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Introduction to Home Sale Tax Issues
Employers who reimburse brokers' commissions and closing costs on the sale of their employees' homes, as part of a relocation, create taxable income for those employees. Since the Tax Reform Act of 1993, no deductions for such relocation expenses are available to employees, and, therefore, all such payments create fully taxable income. As an example, the average sales commission and closing costs on a $300,000 home are approximately $24,000, or about 8% of the home's value. Reimbursing these fees creates a tax liability for the transferee of approximately $8,400 in state, local and federal taxes. For transferees in high-income brackets, this tax liability can run as high as $11,400 (slightly under 50% of the estimated closing costs).
Many employers, attempting to relieve the tax liability for their employees, reimburse their employees for these taxes. In the relocation industry, this is commonly referred to as "gross up." On a $8,400 tax liability, however, the initial reimbursement creates $3,300 in additional taxes for the transferee. Most companies also gross up this amount. If $8,400 is fully grossed up, so that the employee has no net-tax liability, total tax reimbursements come to an average of $16,080 (about 67% of the broker's commissions and closing costs reimbursed) and can reach over $21,230 (about 88.5% of the reimbursement) for employees in the highest tax bracket. (Please see the Assumptions and Calculations chart at the end of this document.)
To eliminate the creation of taxable income these reimbursements create, certain employers have used home purchase programs – also called "buyouts" – designed to utilize the tax effect of Revenue Ruling 72-339 (explained below). Unfortunately, according to the Employee Relocation Council (ERC), historically the cost of buyout programs average almost 17% of the acquisition price of the home. As a result, many corporations have never employed home purchase programs, while others have abandoned buyouts and are looking for other options.
Both companies that directly reimburse brokers' commissions and closing costs and companies utilizing home purchase programs want to assist their transferees in selling their homes without creating taxable income and additional tax costs. This white paper examines the methods by which employers have attempted to do so, and the likely tax consequences thereof.
The utilization of home purchase programs by corporate employers has also created an issue regarding the treatment of the losses and expenses incurred by the employer. Most corporations consider the expenses associated with reselling homes acquired through their home purchase programs as ordinary business expenses, which offset ordinary income. Through a series of Revenue Rulings (e.g. Revenue Ruling 82-204) and Technical Advisory Memoranda, however, the Internal Revenue Service (IRS) has taken the position that for most of these programs, the brokers' commissions, closing costs and losses on resale, relevant to these properties, create capital losses rather than ordinary business expenses. This is significant because many employers (particularly those in the service industry) do not have offsetting capital gains against which to write-off the capital losses.
A brief history of the tax treatments of reimbursements of brokers' commissions and closing costs
Unquestionably, reimbursement of brokers' commissions and closing costs, in conjunction with the sale of a relocated employee's home, creates taxable income. During the mid-1960s corporations created the first home purchase programs in an attempt to eliminate the creation of taxable income by the reimbursement of these costs.
In the typical home purchase program the employer, or a supplier retained by the employer (throughout this white paper, utilization of the word employer also refers to a relocation supplier retained by the employer), purchases the employee's home at "fair market value" as set by an appraisal process. In actuality, the employer has given the employee an offer (often called the buyout) to sell the home within a certain number of days (usually 30 to 60). During the 30- to 60-day offer period, the employee may attempt to market the home to see whether they can sell the home for more than the appraised buyout offer. If the employee elects to accept the buyout, then the employer buys the home and closes with the transferee. Closing costs are not charged to the employee, as the employer is simply willing to take a deed for the home without any obligation incurred for such costs. The only exception to this is the first transfer tax (where it is assessed), which is the sole responsibility of the transferee. Further, if the employee lists the home for sale, he or she must have had the real estate broker sign an "exclusion clause," so that the employee does not incur any obligation for real estate commission if the employee sells the home to the employer. Accordingly, no commission upon the sale from the employee to the employer is due.
If during the offer period the employee does find a buyer willing to pay more than the employer's offer, one of two things occurs:
- Assigned Sale: In an assigned sale the employee simply assigns the contract, with the buyer that he or she finds, to the employer. The employer then closes with the employee at the appraised value. Later, if the sale to the ultimate buyer closes for a higher amount, the employee is given an additional sum to make up the entire purchase price from the ultimate buyer.
- Amended Value Sale: In an amended value sale, the employer does not take an assignment of the employee's purchase agreement with the buyer. Instead, the employee informs the employer that a buyer is willing to pay more for the home and the employer then amends its fair-market-value offer up to the amount offered by that buyer. (Later this white paper will analyze reasons for the difference between an assigned and an amended value sale.)
If no buyer is procured by the employee, he or she will accept the offer from the employer. The employer then completes the sale with the employee and conducts a closing where prorations are made up to a certain date (generally the date at which the employee vacates the home). Thereafter, the employer attempts to resell the home and upon such resale all the costs of brokers' commissions, closing costs and any losses on the resale of the home are incurred by that employer.
In 1972, the IRS challenged a company's in-house home purchase where the employer, as opposed to a relocation service company, purchased and resold the employee's home. The IRS initially contended, in the audit of a taxpayer, who was an employee of the company, that payment of home sale expenses through the employer's home purchase program created taxable income to the employee. Virtually on the "steps of the court house," the IRS relented and thereupon issued Revenue Ruling 72-339.
Revenue Ruling 72-339 basically exempts, from an employee's income, all broker's commissions and closing costs involved in the employer's resale provided that:
- There is no broker's commission or closing costs (which are by law, or local custom, considered seller's cost and which are paid by the employer) in the sale of the home from the employee to the employer; and
- The purchase price of the home is at no more than fair-market value. (If greater than fair market value, the excess would be taxed to the employee as income.)
The reasoning behind the ruling, as discussed in subsequent Private Letter Rulings and in a 1979 IRS General Counsel's Memorandum (GCM-37888), was that the typical home purchase program really consisted of two separate sales:
- The first sale, from employee to employer, was similar to a "for sale by owner" transaction. There were no broker's commissions due because of the listing exclusion clause in the employee's agreement with his or her real estate broker. Furthermore, there were no closing costs—as there would be in a typical transaction—because the corporate employer was willing to close without the usual formalities (except the first transfer tax as noted above). Thus, as there were no commissions or most closing costs incurred, these could not be imputed to the employee.
- The second closing transaction, between the employer and the final purchaser, was deemed totally separate from the first transaction. Therefore, none of the costs of the second sale were attributable to the employee.
Beginning in 1976, certain officials at the IRS began to question the validity of 72-339. In a 1979 IRS General Counsel Memorandum, however, the IRS described why it elected not to revoke 72-339. The Counsel supported the reasoning that there are two separate transactions and stated that the only real benefit to the employee is that he or she can sell his or her home quickly. The value of the "quick sale" benefit, however, was deemed impossible to value and thus impractical to tax.
With regard to "assigned" versus "amended value" sales, during the 1970s the IRS, in a number of Private Letter Rulings, upheld the same favorable tax treatment despite involvement by the employee in locating the ultimate purchaser of the house for the employer. Until 1985, the IRS continually upheld favorable tax treatments for programs that constituted both assigned and amended value sales.
In 1982, Revenue Ruling 82-204 was issued. This ruling held that losses on the resale of homes by an employer with an in-house program could not be used as ordinary business expenses but only as capital losses. In arguing against this ruling, industry sources claimed that losses involved in the resale of houses by in-house programs should be treated as ordinary expenses involved in the company's business operations. This was true, it was argued, because the sale of houses was incidental to the corporation's business, which included the relocation of employees. In reviewing this argument, the IRS saw, as support for the position, that the costs of home purchase programs really benefit employees and should be taxed. At this time, industry sources feared that the IRS would want to reconsider Revenue Ruling 72-339, and accordingly, the relocation industry backed off of any attempt to further question Revenue Ruling 82-204.
Since 1982, Revenue Ruling 72-339 has survived three major changes in the tax laws and, despite continuing concerns by the relocation industry, it appears to be a position of the IRS that can be relied upon, at least for now. Yet at the same time, since 1982, it is apparent that the IRS Technical Staff has developed the position that assigned sales (and possibly amended value sales), are "flexible transactions" that should not receive favorable tax treatment. Their reasoning appears to be that:
- These sales really involve one rather than two transactions, as the sale to the ultimate purchaser by the employer has really collapsed into the sale from the employee to the employer; and
- The employer has satisfied an obligation of the employee to pay a broker's commission.
It was reported that a draft Revenue Ruling distinguishing 72-339 from "flexible transactions" was developed in 1986, but it was never issued. In June of 1985, however, the IRS released Technical Advice Memorandum 85-22002, which was given as the result of an audit of a taxpayer. It exhibits the strongest position taken by the IRS against "flexible transactions." In this advisory memorandum the IRS ruled that it would tax the broker's commission in a certain "flexible transaction." While a Technical Advice Memorandum applies only to the case being considered and is not "the law," it does demonstrate the position of the IRS National Office and, accordingly, must be taken seriously by all corporations involved in this issue.
Observing the facts of 85-22002 is difficult, as they are not defined very specifically. It is unknown whether the transaction targeted in the memorandum was actually an assigned or amended value sale. On the surface, the memorandum speaks of an amended value sale. Certain language, however, implies that the transaction was in fact an assigned sale, which was simply called an amended value sale by the employer.
The IRS states that the employee's real estate broker had reason to believe it would be paid its commission by the employer's relocation company, even though the standard exclusion clause was included in the listing agreement. This could imply two things:
- First, that the broker was either told to expect the commission (despite the exclusionary clause) or knew that relocation companies will always pay the commission to the broker; or
- Second, that the contract with the ultimate purchaser was actually executed by the employee and accordingly, the broker was entitled, at that point, to the commission. In its conclusions the IRS states that the broker's commission was taxable income to the employee "absent any reason for the broker to believe that he would not receive a fee from the transaction."
