Examples of Midcoast in a sentence
See also, Midwestern Gas Transmission Co., 116 FERC ¶ 61,182, at P 42 (2006); Southern Natural Gas Co., 76 FERC ¶ 61,122, at 61,635 (1996), order issuing certificate and denying reh'g, 79 FERC ¶ 61,280 (1997), order amending certificate and denying stay and reh'g, 85 FERC ¶ 61,134 (1998), aff'd Midcoast Interstate Transmission, Inc.
Midcoast Health Services no longer operates a hospital at this location.
Or as the tax court put it, the “record is replete with notice to [the shareholders] that [Midcoast] never intended to pay Woodside Ranch’s [f]ederal income tax liability.”Accordingly, we conclude that the tax court did not clearly err in finding the shareholders liable for Woodside’s tax debt under sections 242.04(1)(b) and 242.05(1).
The Q1 2021 transactions relate to management fee paid to majority owners for advisory services to the group.
Finally, the loan receivable posted on Woodside’s books was (to use the tax court’s words) “a mere accounting device, devoid of sub- stance.” Neither Midcoast nor Shapiro owed Woodside anything, and the loan receivable was later marked “paid” without a cent changing hands.
Moreover, Midcoast drained most of the remaining cash from the corporation within four days of the closing.26 Nos.
If there is a breach of the agreement by Midcoast, or if it defaults on the agreement, then all rights to any structures are vested in Bi-State.
The court noted that from the beginning, Midcoast had characterized the transaction as a “no-cost liquidation.” Woodside had no active business at the time of the transaction.
At trial the parties stipulated that although the shareholders “knew or should have known that Midcoast intended to claim a loss to offset the gain on the asset sale, they did not know and had no reason to know that respondent [IRS] would characterize it as an abusive tax shelter and/or disallow the loss.” As we explain in the text, under the constructive-fraud provisions of the Wisconsin UFTA, whether the shareholders knew the scheme was illegal or fraudulent is irrelevant.24 Nos.
Represents calculation retrospectively reflecting the affiliate capitalization of MEP consisting of 4.1 million MEP Class A common units, 22.6 million MEP subordinated units and MEP general partner interest upon the transfer of a controlling ownership, including limited partner and general partner interest, in Midcoast Operating.