ITOBA SSA Fillies - Betcha (Sangaree - Broken Embrace) bred by Elliott Ventures owned by Southwest Racing Stable Inc. Swifty Farms Inc Swifty Oil Swifty Oil Co Swifty Service Station Swifty Gas Primary Industries Hospitality Restaurants Agriculture Animals & Livestock Contact Information Headquarters 351 S Us Hwy 31, Seymour, Indiana, 47274, United States (812) 523-3805 Revenue 6. Shelby County Stakes - Pretty Assets (Caiman - Utesa) bred/owned/trained by R. Jason Johnson controls and operates multiple subsidiaries which include entertainment, clothing, TV. William Henry Harrison Stakes - Double Tuff (Skylord - Icey Energy) bred by Gary Simms owned by Willowbrook Stables LTD & Jerry Carden trained by Kim Hammond Swifty Farms is a multi-million dollar revenue corporation. Indiana First Lady Stakes - Wellington Wonder (Warrior’s Reward - Wellington Avenue) bred by Swifty Farm owned by Jerry Romans, Charlie Spring, Zoom & Fish Stable, Inc. Governor's Stakes - Flatter Hymn (Flat Out - K C’s Songofprayer) bred by Sugarland Thoroughbreds owned by New Farm trained by Jeff Runco Snack Stakes - Strong Tide (English Channel - Dreamin Big) bred/owned by Penny & Michael Lauer trained by Michael Lauer Transcribed image text: On October 1, 2025, Swifty Equipment Company sold a pecan-harvesting machine to Valco Brothers Farm, Inc. News & Updates from the Thoroughbred Breed Development ProgramĬongratulations to the connections of these 2020 Restricted Indiana Stakes Winners:Įllen's Lucky Star Stakes - Nothinbutflowers (Violence - Sky Mystic) bred/owned by: Dennis Farkas trained by Jeff Greenhill
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There are various pricing methods available in the regulations under IRC I.R.C. Generally, allocations have been upheld by the courts unless the taxpayer can demonstrate that the IRS determination was arbitrary and capricious. Section 482 may apply where an allocation is necessary to:Īllocations affecting taxable income can be made to income, deductions, credits and other allowances. The regulations further provide that, “A presumption of control arises if income or deductions have been arbitrarily shifted.” Reallocation to Clearly Reflect Income The reality-not the form-of the control is decisive In addition, where two or more taxpayers act in concern or with a common goal or purpose, it may be sufficient to constitution “control” within the meaning of section I.R.C. § 482, whether the control is legally enforceable or not. That definition provides that any kind of control, direct or indirect, may give rise to “control” within the meaning of section I.R.C. § 482-1(i)(4) provides a broad definition of what constitutes control. What Is “Control” For Section 482 Purposes? The arm’s-length standard applies to outbound and inbound transactions. Section 482 encompasses the so-called arm’s-length standard. § 482 envisions three basic requirements before it applies:ġ) Two or more organizations, trades or businesses Ģ) common ownership or control, either directly or indirectly andģ) An IRS determination that an allocation is necessary either to prevent evasion of taxes, or to clearly reflect the income of the entities. Section 482 allows the IRS to make adjustments and allocations in order to ensure that transactions clearly reflect income attributable to controlled transactions and to prevent the evasion of taxes. When Does Section 482’s Arm’s Length Standard Apply? § 482 provides the IRS with the authority to make adjustments by reallocating items of gross income, deductions, credits, or allowances in order to properly reflect income between the entities. If the transfer price is not arm’s length, section I.R.C. This is, in essence, the “arm’s length standard,”-the price of the product that Parent charges its CFC should be the same as it would charge to an unrelated party for the same product under similar circumstances. § 482, controlled entities should price transactions in the same way that uncontrolled entities would under similar circumstances. § 482 requires Parent to sell that product at an arm’s length price to its CFC. For example, when a US parent (Parent) sells a product to its controlled foreign corporation (CFC), I.R.C. The concept of “transfer pricing” relates to the pricing of transactions between controlled entities. Again, this is a bargain made at arm’s length even if the price paid is not the ‘market value’ of the asset.Section 482 and the Arm’s-Length Standard There has been a bargain with both people trying to get the best deal for themselves. Mr T, who is an art dealer, knows that the picture is worth £5,000. For example Mrs S may sell a picture from her attic to Mr T for £500. It was a bargain made at arm’s length.Īnother example where a bad bargain could nonetheless be a bargain made at arm’s length is where one party to the transaction has better information about the asset than another. This may not have been the best possible price which Mr A could have achieved if he had left the property on the market for longer but he was still trying to achieve the best deal possible for himself. Mr B knows that Mr A wants to sell his property quickly so he offers him a low price for a quick sale. For example Mr A may wish to sell his property quickly so that he can go and live in Malta. 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I'm driving with it now and it's fine: no sounds or decreased performance, but I'm looking at $2200 plus to have it (and the other front) replaced. Also, the spring is broken in my front right sheared right in half. Since I bought the car I have had to replace- Brakes, rotors ($800), new key fob ($425), gear shift spring broken ($800), fob insert detector ($600), rear ball joints ($1200). Most mechanics will not work on them as the software required is incredibly expensive for them to purchase. The double sun roofs bring tons of natural light into the car and the visibility is excellent. It's so comfortable and the way it handles has me weary to ever let the car go. Off road, this car is a beast! Even without mudding tires I have never had a … moments hesitation, from knee deep mud to deep snow to off roaring on the side of a mountain. I have the cold weather package and the seats warm up so fast and the defroster a for the windshield and rear are quick as well. The Good- This car is my personal listening room the sound system is incredible, one of the best I've ever heard in a car. Maximum capacity is only 59 cubic feet, but the rear seats do fold completely flat (though the seat-bottom cushions must be folded up separately).