From this Technical Advice Memorandum it was difficult to judge what the IRS's position on a "true" amended value sale would be. It is clear that the position of the IRS is to treat the broker's commission on an assigned sale as W-2 taxable income to the transferee. Still today, no one knows what the IRS position would be in a clear factual situation involving the amended value sale formula. As is noted later in this paper, however, we may know its position shortly.
The ERC's "11 Point Amended Value Plan"
In order to deal with industry concerns over this Technical Advice Memorandum, the ERC published guidelines for companies to structure their "flexible transactions" as amended value sales. The highlights of the ERC's definition of an amended value sale are paraphrased as follows:
- A suitable exclusion clause must be contained in every listing between an employee and a real estate broker that excludes the broker from receiving a commission if the employee sells the home to the employer. The exclusion must be structured so that it will remain in place even if the employer resells the home to someone originally procured by the broker.
- The employee must not execute a sales contract with a prospective buyer. Nor may the employee accept a down payment of any sort. The employee must execute the offer from the employer, which offer shall state that the burdens and benefits of ownership pass to the employer upon execution of the contract and the vacating of the property. This contract must be unconditional at the higher amended value whether or not the prospective purchaser obtains a mortgage commitment. The fact that the sale to the prospective buyer falls through later cannot affect the price. Accordingly, the employer must be "at risk" of owning the home after such a "fall through." In addition, if the home sale falls through to the outside buyer and if there is a home sale bonus or incentive in the policy, this payment must still be made (i.e. even if the home subsequently goes into inventory).
- Neither the employee nor the employer (in the case where a relocation company is used) can exercise any discretion over the subsequent sale of the home. Nor may the purchase price paid to the employee (once set by reference to the prospective offer) be affected by the ultimate sales price should it be lower or higher. If the employer chooses to use the employee's broker to sell the house to the buyer procured by the employee, the employer must enter into (a) a separate listing agreement with the employee's broker to assist with the resale (which can be limited to the one buyer procured) and (b) a separate contract with the buyer, with the employer arranging transfer of title to the buyer. The employer cannot be under any compulsion to list the home with the employee's broker.
Corporate employers have taken a variety of positions with regard to the ERC's definition of amended value sales subsequent to its publication. Most employers today have described their "flexible transactions" as amended value sales. Quite a few employers follow the guidelines with respect to not allowing the employee to execute a contract with the buyer or accept a down payment. Fewer, however, go to the trouble of having a new listing agreement signed with the real estate broker. Finally, very few have been willing to take a position of risk in amending the contract to the employee up to the price offered by an ultimate buyer until that buyer has at least obtained loan approval. Thus, most employers trying to take advantage of Revenue Ruling 72-339 have done so through the following methods:
- Method One: Using a standard home purchase format with the flexible transaction being a pure "assigned" sale.
- Method Two: Using a standard home purchase format with aspects of the amended value sale but not by becoming at risk to amend the sale with the employee immediately upon receiving a bona fide offer from a buyer. (This is sometimes called an "Un-Pure Amended Value.")
- Method Three: Using a traditional home purchase program format with a "pure" amended value sale with the employer being "at risk."
- Method Four: Using a non-traditional home purchase program wherein the employee markets the home without an offer being made by the employer to purchase the home at any value. Once the employee finds a potential buyer of the home, the employer then tenders an offer to purchase the home at the price offered by the ultimate purchaser. In virtually all of these programs, the employer is never at risk if the sale of the home to the ultimate purchaser falls through. (Only in a few existing programs, of which the author is aware is the employer "at risk.") We shall then call these the "no risk" form of "un-pure" amended value sales. A "pure" amended value sale plan can be employed once an arms-length buyer is identified and the price established as the amended value. This version is often called the "amend from zero" or Buyer Value Option (BVO) plan.
Analyzing the IRS's position regarding the various methods of meeting Revenue Ruling 72-339
In analyzing the various Revenue Rulings and Technical Advice Memoranda generated by the IRS, some broad conclusions appear. The key to whether a "flexible transaction," whether called an assigned or amended value sale, creates taxable income to the employee is predicated upon three tests:
- Are two transactions clearly separable so that one does not collapse into the other?
- Does the real estate broker have a reasonable expectation of receiving a commission as a result of listing the home with the employee?
- Is the corporate owner of the home (either the employer or relocation service company), in economic reality, the owner of the property as the result of the first transaction so that the second transaction has economic validity?
The following is an analysis of the four ways to take advantage of Revenue Ruling 72-339, discussed above, and the likely tax treatment by the IRS in terms of these three criteria.
Method One
In the traditional home purchase program method with an assigned sale, the IRS has clearly taken the position that this creates taxable income to the employee for the amount of the broker's commission. This is obvious by Technical Advice Memorandum 85-22002, due to the fact that:
- The first transaction collapses into the second because one is dependent on the other.
- The broker has at least a reasonable expectation of a commission from the employee and perhaps even a legal right of receipt.
- The company clearly does not bear the risks and rewards of an owner.
Method Two
The second method, a traditional home purchase program using an "un-pure" amended value method, (where the employer may not be at risk in the event that the sale with the ultimate purchaser does not close) is very questionable upon analysis of Technical Advice Memorandum 85-22002.
The IRS in this area has always taken the position, which has been supported by the courts, that if the form of the transaction is at variance with its substance and lacks economic reality then the substance will be determinative not the form. (Commissioner v. Court Holding Company, 324 U.S. 311, 1945, C.B.58.). Whether or not there are two transactions, in economic reality, largely rests upon the issue of risk. In the "un-pure" amended value sale, the two transactions (between employee and employer and between employer and ultimate purchaser) are economically tied together by what happens in the second transaction. The position of the ERC is that the first transaction (between employee and employer) will collapse into the second transaction, as the first transaction cannot be completed until the second transaction is a substantial reality. Did the employer actually purchase the home and thereby have all of the risks and rewards of ownership of that property? It has been the position of the ERC that this might not be the case unless the sale to the employer is totally perfected and not reliant, in any fashion, upon the sale to the ultimate purchaser by the employer.
Furthermore, the language of Technical Advice Memorandum 85-22002 must be considered. Technical Advice Memorandum 85-22002 found that the real estate broker had a reasonable expectation of receiving a fee from the sale of the property as the result of the employee listing with that broker.
Method Three
In the third transaction, the "pure" amended value sale, the ERC suggests that the greatest protection against an unfavorable tax ruling is achieved. In this transaction, all methods have been used to separate the two transactions, and, in economic reality, the employer has become the owner of the home with full risks thereof. If the sale to the ultimate purchaser falls through, the employer will experience all property risks and rewards.
In the fall of 1995, the IRS, although refusing to give either a Revenue Ruling or Private Letter Ruling, indicated to the ERC that for the time being it will not attack transactions that meet the 11 point "pure" amended value sale. This has created an informal "safe harbor."
Still, the language of Technical Advice Memorandum 85-22002 regarding the expectation of a broker's commission is troubling. It is conceivable that the IRS will later take the position that, regardless of the formalities of the amended value sale, the employee has an obligation to pay a commission to a real estate broker. In economic reality, the employer satisfied this obligation. Thus, the broker would have a reasonable expectation of receiving the commission despite the listing exclusion clause contained in the listing agreement.
Method Four
The fourth method is the use of an assigned sale without the employer making a prior offer. This transaction has the same inherent problems as any "un-pure" amended value sale in that it is questionable as to whether the employer, in economic reality, ever truly completed the acquisition of the property from the employee as an owner with the full risks and rewards of ownership.
The Amend From Zero or Buyer Value Option Program
In the Amend From Zero or Buyer Value Option (BVO) Program, the employer does not make an offer for the home at fair market value. Instead, the offer is extended only at the market value established by finding an arm's length buyer. If that buyer is never found, the employer will not purchase the home. This approach would appear to be highly susceptible to attack, even though it loosely follows the informal "safe harbor" of the amended value sale.
The substance of each of the 11 Points of the Amended Value Program is to cause an absolute and complete separation of the two transactions, (from employee to employer and from employer to ultimate buyer) so that one does not depend on the other. In a BVO, however, the transaction (from employee to employer) cannot occur unless and until a transaction (from the employer to the ultimate purchaser) is agreed upon. The employee has hired a broker to procure a buyer, and unless this occurs, the employer will not conclude an agreement with the employee. Further, when a buyer is found, the employer will not execute an agreement with that purchaser until the employee agrees that the price and terms are acceptable. Clearly the transaction between employee and employer will not occur unless the employee and ultimate purchaser reach an agreement on terms and price. This is unlike the typical amended value sale, where the sale from employee to employer will occur regardless of whether the employee finds a buyer who is willing to pay an amount with terms to which the employee agrees. Thus, a BVO is far riskier than a true amended value sale and it is yet to be determined if it may create taxable income to the employee.
Are expenses of home purchase programs ordinary business expenses or capital losses?
Recall that in 1982, Revenue Ruling 82-204 held that the costs of the resale of a home by an employer using an in-house program (where the employer, rather than a relocation service company, actually acquires the home) could not be taken as ordinary business expenses. Revenue Ruling 82-204 held that the costs of the resale of a home must only be reported as capital losses.
In Private Letter Ruling 90-36003, the IRS extended this theory to traditional home purchase programs in which an employer uses a third-party relocation company to actually take title to the properties. The IRS, relying upon the Supreme Court holding in Azur Nut v. Commissioner, Infra, found that the form of the transaction (the relocation company was the owner) was at variance with the substance of the transaction. The IRS held that the transaction lacked economic reality in that the corporate employer would essentially be in the same economic position as the owner of the property. In this instance, the contract between the relocation company and the employer called for the employer to reimburse the relocation company for virtually all of the costs of ownership of that property. Accordingly, the IRS found that the relocation company was not, in an economic sense, the owner of the property. It found rather, that the employer was in the position of being the actual owner of the property. Accordingly, the home was, in economic reality, the capital asset of the employer and the costs of its resale were capital losses. In so finding, the IRS refused to rely upon the assertion that the relocation company was not, according to traditional agency law, an agent of the corporation.
