Saturday, September 15, 2007

Two little "i's" in the hole (edited)

Yes, that's right my legal friends, Maine is not the only one to use that (ahem) interesting phrase. If you are unfamiliar with the phrase little "i" in the hole, let me clue you in:

(ii)
Ok, the above represents a lower case roman numeral two, set between parentheses. Now, most people would say, "roman numeral two," or simply, "two," or, I have even heard (and secretly love), "romanette two." I do understand the concept of the phrase, "two little 'i's' in the hole," but really people, must we say that?

Here is an example from the Internal Revenue Code:
§ 302. Distributions in redemption of stock.
(a) General rule. If a corporation redeems its stock ..., and if paragraph (1), (2), (3), or (4) of subsection (b) applies, such redemption shall be treated as a distribution in part or full payment in exchange for the stock.
(b) Redemptions treated as exchanges.
(1) Redemptions not equivalent to dividends. Subsection (a) shall apply if the redemption is not essentially equivalent to a dividend.
(2) Substantially disproportionate redemption of stock.
(A) In general. Subsection (a) shall apply if the distribution is substantially disproportionate with respect to the shareholder.
(B) Limitation. This paragraph shall not apply unless immediately after the redemption the shareholder owns less than 50 percent of the total combined voting power of all classes of stock entitled to vote.
(C) Definitions. For purposes of this paragraph, the distribution is substantially disproportionate if--
(i) the ratio which the voting stock of the corporation owned by the shareholder immediately after the redemption bears to all of the voting stock of the corporation at such time, is less than 80 percent of--
(ii) the ratio which the voting stock of the corporation owned by the shareholder immediately before the redemption bears to all of the voting stock of the corporation at such time.
...
OK, if I wanted to refer specifically to the bolded section I would say, "Section three oh four, b, two, cap C, ROMANETTE TWO." How would you site that little roman numeral two? If you are like my legal research
professor (and like others that shall remain nameless), you would call it two
little i's in the hole. I'm not sure why this bothers me so much, other
than it makes one sound like a perverted moron, and I prefer to sound like just
a pervert.

4 comments:

Anonymous said...

Very interesting. I will have to admit that I have never heard that reference. True, I do not travel in the same circles as you do, BUT really, are "they" that clueless as to miss the connotation?!?!?!

T-Money said...

well said mama

Sam said...

I don't get it. Can someone explain it, and possibly attach a photo or something?

Anonymous said...

Sam, Sam, Sam....