No Other Arrangements. The Purchaser is not a party to any Contract or arrangement for services that would result, individually or in the aggregate, in the payment of any amount that would not be deductible by reason of Section 162(m), 280G or 404 of the Code. The Purchaser is not a “consenting corporation” within the meaning of Section 341(f) of the Code. The Purchaser does not have any “tax-exempt bond financed property” or “tax-exempt use property” within the meaning of Section 168(g) or (h), respectively of the Code. The Purchaser does not have any outstanding closing agreement, ruling request, request for consent to change a method of accounting, subpoena or request for information to or from a Governmental Authority in connection with any Tax matter. During the last two years, the Purchaser has not engaged in any exchange with a related party (within the meaning of Section 1031(f) of the Code) under which gain realized was not recognized by reason of Section 1031 of the Code. The Purchaser is not a party to any reportable transaction within the meaning of Treasury Regulation Section 1.6011-4.
Appears in 5 contracts
Samples: Acquisition Agreement (Bergio International, Inc.), Asset Purchase Agreement (Elite Data Services, Inc.), Asset Purchase Agreement (Elite Data Services, Inc.)