On one hand this ruling was helpful in that it reasserted the IRS's position that the two-transaction theory in Revenue Ruling 72-339 was still applicable. Unfortunately, however, for the vast majority of corporate employers that utilize third-party relocation service companies, traditional home purchase programs do not create ordinary business expenses for those employers but rather capital losses, which can only be written off to the extent that the company has capital gains.
There is, however, one "safe harbor" for employers to receive treatment of such expenses as ordinary losses. In a Private Letter Ruling 92-44027, the IRS approved as ordinary business expenses, for a relocation company, the costs of holding and reselling homes it acquires. In this situation, the contract between the employee and the relocation company could be categorized as a "fixed-fee contract." In this contract, the relocation service company acquires the home in the traditional home purchase program manner. Rather than the employer reimbursing the relocation company for all expenses and indemnifying it for all losses, the employer's only obligation is to pay the relocation company a fixed fee based upon a percentage of the appraised or amended value of the home. In finding that the relocation company was, in fact, purchasing employees' homes for its account rather than as an agent or "appendix" to the employer, the IRS commented on issues that are germane to both the issues of creation of taxable income and capital loss. The IRS, relying in part on Derr v. Commissioner, 77 T.C. 708, 723 (1991) and Grodt and McKay Realty Inc. v. Commissioner, 77 T.C. 1221, 1237-1238 (1981), found that economic reality was that the relocation service company, which bore the risk of loss or damage to the property, was in fact the actual "owner" to which the sale from the employee occurred.
In citing Grodt and McKay Realty Inc. v. Commissioner, supra, the IRS relied upon a number of factors in determining whether the burdens and benefits of ownership of the property have fallen upon a particular party. These factors include:
- Whether legal title passes
- How the parties treat the transaction
- Whether an equity interest was acquired in the property
- Whether the contract creates a present obligation on the seller to execute and deliver a deed, and a present obligation of the purchaser to make payments
- Whether the right of possession is vested in the purchaser
- Which party pays the property taxes
- Which party bears the risk of loss or damage to the property
- Which party receives the profits from the operation and sale of the property
Accordingly, although the Private Letter Ruling does not specifically mention the capital loss issue or the amended value sale issue, it does bear directly upon both. One may assume that a fixed-fee contract, where the relocation company uses a "pure amended value" sale, may pass scrutiny as (a) not creating taxable income to the employee and (b) creating an ordinary business expense for the employer in the payment of the fixed fee.
Impact on the issue of taxable income:
Note again that Revenue Ruling 72-339 is predicated upon the existence of two transactions and that it appears to be both the position of the ERC, as well as the IRS, that the application of 72-339 is partially based upon whether the economic reality of the transaction is that the employer or its relocation service company is, in fact, the owner of the home. The two transactions (the first from employee to employer and the second from employer to ultimate purchaser) are separable. If in fact the relocation service provider is deemed to be the economic owner of the home through completion of a separate sales transaction with the employee and followed by the relocation company, bearing the benefits and burdens of ownership, then the costs attendant to the disposition of the property should not be taxable income to the employee.
Impact on capital loss:
Again, if the relocation service company is, in economic fact, the owner of the property, attendant with all risks and rewards of ownership, the Private Letter Ruling indicates that the relocation company, rather than the employer, is the owner of the property. As such, payments of a fixed fee from the employer to the relocation service company, which are not conditioned upon the actual economic losses and expenses incurred in the ownership of the property by the relocation service company, should result in the treatment of the fixed fee as an ordinary expense to the employer.
The Amdahl Case and its Impact
In furtherance of the position taken in Technical Advice Memorandum 90-36003, the IRS took the Amdahl Corp. to tax court in 1997, asserting that the costs of its assigned sale program created capital losses, not ordinary business expenses (Amdahl v. Commissioner, 108 T.C. 507 [1997]). The court held that the assigned sale did not create ownership of homes by the corporation, using the criteria of Grodt and McKay Realty v. Commissioner, supra. The court focused on the fact that the assigned sale never vested legal title in the company or its third-party supplier; that the benefits and burdens of ownership never shifted to the company or its third-party supplier; and that the employee, under Amdahl's benefit program, would receive the benefit of any increased sales price if the home was resold by the third-party supplier for more than what was paid to the employee.
The court never reached the issue of whether it was the employer or the third party that was the "owner" of the homes, as it ruled that the employee was truly the owner. Thus, the issue presented in Technical Advice Memorandum 90-36003 of whether the corporation or the third-party supplier was the "owner" of the home was not reached. Nor was the employer's position explored, which stated that if the home was the employer's asset, it was not a "capital asset" at all but merely an asset held incidental to its normal course of business.
Recent Developments—Amdahl and Deed-in-Blank
The litigation involving the Amdahl Corp. is having a substantial impact on the relocation industry. Since the Court ruled that neither the corporate employer nor its third-party relocation supplier ever actually owned the employee's home, the logical conclusion was that the assigned home sale process merely passed ownership from the employee to the ultimate buyer. Thus, the broker's commissions and other costs of acquisition and resale (which the Court concluded were in reality, simply reimbursed expenses from the employer to the employee) could not be deemed capital losses for the employer but rather, were ordinary business expenses. The decision, however, contained very troubling language regarding the creation of W-2 income to transferees.
One of the steps used by Amdahl in its home sale process involved the use of a deed-in-blank. Briefly, in home purchase transactions, the relocation industry had typically utilized one deed for both transactions (from employee to employer or relocation company and from that entity to the ultimate purchaser).
The employee, when selling the home to the employer or relocation company, would execute a deed that did not contain the name of the ultimate purchaser. When the employer or relocation company resold the home, the ultimate purchaser's name would be placed on the deed, using the power of attorney given to it by the employee at his or her closing. In conversations with the IRS, the ERC became sensitized to the IRS's position that because of the absence of the employer or relocation company in the chain of actual title, as required by Revenue Ruling 72-339, the two transactions never really occurred. Historically, the industry's position had been that the actual agreement and closing between employee and employer had transferred sufficient "equitable title" to create ownership of the home to the employer or relocation company.
For over 20 years, the deed-in-blank process had been used by the relocation industry to minimize paperwork, reduce administrative complexity, and keep the company out of the legal chain of title to minimize cost and risk. This process transferred ownership of the transferee's home to the ultimate buyer using a deed-in-blank without the expense of filing and recording deeds twice. The relocation industry had every reason to believe that using a deed-in-blank process at no time created a situation in which there were not two distinct and separate home sales as required under Revenue Ruling 72-339, since, in substance, the transferee transferred all of the benefits and burdens of ownership to the relocation service provider or employer.
Post Amdahl
After the Amdahl case, in July of 2001, the ERC Board of Directors approved the unanimous recommendation of the ERC Public Policy Committee relating to "Taking Title by Deed and Eliminating the Deed-in-Blank Process." The ERC took this rare and unusual action and recommended to all of its membership the following:
"…it would be in the best interest of the members of ERC to use two deeds in relocation home purchase transactions. In the view of the Public Policy Committee, the advantages of doing so far outweigh the costs and other disadvantages identified. Consequently, the Committee believes that ERC should recommend to its members that they take title by deed in home purchase transactions."
The increase in IRS audits and deed-in-blank under fire
In 2004, the IRS put the spotlight on relocation tax issues. As a result of the Amdahl case decision, the IRS Employment Compliance Audit Division has taken the position that failure of the relocation service provider (or employer) to take title by deed from the employee will result in the transaction being classified as noncompliant with the two-transaction requirement of Revenue Ruling 72-339. This position jeopardizes the protection of the employee from imputed W-2 income, which results from the payment of real estate commissions and most closing costs.
As a result, the number of IRS audits relative to the treatment of home sale expenses has significantly increased, with the IRS auditors taking their position from the unintended consequences of the Amdahl case (which was a capital loss case) and applying these erroneous assumptions to the determination of whether such expenses ought to be required to be treated as W-2 income to the transferee. There is nothing to suggest that the increase in the number of these employment tax audits, where the IRS auditors are attacking the use of the deed-in-blank process, will not continue.
ERC asks for assistance
In late 2003, the ERC asked the IRS to put the Amdahl issue on its Priority Guidance Plan, hoping that it would provide public guidance to the industry on the impact of the Amdahl decision on relocation home sale programs. The IRS agreed, and the Income Tax and Accounting Division (IT&A) of the Office of the Chief Counsel of the IRS took on the project in 2004. The ERC, and member relocation service providers such as SIRVA Relocation, have worked closely with the IT&A to suggest language for a new ruling and submitted a detailed analysis of the current amended value type home sale programs. The submission also included recommendations regarding the proper elements necessary to keep the program compliant with Revenue Ruling 72-339. This process has generated comments and questions from the IT&A and further responses from the ERC. A new ruling is expected by the end of 2005. It is hoped that the ruling will be prospective only, that it will overturn the use of the Amdahl decision in W-2 income audits, and will give guidance as to the appropriate elements of a Revenue Ruling 72-339 compliant transaction.
Coordinated Issue Paper Drafted
In October of 2004, the large and medium size business (LMSB) audit division of the IRS issued a Draft Coordinated Issue Paper (CIP) that directly attacked amended value home sale programs. The Draft CIP was circulated to the ERC and many taxpayers who were, at the time, under audit. The ERC responded in December of 2004 with comments and suggestions for an extensive rewrite of the assumptions and conclusions in the Draft CIP. If adopted by the IRS audit division as originally written, there would be a substantial negative impact on the way the industry manages home sale programs.
The Next Action is With the IRS
It has been determined that the Draft CIP project is not being done in conjunction with the Chief Counsel Office's public guidance project. The industry is taking the position that the Draft CIP project should be shelved in deference to the public guidance project. The industry anticipates that the Office of the Chief Counsel will issue a new Revenue Ruling by the end of 2005, but this timing is not certain.


