Further, the IRS contends that the district court correctly determined that the evidence in the record, particularly regarding the timing of the memos' creation, suggested that they were not created in anticipation of litigation and that this evidence was sufficient to controvert
the "after-the-fact, self-serving statements of Yum personnel involved in planning and executing the transaction.
Currently, the department said, insurers often feel pressured to controvert
cases before they receive all of the relevant information before deadlines expire.
More specifically, the court determined, Greenshields had presented no evidence to controvert
the school board's assertion that the reason for its decision not to reemploy her was her failure to follow administrative directives, including the APIs--not her letters to school administrators and board members or her filing of the first suit.
2d at 1329 ("Even where the feasibility of remedial measures is as apparent as in our case, manufacturers should be deemed to controvert
that feasibility unless they unequivocally admit it.
Now, Jenni could find herself following in their footsteps in the film of controvert
sial Scots authorj Irvine Welsh's novel, Ecstasy.
Even after spending this money, it may still turn into a battle of the experts if the guarantor hires his own expert to controvert
the findings of the creditor's expert.
You can't suddenly decide to controvert
the public's request - it's a violation of our vote.
Dixon novels which advocated full segregation to the extent of African colonization, Griffith's film caused a nationwide explosion over race, alerting white film makers to the danger of overt racism in their films, and galvanizing African Americans to produce films of their own to directly controvert
1, which addresses meritorious claims and contentions, states, "A lawyer shall not bring or defend a proceeding, or assert or controvert
an issue therein, unless there is the basis in law and fact for doing so that is not frivolous, which includes a good faith argument for an extension, modification, or reversal of existing law.
The awkward title (try reading it out loud) and cover (the text is either faux cut and paste or blurry drop shadow) of this book controvert
the challenging and engaging contents, which include writings on such topics as dyke graffiti, the white legacy of second wave feminism and the Prairie School of Union Women.
And, the city did not controvert
the Jennings' summary judgment evidence that sanitary sewage from a sewage line owned and operated by the city flooded their home.
The school physician should be especially active in his contacts with teachers, parents, and pupils to controvert
on every occasion the pernicious, blatant, and intentionally misleading advertising that pours upon teachers, parents, and children from the advertisements in newspapers, magazines, and worst of all -- because it is frequently mixed with interesting and attractive entertainment -- the radio.