"....obviously there was paperwork at some point that showed taxes were overpaid otherwise PR wouldn't have made the agreement in 2006 and revised agreement in 2012."
Not so obvious when you take into account that a person in tax department that may have assessed the claim, and constructed the repayment agreement, is now an employee of DRL
To correctly assess risk here, I believe, is assume shenanigans occurred and to understand the legal classification of such an event. Would it be 'simulation or illegal artifice' or 'misrepresentation of material fact' ?.
The Democratic governor's office argues that the agreement, signed under a previous administration, is null because Doral's supporting paperwork did not prove that the bank had overpaid its taxes.
If people are looking for a spike on news of settlement, surely today's increase on no news just raises the platform from which the anticipated spike will begin, thus substantially increasing foreseen gains in said spike......no?
"...your investment in this..."
To prevent any further waste of your time...."My confidence is only derived from the outrageous requirement to prove exceptional fraud, not just fraud."....meaning the unlikely scenario of Treasury proving fraud above simulation or illegal artifice.
Its very odd that you would present a post, that you claim to spell out a nonsensical contradiction, with mostly reiteration and adjacency. Again, it appears you're "shooting yourself in the foot".
"CoFI stated that the only valid grounds for nullifying the contract were fraud, malfeasance, or misrepresentation of material fact."
This is what I said, but you left out the good bit from Section 6051.07 of the Internal Revenue Code: that the fraud schemes of simulation or illegal artifice aren't sufficient.
"..they currently don't have [a case] that would satisfy the only valid grounds the Court has provided for an annulment of this contract."
Aslo what I said.
Your guess as to what was submitted as reason for annulment by Treasury would also be my guess, but I'm not guessing (outside your 'thumbs down' rate of my post).
You also appear to be agreeing that Treasury has yet to table their full case.
With such comparability in posts, I'm guessing you rated your own post poorly.
"First CoFI did rule that the original basis for nullifying the contract was not valid"
I don't think thats correct. I thought the ruling was for the adjudicative process to be completed and guided the Treasury on how to successfully nullify the closing agreement based on Section 6051.07 of the Internal Revenue Code. I don't know what you mean by "original basis". I don't think the Hacienda's full case has yet been tabled in court because they haven't had to.
"Don't you think if Hacienda could prove fraud they would have started with that argument?"
Hacienda hasn't had to prove fraud (in court) 'til now.
I too am slightly worried. My confidence is only derived from the outrageous requirement to prove exceptional fraud, not just fraud. Look for the Padilla Gov. to change that law!
Saw some relatively big orders go through just recently and was tempted to buy back what I sold @ 9. If there is no news tomorrow, a lot won't want to hold over the weekend and may very well go under 5. This is when I'll be looking to buy.
There’s nobody more ignorant than a political hack.
I noticed you haven’t responded to the critiques of your declaration of “truth” based on your political bias. Surely the responses adequately demonstrate how stupid it is to call such a skewed extrapolation the truth.
Further to that confirmation is your present post that indicates incomprehension of mine, in that I noted your invalid arrogance rather than the absence of a potential for a bankruptcy filing. Also related is my memory of you not competently responding to the question as to why a plan to reorganize under a bankruptcy filing would be dominant, given that assets do not have to be liquidated under such a filing, when assets are being liquidated.
"new Liberal math "
Panick reminds me of a new research paper by Yale law school professor Dan Kahan’s called “Motivated Numeracy and Enlightened Self-Government". Kahan conducted some ingenious experiments to demonstrate the impact of political passion on people’s ability to think clearly.
By wanting to be the buyer then the seller are you saying they sold too low and you could flip it for profit immediately?
There's a lot panic doesn't understand.
I'm glad he's stopped boasting about how he, and nobody else, can read an 8K and that bankruptcy is imminent.
A valid point is not made from suggestions derived from blinkered view points.
I put it to you that your claim of not being politicized is disingenuous and that your post stems from an equally bias rightwing delusion.