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All information deemed reliable but not guaranteed. Listed subject to errors, omissions, change in price, prior sale, rent and withdrawal without notice. Photographs, description and information about the properties reflect conditions at the time the photographs were taken. All dimensions and all square footage are approximate. For exact dimensions, you must hire your own architect or engineer. Copyright 2009-2012. All rights reserved.

subset: commoncrawl


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Acro Tool & Die Products
At Acro Tool & Die, we specialize in small metal parts, components, and assembly for a vast array of products in a variety of global industries. We manufacture millions of parts each year in full production runs. Acro also works with companies and institutions in public and private sectors in areas of product development and prototyping. Primary and secondary manufacturing operations are all performed in house utilizing the following manufacturing capabilities and materials:
• DMLS (Direct Metal Laser Sintering)
• CNC Machining
• Laser Cutting
• Wire EDM
• Swiss Style Screw Machining
• Precision Metal Stamping
• Forming
• Grinding
• Heat Treating
• Tumbling
• Polishing
• Engraving
• Capacitive Discharge Welding
• Spot Welding
• Titanium
• PEEK Plastics
• Stainless Steel
• Tool Steel
• 1018 Cold Rolled Steel
• Aluminum
• Copper
• Inconel
• Brass


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The Witchwood Card Review + Laddering
The Witchwood card reveals are now complete and it's time to review the cards from the new set. This set brings in the Year of the Raven meaning these sets (along with a few classic cards) will be leaving standard:
The Boomsday Project Laddering
A pre-vacation day of HearthStone
My last show is tomorrow evening, so I HAVE to do a full day of HS streaming before I go. I'm still determined to try get a handbuff deck to function well.
The Witchwood Final Card Reveal Livestream w/ Ben Brode & Day[9]
Grab a torch, prime your crossbow, and join Game Director Ben Brode and Sean "Day[9]" Plott as they valiantly wrap up The Witchwood card reveal season on April 9 at 11:00 am PDT
The Boomsday Project - Pack Opening and Meta Deck Laddering
The Boomsday Project Laddering
Hearthstone - My first day of KFT
Time to try some new KFT decks ALL DAY! Part 1 Part 2
Kobolds and Catacombs Card Reveal w/ Ben Brode and Day[9]
Join Game Director Ben Brode and Sean "Day[9]" Plott in the final Kobolds and Catacombs card reveal session. Glimmering treasures, hoarding dragons, and ancient weapons are all waiting to be unearthed!
The Boomsday Project Final Card Reveal w/ Day[9] & Mike Donais
Join Game Designer Mike Donais and Sean "Day[9]" Plott as they dive into the last of The Boomday Project's cards, showcasing their own brand of weird science with some interesting decks we've brewed up for the stream.
Minion Masters (sponsored)
BetaDwarf has sponsored me to play Minion Masters as it now reaches version 1.0 and leaves early access. Minion Masters is a fast-paced free-to-play online minion battle game for PC and Xbox. Players choose a Master, build decks from hundreds ...


