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text:
This growth is part of a broader boom in live streaming services.Meerkat emerged as a media and tech darling, easily winning the war for attention at this year's SXSW.If a customer was in on the joke, Abuhamdeh would banter with them a bit.
In June of last year, on a whim and mostly out of boredom, Abuhamdeh mounted his phone next to the register and began to broadcast his day on You Now, a live streaming service. People would walk up and pay, he would ring them up, and then as they left, nail them with a zinger spoken to the camera.
But I was nervous, I felt like there were people watching. It was weird." After a few weeks of broadcasting he began to find his rhythm.
A 99 cent tip sometimes gets a broadcaster to smile, while more expensive offerings elicit a personal shoutout, or more intimate reaction.
The company won't share what the revenue split is between streamers and You Now, saying only that broadcasters in the partner program get "the lion's share" of their tips.
Despite myself, I feel a rush of excitement, the thrill of having another human perform just for me.
"The broadcaster is not the only content creator in the room," says Sideman.These cost coins, which you earn from spending time interacting on You Now.Users can also give premium goods, which cost money to acquire.Of course, anyone getting premium goods outside the partner program gets no cut. He tunes in to the channel of a user named Flippin Ginja, a red-headed teen and amateur gymnast who is lounging on his porch swing."Guys, I've been drinking too much water," he tells his smartphone camera.With the press of a few buttons Sideman tips Ginja the equivalent of , along with a message asking him to flip for Ben. Ben this flip is dedicated to you, for being so awesome.

subset: commoncrawl


text:
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The Kiralyudvar winery in Tarcal: inside the wine making facility: stainless steel fermentation tanks and steel containers where the aszu grapes are put, allowing for the Eszencia to collect at the bottom. Kiralyudvar (meaning "King's Court")is run by Istvan Szepsy, considered maybe the best winemaker in Tokaj. he also makes Tokaj under his own name. Credit Per Karlsson BKWine.com
Filename: 030425-kn1-0097.jpg |
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Copyright: Per Karlsson, BKWine Photography
030425-kn1-0097.tif, 3, 5, 6, 7, a, BKWine, central, containers, east, eastern, Europe, Heritage, horizontal, Hungarian, Hungary, istvan, István, Kiralyudvar, Királyudvar, Magyar, metal, noble, North, on, stainless, steel, Szepsy, tanks, Tarcal, tokai, tokaij, tokaj, tokajhegyalja, tokay, vats, viniculture, vinification, wine, WINERY