īought in 2012 with 94,000 miles. Cargo space behind the rear seats is a bit small at 27 cubic feet due to the LR2's high cargo floor. The backseat has ample room as well, but the low-mounted bench compromises comfort for adults. The LR2's front seats offer plenty of legroom and headroom, and the steering wheel's wide range of telescope adjustment makes it easy to find a comfortable driving position. Cupholders and storage slots are sprinkled liberally throughout the cabin. Although the climate and audio controls are clunky to use at first, the optional navigation system's touchscreen interface couldn't be simpler. Materials are average in quality and the overall look isn't very elegant, and the busy instrument panel is a little hard to read at a glance. The LR2 has an unmistakable Land Rover feel to it, which means plenty of leather and wood to go around, plus a traditional upright seating position and a utilitarian control layout with numerous buttons. Accordingly, we think most compact luxury SUV shoppers will be happier with an X3, EX35 or RDX than they will with the 2008 Land Rover LR2. But these competitors provide better performance, sportier handling, higher-grade interiors and more in the way of overall refinement. To its credit, the LR2 does have more off-road capability and a more forgiving ride than firmly tuned rivals like the Acura RDX, BMW X3 and Infiniti EX35. Inside, its cabin looks more utilitarian than it does elegant, and materials are unimpressive for a premium-brand sport-utility. Among the LR2's flaws are soft handling on pavement and just-adequate acceleration. However, as small luxury SUVs go, Land Rover's latest is not the ultimate on-roader. During our testing of a 2008 Land Rover LR2, Terrain Response proved its worth as the LR2 scaled rutted dirt trails with considerably more gusto and poise than most car-based sport-utilities. Each mode specifies different settings for the engine, transmission, center differential, suspension, traction and stability control system and hill descent control system. Among them are a healthy 8.3 inches of ground clearance, standard all-wheel drive, and Land Rover's Terrain Response system, which provides four driver-selectable modes tailored for varying terrain. In addition, this all-new LR2 still packs enough tools to handle light- and even medium-duty off-highway trails. The resulting lightweight unibody construction, all-independent suspension, and new inline six-cylinder engine make this the easiest Land Rover to drive in history, while leather seats, wood trim, dual sunroofs, and room for four are meant to keep the brand's upscale luxury image intact. As a replacement for the now discontinued Freelander, the 2008 Land Rover LR2 comes to life with lots of mechanical DNA from parent company Ford's Volvo S40 and European-market Ford Focus. Land Rover clearly designed its new LR2 compact SUV for a life on pavement, but the company tried to preserve a modicum of off-road capability in the process. For a prime example of this shift in philosophy, look no further than the 2008 Land Rover LR2. More recently, the company's vehicles have been increasingly able to provide on-road comfort and performance as well. 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Personally, I always prefer to stay within the same company's software, but if creating PDFs or printing to PDF is important to you (and 'saving to PDF' as from within MS Office applications isn't an option), that may be the way to go for the time being. For what it's worth, I assume you did manage to find the link to PDF Creator v.11? If not, I would suggest that one of the moderators put a direct link in this forum for both x86 and 圆4 versions until such time that the issue is resolved for the full Nitro Pro 13.Įven so, when installing the stand-alone PDF Creator, things went perfectly smooth in my case: the v.11 software was installed next to the full Nitro Pro v.13 package there were no error messages or references to an existing account or anything.Īs yet another alternative, you may want to try another brand's PDF creator until Nitro has resolved things: Until I came across Nitro's stand-alone v.11, for a few days I used CutePDF Writer which is free of charge and works in the same way. I'm afraid I must pass here as I'm not a computer specialist by any standard - I managed to get things working by some trial-and-error. Whatever, I just wanted to mention it.įor now I can get by, having installed a free CutePDF Writer, but I would prefer to stay within Nitro. This probably is some glitch in the Cleanup Tool, because the first version I purchased was version 9. I just noticed that the log refers to a Nitro 7 version: One last thing: I mentioned before that I did a full reinstall after also running the cleanup tool. But if it may help you solve the issue, I'd be happy to uninstall the current version, run the Nitro Cleanup Tool, and reinstall a previous version to see what happens. As I mentioned earlier, the layout is a vast improvement over the version I was using before and I would hate to go back. I wonder if it is possible to get a previous full installation file (instead of the download assistant), prior to 13.70.2.40, which I could install and see if that makes a difference. I checked the Country/Region setting in the Control Panel to make sure (unless there is still some other place to check), and the 'Current country system' setting (Huidige systeemlandinstelling) clearly shows 'Nederlands (Nederland)' (Dutch (Netherlands)). So the issue may have existed in some version after 13.24.1.467, but it's impossible to verify.įor what it's worth and for your information, the add-in in Microsoft Office doesn't work either - when trying to create a PDF document, there is an error message 'An unknown error has occurred.' But note that I don't use this option ('saving as' a PDF document is my usual way of creating a PDF from within Microsoft Office I am now working on a project in music editing software, and do need a separate PDF printer).įinally, I have also tried to install the separate PDF Creator (Nitro_Creator_圆4.msi), but don't notice any effect.Īgain, thank you for looking into this and should you need any additional information, please don't hesitate to let me know. I suspect there have been updates between these two versions, but I have never checked for updates or, for that matter, installed any. It's only after I upgraded from version 13.24.1.467 to 13.70.2.40 last week that I ran into the problem of the missing printer driver for the first time. The conversion from Windows 10 to 11 (in December 2021, so over a year ago) has not caused any errors either. I have been using Nitro Pro ever since version 9, with upgrades to each subsecutive version, without any problems ever. I see - the OS (Windows 11) is installed on a stand-alone PC. No problem for the delay, everyone is entitled to a weekend or some time off. |
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