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What our parents say
Mr Shellard (Y2, Reception, Nursery)
As first time parents we thought long and hard about where to send our first son before choosing Daiglen. Neither I or my wife had been to a private school and, to be frank, our respective parents were dead against us sending our children to one. Therefore, it was such a nice surprise and quite honestly a relief to come across this wonderful school. On our first walk around the building we were taken in hand by polite and amazingly confident 11 year olds who clearly liked their school and spoke warmly of all it had given them. The small size of the school, far from being a hindrance means that nearly every child we meet knows the names of every other child in every other year and there is a genuine feeling of community. In terms of tutorage even now with my son only 4 years into his life at the school I can see that he is at least 2 or more years ahead of his equivalent 6-year-old state school peers. It was therefore an easy decision for us in sending his two brothers to Daiglen and although it's sometimes a struggle to bear the costs involved in this choice, we believe it is good value for money and truly worth it. We also feel that by the time our children leave the school we can rest assured they will obtain a place at whichever their desired choice of school might be from year 7.
Mrs Swain (Y3 & Nursery)
My son joined Daiglen later in his education and I was obviously concerned about changing schools after he had made close friends and settled well at his previous school. I was surprised and comforted with just how quickly he became engaged in his new class, his education and school life. Over the time he has been there, it is evident that this wasn't just a one off effort to settle him in, but to us defines the nature of Daiglen. Being small, it feels more like a family and so provides a supportive, safe and encouraging environment for the children to develop and grow. Daiglen was absolutely the right choice for our son and our family
Dr & Mrs Schwartz (Y5 & Y1)
We love the family atmosphere, that the Headteacher, all the teachers and all the children know and value each other in the school.
The teachers are so supportive, encouraging and imaginative, and our children are happy and flourishing as a result. We value the fact that our children's own personalities and characters are encouraged to shine!
The school has high expectations of academic and personal achievement, and we are delighted that our eldest gained a double scholarship at a local private school.
Mrs Malik (Y2 &Y4)
I've been pleased from day one and each day has got better. My daughter is gaining confidence which is something she's always lacked despite being a gifted little girl. Its hardly been a month and the changes in my daughter are huge so I am extremely pleased with my choice of school and also very grateful and thankful to the staff at Daiglen, especially Mrs Bradfield who is so focused and involved with the children.
At Daiglen each child is recognised as an individual as opposed to just being a number. I am very pleased and hope that it continues this way. I saw so many schools but Daiglen seemed different. The welcome and the very natural manner in which Mrs Bradfield welcomed us on the visit said it all. The staff are just great. The atmosphere is brilliant in the playground with very friendly parents. My husband is pleased too. I am now in the process of moving my middle child to Daiglen.
Mr & Mrs Buckley (Y3 & Reception)
I've seen our children grow and become beautifully educated, happy, well rounded little people! Daiglen is a caring, nurturing environment. We couldn't ask for a better school.
Mrs Petrie (Y5 & Reception)
Daiglen School has provided a warm and nurturing environment for my children to learn in. Both my children are happy about going to school each day and have developed strong friendships within the school. I highly commend the Nursery for teaching both my boys to read by the end of the first term of joining the school. Daiglen provides a friendly atmosphere, enabling each child to show their true potential by the time they leave the school in year 6.
Mrs Yull (Y1)
I am so happy with Daiglen school. Choosing your child's school is one of the most important decisions you will ever make on their behalf. I could not be happier with my decision to send my daughter to Daiglen. The school encourages the children to perform to the best of their ability academically by providing them with all the support they need to thrive in a safe, happy and stimulating environment. The school's size provides for a friendly, real community feel. My daughter loves the school and is very happy there. I would not hesitate to recommend the school to other parents.
Mrs Boulton (Y4 &Y2)
Daiglen is not just a school, it's a community. The teachers really care about our children both educationally and emotionally. When my children moved from the state sector to Daiglen, they were welcomed and encouraged. Daiglen instils confidence and makes every child believe in themselves. Sending my children to Daiglen School was one of the best decisions that I, as a parent, have made.
I am so pleased with the school and everything that the teachers are doing to help my children.
Mr & Mrs Lad
A great 'family feel' school, where children feel safe and secure.
Mrs Hanedan
Daiglen School has a small, friendly environment. I feel that it has a strong foundation of values which produces excellent results. It has a sturdy focus on manners and politeness. Pupils gain confidence over the years and enjoy working together in classes. The teachers at Daiglen school are very friendly and make you feel welcomed. They are experienced, caring and also approachable. I would definitively recommend this school to others.


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The Bradley Smart Smoker™ is the new automatic, electric food smoker from Bradley Smoker®. It features innovative iSmoke™ Technology, that allows you to connect with and control the smoker from Bluetooth-enabled smartphones in real-time. It's the result of years of advancement and testing on existing smokers.
The idea for this smoker started in pursuit of achieving the best tasting smoked food, every time. Having control over every detail of the process of food smoking, allows barbecue enthusiasts and backyard foodies to create delicious, consistent results, without a lot of hassle.
Wade Bradley, owner of Bradley Smoker® shares the key to food smoking that was told to him many years ago, "The secret to food smoking is you must control the smoke and heat, plain and simple". The best smoked flavour comes from cooking low 'n slow, and with real-time control over temperature and smoke, you can relax or prepare the rest of your meal, without manually adjusting the smoker or adding wood all the time.
All Bradley smokers feature the innovative automatic feed system, where a hinged burner drops smouldering wood bisquettes into a bowl of water at regular intervals, to extinguish the wood when it turns to ash. This means the smoke burns cleaner, providing great smoked flavour and the best tasting food possible. Two separate heating elements allow to you continue cooking food in the smoker, even once the smoke has been shut off.
The Bradley Smart Smoker™ allows you to control settings from a user-friendly new touch screen on the front of the smoker, or from a smartphone with Bluetooth®. Settings display in real-time, so you'll be able to bring out food at just the right moment and not overcook it. Another improvement is its larger capacity smokehouse, with room for 10 racks of food. Two removable, color-coded temperature probes allow you measure heat in different areas of the smokehouse simultaneously, for advanced monitoring.
For 30 years, Bradley Smokers have been known as easy-to-use electric smokers that deliver consistent results. "You can think of it as smoking goes high-tech" says Steven Raichlen, author of The Barbecue Bible and the new Project Smoke, and host of Steven Raichlen's Project Smoke on Public Television.
Many cultures and cuisines from around the world have been smoking foods for hundreds of years. While it was originally used as a way to preserve and keep food without refrigeration, it has become popular again, along with other homegrown methods like pickling and fermenting foods, for the unique flavour it adds to dishes.
A variety of foods can be smoked, from meat and seafood, to more unusual items like cheese, vegetables and desserts. This cooking technique isn't one to be rushed, and lends itself to relaxed, casual gatherings of family and friends. It's the essence of slow food, taking the time to share a homemade meal with those around to you.
About Bradley Smoker®
Bradley Smoker® is the premium brand of automatic electric food smokers in North America. Bradley smokers are sold in major retailers across North America, Europe, Australia and New Zealand; they can be found being used by gourmet chefs, barbecue fanatics, and do-it-yourself home cooks.Bradley Smoker is a North American company that specializes in meat and food smoking products, including electric smokers, grills, wood bisquettes, cures and smoking accessories. Whether you're a foodie, a sportsman, an outdoors type or a chef, food smoking is a great way to enhance the flavour of homemade food and add that extra special taste.


