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The undeveloped land can be exempted as unproductive real property as long as it is not adjacent to non-exempt productive real property (i.e., the land that the winery resides on). The agricultural...

There is a two-pronged test for the 802.5 exemption: 1. The property must be currently rented or currently held for rent but not rented; and 2. The acquiring person must intend to rent the property to...

04/02/2013 See lnterp #116 in the PNPM, p.151 - paragraph beginning with "Moreover, the PNO..." This was specifically talking about cash to ·pay liabilities in a voting stock deal also being excluded...

but only to the extent they are non-duplicative. E.g., if a sale is made from a foreign sub to a US sub and then sold on by the US sub, you would count the following: - Sales by the US sub to US...