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The Court agreed with the IRS that the assets transferred by the Decedent to two Limited Partnerships were includable in his Estate under 2036(a)(1) because of retained enjoyment of the assets. The Court’s opinion emphasized the lack of any legitimate business factors involved in the formation of the Partnerships and stated that the assets were merely “recycled”. Where there is only a “recycling” that does not appear to be motivated primarily by legitimate business concerns, no transfer for consideration within the meaning of 2036(a) takes place.

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Der Journalist von heute muss in der Lage sein, den gewaltigen Informationsstrom zu bndigen. Das Kuratieren ist ja gerade das, was professioneller Journalismus heute leisten muss. Vertrauensvolle, relevante Information herauszufiltern. And yet it hardly requires a college degree to see that students, let alone teaching talent, would think twice about moving to a state supplying half the country’s GDP of late night satire. Such embarrassment has been the historical constant of Alabama’s “elites,” and they have borne it with exasperation, silence and paralysis. Thus, I was not surprised when of the 27 Auburn and Alabama system officials I contacted a few presidents, along with bankers, industrialists and lawyers on the boards of trustees none would weigh in on the Senate race..

As chief administrative officer, Knutson has led strategic planning for the company’s growing portfolio of television, radio and digital media brands and manages company wide functions including consumer insights, human resources, information technology, outsourcing governance, project management, corporate communications and The Scripps National Spelling Bee. Prior to that role, she served as senior vice president of human resources. She has a bachelor’s in accountancy from Miami University..