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Porter for Luxury Hotel in Melbourne
24 Marposted by Alliance Abroad Group
Categories: Jobs in Australia
Tags: hotel job in australia, hotel jobs, hotel jobs abroad, hotel porter job, porter, work abroad, work in australia, work in Melbourne
Comments: 0
Work in the Heart of the World's Most Livable City
Positions: Porter
Pay: $18/hr
Start Date: April/May 2014
Duration: 6 months
Location: Melbourne, VIC (luxury hotel)
Apply HereRequest InfoContact Us
This luxury hotel is a retreat oasis in the heart of the bustling Melbourne Central Business District, near the theatre district, and amongst trendy restaurants and art galleries. This extravagant establishment provides guests tranquility and rejuvenation, and offers plenty of things to do in the area. This remarkable hotel redefines personal service with a gracious manner, ensuring a truly unforgettable experience you will help to upkeep as a porter. Each hotel room offers magnificent views of the historic St Paul's Cathedral, Melbourne's City Square, or the stunning Paris end of Collins Street.
If you have a polite and friendly manner, this job might suit you well. As a hotel porter, based in reception or at the porters' desk, you will often be the first person to greet the guests. You need customer service skills to welcome guests and see to their needs. You should have a smart appearance, and should also be physically fit, for carrying luggage.
A job working for this prestigious, global brand hotel will look amazing on your hospitality resume. Work here for 6 months then travel Australia, return home with money in your pocket, or stay for another 6 months and work for a different hotel!
Your work as porter may include:
- helping guests by carrying luggage
- advising on hotel facilities
- arranging taxis and booking tickets
- running errands, such as taking and picking up dry cleaning
- taking messages
- giving directions
- responding to safety and security issues
- answering queries and making reservations.
Apply HereRequest InfoContact Us


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'A Check on Tyranny:' Judge Rules in Favor of Sanctuary Cities
- Written by teleSUR
- Published in Diaspora
- 0 comments
The U.S. Trump Administration declared last year that federal funds would be withheld from "sanctuary cities" refusing to comply with immigration policies.
U.S. District Judge Edgardo Ramos ordered the administration to award the funds without conditions to "sanctuary cities" that offer protection to undocumented residents, citing the tenth amendment that upholds states' powers.
He is at least the fourth judge to rule against the administration, saying Friday that legal limits on executive authority were "a check on tyranny and the concentration of power."
Ramos' ruling prevents the federal government from withholding any future funds from the Edward Byrne Memorial Justice Assistance Grants. He has also instructed the justice department to transfer funds withheld last year. His ruling marks a victory for six states that had sued the administration in July, including New York, Connecticut, Massachusetts, New Jersey, Virginia, and Washington.
New York City has also filed a separate lawsuit and is one of dozens of cities, including Chicago, Los Angeles, Philadelphia, and New Orleans, that have resisted deportation enforcement.
"Today's decision is a major win for New Yorkers' public safety," said New York Attorney General Barbara Underwood in a statement.
Federal judges in Pennsylvania, California, and Illinois have previously ruled against the policy. The 7th U.S. Circuit Court of Appeals has upheld the ruling from Illinois, finding that Congress, and not the administration, has the authority to decide how the funds are spent.
The six states that filed lawsuits received grants totaling US$25 million in the last fiscal year. They said they were given an Aug. 10 deadline to decide whether to accept the funds on those conditions.
Last year, the Trump administration announced that state and local governments must give federal immigration authorities access to their jails and advance notice of immigrants' release from custody in order to receive that funding.
As part of that policy, the Justice Department has sought to punish cities and other local jurisdictions that have joined a growing "sanctuary" movement aimed at shielding illegal immigrants from stepped-up deportation efforts.
Trump has made tougher immigration enforcement a centerpiece of his presidency, most recently with a reactionary asylum ban to the migrant exodus from Central America, who have traversed thousands of miles through harsh conditions in the hopes of reaching the U.S.
- Countries: United_States
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This business list contains veterinarian names, addresses (including clinic names in most cases) and telephone numbers from across Australia. The list has been compiled from various veterinary member lists, Yellow Pages, veterinary marketing companies and other sources.
The names of veterinary clinics may be extracted and rented separately.
Records are regularly updated.
One Contact per Address-Number of Clinics:
Rental (One Use Only) Rates
Data Type
Rate per 1,000 Records
Set Up
Minimum Order
Postal Data
Rates From: $300.00
Telemarketing Data
Postal & Telemarketing Data – Defined Selection (at List Owners discretion)
From: $1200.00
Ø 10,000 Records
Rates From: $280.00
Please Note: When accessing both Postal & Telemarketing data for the entire file this maybe deemed as purchase. The purchase price is four times the rental cost.
10% GST applies to all pricing, including the minimum order requirement.
2-3 Working Days
Know who you're looking for? Provide us with your contact details and an overview of your target audience or marketing needs and we'll get back to you quickly with impartial advice and recommendations.
Copyright 2012 Impact List | Ph: 1300 554 671 | Email: firstname.lastname@example.com | Website by Kudos Web


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This library contains research reports produced by the Building America program and other building science resources used to support this Solution Center. The materials cover both new construction and existing homes. Use the search box and/or the filters to explore hundreds of residential building resources. Access to some references not produced by Building America may require purchase from the publisher. Documents are listed alphabetically. While we continually update our database, links may have changed since posting. Please contact our webmaster if you find broken links.
This report describes how twenty homes were tested and monitored in the Zone 2 climate of Houston, Texas, U.S.A., to evaluate the humidity control performance and operating cost of six different integrated dehumidification and ventilation systems that could be applied by production homebuilders.
In this report, BSC seeks to research and report on the field monitoring of the performance of in-situ supplemental dehumidification systems in low-energy, high performance, homes in a Zone 2 climate.
This report evaluates the performance of variable-capacity comfort systems, with a focus on inverter-driven, variable-capacity systems, as well as proposed system enhancements.


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Claus Ejner
Claus Ejner is a multidisciplinary artist, whose works include cartoons, photography, poetry. collages, drawings, performances and video. He is educated from the Art Academy of Jutland and recieved the 3 year bursary scheme from the Danish Arts Council in 2013.
At Hitparaden 1 Claus Ejner performed "performance om det at være til"


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I am the Geekzone Robot and I am here to help. I am from the Internet. I do not interact. Do not expect other replies from me.
martyyn: Really ?
I bought mine more than second hand two years ago and it's been great. My wife's is a year old (second hand) and that's been great too.
Just like anything I suppose, you take your chances.


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penitentiary(redirected from penitentiarily)
Also found in: Dictionary, Thesaurus, Legal.
penitentiary:see prisonprison,
place of confinement for the punishment and rehabilitation of criminals. By the end of the 18th cent. imprisonment was the chief mode of punishment for all but capital crimes.
..... Click the link for more information. .
Place for the imprisonment of inmates and for their reformation through discipline and work.
1. (in the US and Canada) a state or federal prison: in Canada, esp a federal prison for offenders convicted of serious crimes
2. RC Church
a. a cleric appointed to supervise the administration of the sacrament of penance in a particular area
b. a priest who has special faculties to absolve particularly grave sins
c. a cardinal who presides over a tribunal that decides all matters affecting the sacrament of penance
d. this tribunal itself
3. US and Canadian (of an offence) punishable by imprisonment in a penitentiary


