) who is not the taxpayer or a disqualified person, and either such person is subject to Federal income tax or, if such person is treated as a partnership or S corporation for Federal income tax purposes, more than 90% of its interests or stock are owned by partners or shareholders subject to Federal income tax.
The bold "bulk rate" indicia
gives away the game that it isn't a bill or personal correspondence.
The court said that indicia
of actual authority or ability to pay the taxes owed (in view of an employee's status within a corporation) include whether the employee:
Lee McFadden, of Mosaic Media Inc., mirrors many newsletter publishers when he reports, "Clearly, both our b-to-b prospects and existing customers are opening their mail, and I suspect it's because it looks like advertising mail--preprinted Standard Rate indicia
, commercial-sounding tease, window envelope, return address (usually with our logo, but sometimes not).
These are indicia
of comprehensive consolidated supervision; no single factor is essential and other elements may inform the Board's determination.
& Tax Code [sections] 25120(a), income is business income if it arises "from tangible and intangible property if the acquisition, management, and disposition of the property constitute integral parts of the taxpayer's regular trade or business operations." The court held that "acquisition, management and disposition" of an asset are intended to represent the indicia
of owning corporate property.
of independent appearance are clear-cut.
(IBM), 517 US 843 (1996), the Court stated that the HMT bears the indicia
of a tax: it is described as such by Congress and was enacted as part of the Code.