While CSC Grodt
is at the helm, Ernestine Pitchford is the glue that holds it all together.
We saw this as any opportunity for businesses to bless this baby,'' Grodt said.
1) William Francis Martin IV, first baby born at Simi Valley Hospital in 2000, snoozes before a limousine ride home Monday while his mom, Meagan, gets a hug from licensed vocational nurse Tammy Grodt.
Based on the Grodt factors, the majority held that the loan constituted a sale of the shares in 2001 because:
However, Judge Halpern asserted in his concurring opinion that the Grodt factors were inappropriate to determine whether the loan constituted a sale of the shares.
Judge Holmes, in his concurring opinion, agreed with Judge Halpern that the Grodt factors were inappropriate.
First, should the Grodt factors be used in determining the owner of the shares?
The IRS position in the CIP is based on Grodt & McKay Realty, Inc.
Benefits-and-burdens test: In determining whether the leasehold improvements were owned by the tenant or the landlord for Federal tax purposes, the IRS applied the benefits-and-burdens-of-ownership test outlined in Grodt & McKay Realty, Inc.