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22 Feb 2006
SSIS Connection Object and Expressions
I have been writing a custom source adapter that uses a file connection within the connection manager. If I hard-code a specific file then the component works. However if I use a file connection that has an expression defined which updates the connection, for example when you have a for-each loop looping over a set files. The file connection doesn't seem to re-evaluate expression each time you access the file connection via the code.
Posted by Steve Wright at 17:48 No comments: Links to this post
9 Feb 2006
SSIS Variable Deadlock
I have noticed a problem with the script task within SSIS. The problem occurs when a script task encounters an error and the SSIS on-error event also has a script task that uses a variable that is being locked by the script task that raised the error. The problem seems to be that the SSIS on-error event fires and runs before the script task that raised the error has finished and released its lock on the variable. I have even tred to overcome this problem by using a try/catch block to release the variable locks but this also failed to resolve the problem.
Posted by Steve Wright at 14:46 1 comment: Links to this post
SSIS Changes Database Settings
I have a SSIS package with a simple data flow task, which takes data from a flat file and loads it to an OLE-DB destination (which is configured to use Native OLE-DB\Native Client). As I ran the package via the command-line I noticed that SSIS made changes to the database options. One of the most important options that were being changed was the database recovery model which was modified to run under Bulk-Logged. This changing of the recovery model could cause problems for the back-up and recovery procedure if you are using incremental transaction log back-up as Bulk-Logged will not allow this to run. I can understand why SSIS makes this change because Bulk-Logged does not write any data to the transaction log for Bulk operations. For this reason it does not allow incremental log back-ups and always recommends that you do a back-up of the database when you change back to Simple or Full mode.
Posted by Steve Wright at 14:45 No comments: Links to this post
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Supa Fresh's Website!
Become a 2019 CSA Member!
To cultivate Self-Sufficient, Confident and Joyful youth who Enthusiastically pursue their career and life goals through internships, training and entrepreneurship.
What is the Supa Fresh Youth Farm?
The Supa Fresh Youth Farm is an established Social Purpose Enterprise that has employed and trained underserved youth, ages 16-24, in the Tigard-Tualatin School District (TTSD) and Southeast Washington County since 2009, and serves as a learning space that provides rich experiential vocational opportunities for youth.
The Supa Fresh Youth Farm is a component of the YouthSource program, and is administered by the non-profit organization, the Oregon Human Development Corporation (OHDC), located in Tigard. YouthSource is funded by Worksystems Inc. through a grant from the Department of Labor, The City of Tigard, as well as other grants, corporate and private donations, and farm profits.
The Supa Fresh Youth Farm, which started with just four raised beds at the Durham Education Center Alternative High School, has grown into a learning space that includes three additional 1/4 acre farms, located at the Bethlehem House of Bread/home of the Hub High School Reengagement Program, Metzger Elementary School and Durham Elementary School, in beautiful Tigard, Oregon. The farm employs up to 50 youth per year in paid internships that include Work Readiness Training, Leadership Development and Support Services. The hands-on, student-centered approach to learning at the farm empowers and supports youth to learn by doing.
At the farm youth earn money, develop transferable work skills and earn school credits while learning about sustainable agricultural practices, environmental stewardship, and healthy nutritional habits. Youth also develop entrepreneurial skills, learn about business management, customer service, marketing, and teamwork by running a farm stand, farmer's market booth and operating a CSA.
The farmers grow a variety of produce, herbs and flowers using sustainable, organic methods. We use ZERO chemical fertilizers, pesticides or herbicides on their crops. Visit us at our farm stand on Wednesdays afternoons and ask the farmers how we grow our crops. Know thy farmer!
Proceeds from the farm go toward paying the farmers and purchasing tools and supplies, and 15% of the produce grown at the farm is donated to an onsite food pantry.
Who are the farmers?
They are hardworking youth from the Tigard-Tualatin area, who want to learn employment and life skills while making the world a better place.
They are the future.


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Because many of your everyday duties and social engagements likely take place outside of your home, you probably spend much of your time on property owned or operated by other individuals. Friends' homes, schools, stores and your work location likely all fall outside your property line. Therefore, other individuals have a responsibility to ensure your safety and the safety of others who may set foot on the premises.
Hold responsible parties liable for a dog attack on your child
Many individuals understand that when a child experiences a traumatic event, the repercussions of that event could prove long-lasting. For cases in which a child has suffered serious injuries due to a dog attack, physical and emotional scars could follow the child well into adulthood. In many cases, victims of such incidents may develop a fear of animals that could hinder parts of their everyday lives.
Be prepared for anything in a slip-and-fall case.
Most people think of slip-and-fall premises liability lawsuits as some of the simplest legal claims. In many ways, this is true: slip-and-fall claims can settle quickly in most cases and if the case is strong, they can be simple to win.
Several Temple University students injured in flash mob attack
A recent "flash mob" style attack on Temple University students has resulted in four arrests and at least eight injuries. The flash mob started from a seemingly innocent gathering for a movie showing at Pearl Theater in North Philadelphia and resulted in random acts of violence. 150 teenagers gathered near the theater and began attacking university students returning to campus from the Temple football game.


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Planning for a 'troublesome' beneficiary
Sometimes we don't like to admit it but we often find ourselves with loved ones that raise additional concerns. Today I want to share some thoughts about planning for beneficiaries that may have an alcohol, drug or gambling addiction or even for a beneficiary in a difficult relationship.
While a basic estate plan is often centered around a Simple Will, power of attorney, and Health Care Proxy, a Simple Will does one thing- it distributes your estate to the intended beneficiaries. When someone is the beneficiary of an estate, the appointed fiduciary will simply write that person a check in the amount described in the Will and go home. Studies show that most people spend the entire inheritance within a few years. The real problem arises when a beneficiary has an issue such as a gambling addiction. It can be a matter of days or weeks before that money belongs to the casino. Unfortunately, the drug addicted will sell almost anything for a fix; sadly it also won't be long before your hard earned money is gone. These issues are very important because nobody wants their hard earned money to contribute to a terrible affliction- you likely want your money to ensure that this beneficiary has a roof over his or her head or is otherwise cared for.
Additional considerations are difficult relationships of beneficiaries. If a loved one and potential beneficiary cannot manage their own money or is in a relationship where their significant other may blow money that doesn't belong to them, or can possibly just steal the inheritance, these issues must be accounted for and discussed with you estate lawyer when crafting your estate plan.
Once somebody passes away, either without an Estate Plan or with an Estate Plan that simply did not include the various protects available, it is too late for that money to be protected and spend properly. As noted in my previous article "Why making your own Will is a bad idea" you only find out the lost potential once it's too late.
There is a simple way to protect the beneficiaries discussed above from themselves, from outside creditors or from bad partners and it's called a Trust. The Trust comes in many shapes and sizes and is often referred to as a mythical being that people often shy away from. Trusts dates back a thousand years and have always been used to protect, hold and distribute property. A trust is its own being, a trust can hold legal title to assets and own bank accounts but the trust is also nobody. The trust is the Trustees. Trustees are like managers of the trust and are fiduciaries bound by the terms and conditions of the trust.
With a trustee, you can direct your trustee, the person who controls the assets in the trust to spend the money for the benefit of your intended beneficiaries or direct that the trustee only distribute money if they know it will not be used for unintended purposes such as gamble, drugs or creditors. For a free consultation on how to best accomplish estate planning for your specific and unique family please call us at (718) 838-3334.Read More
Why making your own Will is a bad idea
Too many people think the 'do-it-yourself' (or DIY) Will is the way to go. They think they will be saving money. They think "how hard could it be?" What most people don't think about is, "what if you get wrong?" Would you even know if you were doing it wrong- you wouldn't. The scary answer is, you wont know until a lawyer reviews it. if your self-executed Will to lawyer then you can get a professional opinion (the will be to have a lawyer do it-because of estate litigation issue that can arise, the best defense is having had a lawyer draft and supervise the execution- look out for an estate litigation article on this topic).
So now your nominated executor (if you nominated one as necessary in your DIY Will) your self-executed, do-it-yourself Will goes to Court to probate it and finds out that it may not be good. What now?
What if your kids don't end up with the people you want them to? What if that deadbeat brother of yours gets a sizable inheritance because you didn't disclaim him correctly? And what happens if you child has a debtor that comes to take their inheritance because you didn't protect it properly.
These are issues that are easily avoidable but that unfortunately arise ever single day. There is simply too much at stake and risk of irreparable harm is too high to risk not have a professional involved in your estate planning process.
Estate planning and Will drafting is undertaken with an eye toward protecting the end product from unforeseen issues. The laws and rules surrounding Wills, are not unforeseen to those experienced in the field.
Our office has handled many DIY Wills that did not ultimately carry out the decedent's wishes.
Doing you own documents may be cheaper in the short terms but may cost you and your family significant time, effort and money in the future. For a free telephone consultation, please call our office at (718) 838-3334.Read More


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Gift Certificates can be ordered with a credit card here
(leave your name, telephone number & recipient's name and address in the notes section of the order).
Or, by telephone 714-470-2329.
Gift Certificates will be mailed within 2 business days or can be picked up.
Mark B…. on Yelp"Ever want to get a gift for a lady? Mom, girlfriend, sister, cousin, business associate, customer, whatever? Women love facials. I have no idea why, but if you get them a gift of a facial from Tamara, they thank you and love you for getting it for them. Better to get such a gift from an actual real person too. Tamara is a quality individual and a business owner who cares about her clients. She is not a corporation. Service will be personalized and every one of my friends and relatives I have sent to Tamara not only are happy, but go back to her on their own. Try it out! Giving really works when you give quality like this.


