The lender of any debt on the property or any debt incurred to acquire an undivided interest
in the property may not be related (as previously defined) to any co-owner, sponsor, manager or lessee.
For valuation purposes, a decedent's undivided interests
in certain real properties held in trust were not aggregated with similar interests held in a QTIP trust.
If the buyer and seller wait a sufficient amount of time to contribute their undivided interests
in the business assets to the partnership (and they had no plans to do so at the time of the original asset sale), the partnership may be able to amortize a portion of the buyer's pre-1993 intangibles under the unrelated transaction exception to the anti-churning rules previously discussed.
The undivided interest
method is not a specifically identified method in the final regulations because it appeared to have limited application.
The second exception is for distributions of an undivided interest
Further, the IRS stated that the husband's continued occupancy would not be considered an acceptance of the one-half undivided interest
he was seeking to disclaim; his continued occupancy arose by virtue of his continuing ownership of his one-half undivided interest
in the home, not by virtue of accepting the benefits of the disclaimed interest.
After extensive due diligence, we have identified a very unique opportunity to acquire undivided interests
in multiple oil leases throughout Utah, Texas and Oklahoma," stated Thomas Aliprandi, CEO of PrimeHoldings.
owns 100% of the undivided interest
in the Bissett Creek Graphite patented mineral lease, containing a resource of 640,000 tons of flake graphite on 10% of the patented mineral lease that has been drilled to date.
TSX Venture: ESK) to acquire up to a 60% undivided interest
in the SIB project, located in British Columbia, Canada, the company said.
Weststar") regarding an option to earn up to a 80% undivided interest
in the Diego property composed of 53 mining claims (the Property ).
Stockholders own a current, undivided interest
in the net assets of the corporation.
Affirming the dismissal in an opinion by Judge Wallace, the Ninth Circuit noted that Ford and Citibank did not contend that any plaintiff had an individual damages claim exceeding $75,000, that the individual claims could be aggregated, or that the individual plaintiffs had a common and undivided interest
in a claim for damages.