Examples of PLR Request in a sentence
As a result, the PLR Request was created with an eye toward foreseeable future litigation with the IRS.
While Claimant is not currently laboring under an IRS audit or other tax- related suit, his PLR Request can reasonably be viewed as an attempt to discern the likelihood and magnitude of his future tax liability.
The Parties shall use their respective reasonable best efforts to (i) to file or cause to be filed the PLR Request Submission within ten Business Days of the date hereof and (ii) to ultimately obtain from the IRS the private letter rulings set forth in the PLR Request Submission, unless both Purchaser and the Company mutually agree that the IRS will not grant a favorable private letter ruling related to the PLR Request Submission.
Claimant’s PLR Request was drafted by his counsel for the purpose of seeking a legal opinion from the IRS Office of Chief Counsel concerning the potential tax implications of certain transactions.
The first two benefits are “Preservation of Tax Benefits” and “Joint Submission of the PLR Request to the IRS.” PTAC currently controls the filing of the tax return that includes PTNA.
Response: The Company did not intentionally or inadvertently omit any letterhead from the June 5, 2003 PLR Request.
As noted above, National Grid has structured the PLR Request to strongly advocate the conclusion that Petitioners are seeking.
DeWitt Public Schools then volunteered to be that taxpayer and the 2018 PLR Request was filed.
Settlement Agreement Section I.A.1.c.iv.The Settlement Agreement also provides that no Settling Party shall be deemed to have waived any position in a subsequent case as to whether I&M may recover the costs it incurs associated with the PLR Request.
Where, in the opinion of the Registrar, an applicant is in default in the prosecution of an application filed under this Act or any Act relating to trade marks in force prior to the commencement of this Act, the Registrar may, by notice require the applicant to remedy the default within a time specified and after giving him, if so, desired, an opportunity of being heard, treat the application as abandoned, unless the default is remedied within the time specified in the notice.