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New Eco-friendly Treated Railway Sleepers
UK Sleepers are reliable and experienced suppliers of New Eco-friendly Treated Railway Sleepers. Our products offer you inventive and cost-effective ways of customising your garden to give it a truly unique touch. We have all kinds of different product options available to make sure you'll be able to find exactly what it is that you're looking for. Nationwide crane vehicle delivery services are available. For more information, just give the product experts in our sales team a call on 01536 267107.
Planed All Round with a bevelled/eased edge to ensure that they are virtually splinter free.£3.25 ex VAT
These Planed All Round softwood garden sleepers are green pressure treated to ensure longevity.£2.25 ex VAT
Manufactured from quality whitewood, the INC15ED range of landscaping sleepers will give added confidence and assurance to your landscaping project.£19.25 ex VAT
Lovely treated softwood that will achieve an attractive silver grey finish with the bleaching effect of the sun within 3 - 6 months, perfect for all garden uses, water features, ...£2.25 ex VAT
Lovely treated softwood that will achieve an attractive dark brown/grey finish with the bleaching effect of the sun within 3 - 6 months, perfect for all garden uses, water ...£5.99 ex VAT
A very useful UK Softwood sleeper that can be used for many landscaping purposes. It can be stacked, placed vertically in the ground or used as path edging. It is treated with ...£2.75 ex VAT
Stylish Moulded, Log lap/Jigsaw softwood sleeper, splinter-free and using log lap style joints. Ideal for construction with minimal required fixings.£4.04 ex VAT
Our newest, most cost effective machined sleeper for use in landscaping, gardening, raised beds etc.£7.50 ex VAT
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Three years ago, today, I started BeautyinBudgetBlog. I can't believe that it has been three years! August 12, 2011 (so long ago!) I started this blog on a whim because I thought it would be fun (which it has been) and as an excuse to indulge my ever-increasing makeup obsession. Despite pretty terrible pictures and not really knowing what I was doing, I found that I really enjoy blogging about beauty and how to work it into a budget. I love hearing that I help people save money by trying cheaper alternatives to products that they've been spending a fortune on. I am so thankful that you all enjoy my posts and take my opinion seriously. It still amazes me that anyone is actually paying attention to what I have to say. I'm thrilled when I hear that someone has found products that they really like as a result of something they read here on my blog. I really appreciate all of the comments and support that you give me. In the last three years, I have managed to grow my blog into something that I can be really proud of. I have almost 600 posts, and well over 400,000 views. I want to thank those of you who have supported me and watched me grow, and that is what this giveaway is all about. I want to give back to you because I wouldn't be doing this blog if it wasn't for my readers. So, as a thank you for sticking with me over the last three years, here are three different prize packages that you can win. I've been collecting products for a while in anticipation for this giveaway.
Prize package #1
- Paula's Choice Skin Perfecting 2% BHA Lotion
- Big Sexy Hair Blow Dry Volumizing Gel
- Covergirl Clean Glow Blusher in Roses
- POP Beauty Bright Up Your Life Eye Shadow Trio in Smokin' Hot
- L'Oreal Infallible Silkissime Eyeliner in Black
- Pixi Beauty Lash Booster Mascara Mini
- Covergirl Colorlicious Lipgloss in Give Me Guava
- Hedy's Ma.nish.ma Transparent Automatic Lip Crayon in Tangerine
- e.l.f. Essential Lip Balm Tint in Nude and Grapefruit
- e.l.f. Nail Polish mini in Mango Madness
- Bonita Salon Nail Polish in Pink and Wicked Good Time
Prize package #2
- Derma MD Enzyme Cleanser with Pineapple and Papaya
- CoverGirl Classic Color Blush in Rose Silk
- e.l.f. Studio Shadow C Brush
- NYC HD Color trio in Long Beach Sands
- Starlooks Kohl Eye Pencil in Obsidian
- POP Beauty Mascara Mini
- Zoya Nail Polish in Dot
- e.l.f. Nail Polish mini in Desert Haze
- CoverGirl XL Nail Gel Polish in Rotund Raspberry
- Rimmel Show Off Lip Lacquer in Aurora
- Covergirl Colorlicious Lipgloss in Craving Cranberries
Prize package #3
- Freeman Feeling Beautiful Pumpkin Peeling Mask Travel Size
- Freeman Feeling Beautiful Pomegranate Facial Revealing Peel-Off Mask Travel Size
- e.l.f. Zit Zapper
- The Body Shop Coconut Body Milk Travel Size
- Urban Decay 24/7 Glide-On Eye Pencil Mini in Zero
- Ulta Amped Lashes Volume+Defining Mascara
- e.l.f. Essential Glitter Primer
- e.l.f. Studio Long-Lasting Lustrous Eyeshadow in Toast
- e.l.f. Studio Pigment Eyeshadow in Golden Goddess
- e.l.f. Nail Polish mini in Jazzy Berry
- Nicole by OPI Roughles Polish in On What Grounds?
- Nailtini Straight Up Color Nail Lacquer in Caviar Cocktail
- Covergirl Colorlicious Lipgloss in Berrylicious
- L'Oreal Glossy Balm in Vintage Rose
Wow, that was a lot. Be sure to let me know what your preference is when you enter. The first winner I choose will get their first choice, the second winner will get their first choice, or second if the first was taken and so on. If you don't order your preferences, I will assume that you are equally happy with any of the prize packages, and I'll choose one for you. To enter, my usual rules apply.
- You must be a subscriber to this blog (I check). If you are not yet a subscriber, just enter your email address in the box on the right hand side of the page and hit the "Sign me up!" button. A confirmation email will be mailed to you to verify that your address is a real one. Once verified, you will receive email updates (you set the frequency) of any new posts so that you won't miss a thing here on BiBB. Or, if you have your own WordPress blog, "follow" me here and sub that way.
- You must provide a valid email address so that when you win I can get your shipping details.
- You must be willing to provide me with your mailing address so that I can ship your prize. US only, please. If you are under 18, you must have explicit permission from your parents to give out your address. I don't want any angry parents, so be honest kids.
- You must leave a comment on this post in order to be entered. Tell me something that you have gotten out of reading this blog. What was your favorite post? Have you discovered a favorite product because of something that you read here? What keeps you coming back? What would you like to see in the future? Anything in that general vein.
You have two weeks to enter. I will announce the winner on Wednesday 8/27. Good luck to you all, and thanks again for 3 great years.
And, don't forget that you still have time to enter my other current giveaway for a duo of Derma MD products.


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Doctor of Philosophy - Mathematical Sciences
UNLV's Mathematical Sciences Ph.D. program is Nevada's only Ph.D. program in the Mathematical Sciences. It is relatively new (established in 2005) and includes concentrations in Applied Math, Pure Math, Computational Math, and Statistics to serve students in many different areas of Mathematical Sciences.
The main part of the Ph.D. is the dissertation. The degree requirements also include: credit requirement, qualifying examination requirement, subject area breadth requirement.
The qualifying examination requirement and the subject area breadth requirement are tailored according to the area of concentration.
For information regarding accreditation at UNLV, please head over to Academic Program Accreditations.
Learning Objectives
- Students will have a broad understanding of several areas of mathematical sciences. They will be able to formulate and solve problems in these areas.
- Students will be able to understand, analyze, create, and write mathematical proofs.
- Students will be able to study and understand mathematical literature.
- Students will be able to produce a piece of original research that is publishable in a peer-reviewed journal.