text:
In re Rossman, 2012 WL 6043279 (Bkrtcy.D.Mass., Slip Copy, Dec. 5, 2012).
United States Bankruptcy Court,
D. Massachusetts.
In re Neil ROSSMAN, Debtor.
Neil Rossman, Plaintiff
United States of America, Department of the Treasury, Internal Revenue Service, and Gary W. Cruickshank, Chapter 7 Trustee, Defendants.
Bankruptcy No. 10–18534–JNF.
Adversary No. 11–1006.
Dec. 5, 2012.
Nina M. Parker, Parker & Associates, Winchester, MA, Roger S. Davis, Davis & Rubin, Quincy, MA, for Plaintiff.
Edward J. Murphy, U.S. Department of Justice, Tax Division, Washington, DC, for Defendants.
Gary W. Cruickshank, Law Offices of Gary W. Cruickshank, Boston, MA, pro se.
JOAN N. FEENEY, Bankruptcy Judge.
*1 The matter before the Court is the First Amended Complaint for Determination of Dischargeability of Indebtedness (the "Complaint") pursuant to 11 U.S.C. sec. 523(a)(1)(C) filed by Neil Rossman ("Rossman" or the "Debtor"). Through his Complaint, Rossman seeks a judgment determining that assessed but unpaid federal income tax liabilities for the tax year 1986 and the assessed and unassessed interest and penalties with respect to those tax liabilities are dischargeable in his bankruptcy case, as well as all penalties, "additions to tax" as that term is used in the Internal Revenue Code FN1 whether assessed or unassessed, which were imposed with respect to a transaction or event that occurred prior to three (3) years before August 5, 2010, the date he filed his bankruptcy petition, are dischargeable, regardless of whether the underlying tax liability is dischargeable. The Defendant United States of America, Department of the Treasury, Internal Revenue Service (the "IRS"), filed an Answer to the Debtor's Complaint. The Chapter 7 Trustee was named as a defendant and served with the Amended Complaint as an interested party but has not participated in these proceedings. FN2
FN1. See 26 U.S.C. secs. 6652, 6653, 6654, 6659, 6661, 6662, 6663 and/or 6621(c) and/or (d).
FN2. The Court shall enter an order dismissing the Chapter Trustee as a defendant as he is not a proper party to the proceeding and the Complaint contains no claim against him.
The Court conducted a two-day trial on August 7, 2012 and August 8, 2012 at which two witnesses testified, Rossman and Donald Guild, a revenue officer and technical advisor with the Special Advisory Group of the IRS located in Boston, Massachusetts. Additionally, the parties introduced numerous exhibits into evidence. Pursuant to post-trial motions, the Court permitted the parties to submit additional exhibits and portions of the deposition testimony of Gerard Miller, an attorney with the Tax Division of the Department of Justice.
The Court has jurisdiction pursuant to 28 U.S.C. secs. 1334(b). This is a core proceeding within the meaning of 28 U.S.C. sec. 157(b)(2)(I). The IRS does not contest this Court's jurisdiction except as to a re-determination of the Debtor's 1986 federal income tax liability under 28 U.S.C. sec. 1334(b) "because, in a no-asset Chapter 7 case such as this, there are no assets to pay any tax claim and thus no bankruptcy purpose for a proceeding under 11 U.S.C. sec. 505."
On May 7, 2012, the Court ruled in conjunction with "Plaintiff's Motion to Strike Declaration of Shelley Modahl and Motion in Limine," that "the amount of the debt owed the IRS is not an issue in this proceeding as no money judgment has been requested." At the commencement of the trial, the Court modified that ruling, stating that reference to the amount of the debt would be permissible to the extent it was germane to the willfulness of the Debtor's belief or conduct resulting from his understanding of the amount he owes the IRS. Additionally, before the trial began, the IRS through counsel indicated that it did not intend to submit evidence regarding the filing of a fraudulent return by the Debtor. Thus, the sole issue in this proceeding is whether the IRS sustained its burden of establishing that the Debtor "willfully attempted in any matter to evade or defeat" any tax owed. See 11 U.S.C. sec. 523(a)(1)(C).
*2 Prior to trial, the parties filed a Joint Pretrial Memorandum, setting forth facts which were admitted and required no proof. Based upon the stipulated facts, the testimony, and documentary evidence, the Court now makes its findings of fact and rulings of law in accordance with Fed. R. Bankr.P. 7052.
A. Procedural Background
The Debtor filed a voluntary Chapter 7 petition on August 5, 2010. On Schedule A–Real Property, he listed a residence located at 455 Puritan Road, Swampscott, Massachusetts, which he owns with his spouse as tenants by the entirety. FN3 He valued the property at $825,000 and disclosed that it was subject to liens held by National Grand Bank of Marblehead, Massachusetts (i.e., a $91,273.53 first mortgage and a $19,218.20 home equity loan) and by the IRS ($1.2 million).FN4 On Schedule B–Personal Property, the Debtor disclosed various accounts, including 401(k) plans, as well as a 90% interest in Benny J Fisheries, a so-called "Subchapter S corporation," a commercial, non-transferable lobster license and related permits, an interest in Neil Rossman, P.C. d/b/a Rossman and Rossman Partnership and a 50% ownership interest in the partnership, and a leased automobile. Rossman valued all assets listed on Schedule B at $234,173.45.
FN3. At the time of trial the Debtor had moved from Puritan Road in Swampscott to 15 Oak Road, Swampscott. His spouse continues to reside at the Puritan Road property.
FN4. On Schedule D, the Debtor indicated that the IRS lien was contingent, unliquidated and disputed.
On Schedules I and J–Current Income and Expenses of Individual Debtor(s), the Debtor disclosed that his expenses exceeded his income, a result which would not be obtained if the expenses associated with Benny J Fisheries were excluded from Schedule J.
On December 14, 2010, the Chapter 7 Trustee filed a Report of No Distribution. Prior to that date, the Debtor commenced the adversary proceeding which is now before the Court. The Court entered a discharge order on January 11, 2011 with respect to all dischargeable debts.
B. Factual Background
Rossman is an attorney and a partner in a small law firm, Rossman & Rossman located in Boston, Massachusetts. He graduated from Wesleyan University and attended Boston University School of Law. In addition he served in the Army, was employed as a career firefighter to finance his law school education, taught school, and worked as a police officer. He is the father of three children.
Rossman testified that he performs a wide variety of legal work for a wide variety of clients. He served as lead counsel in the Dalkon Shield multi-district litigation and has tried cases all over the country for firefighters killed or injured in the line of duty. Rossman's income is primarily from his earnings as an attorney.
In 1985, one year before the onset of the investments which precipitated the current dispute with the IRS, Rossman recovered a $5 million dollar judgment in a case which rested on proof that fire engines were defectively designed and presented an unreasonable hazard to the firefighters who used them. According to the Debtor, the case resulted in a change to the design of fire engines. In conjunction with the action, Rossman received a substantial fee of approximately $900,000, a sum which dwarfed his previous, typical income of approximately $100,000 per year.
C. Rancho Madera Partners and Vista Ag–Realty Partners
*3 Because of Rossman's success in obtaining a large judgment for firefighters, he was solicited by a financial planner, identified as Mr. Robillard ("Robillard"), with whom he shared office space. Robillard presented him with materials regarding investments in two partnerships, Rancho Madera Partners and Vista Ag–Realty Partners, both of which were promoted and operated by American Agri–Corp ("AMCOR"). The marketing materials set forth significant tax benefits for investments in the partnerships, namely a 220% write-off in 1986 for a minimum 30–unit subscription for Rancho Madera Partners, and a 200 % write-off in 1986 for a 35–unit subscription for Vista Ag–Realty Partners. Prior to making any investments in the partnerships, Rossman consulted with his accountant, Paul Johnson ("Johnson"), a certified public accountant. Following his discussions with Robillard and Johnson, Rossman, in 1986, invested $200,000 in Rancho Madera Partners and $100,000 in Vista Ag–Realty Partners.
The Debtor explained his understanding of the investments:
The plan was that the land was being used—essentially it was being held and it was being used to raise crops and specifically grapes and other crops and with the idea that the land ultimately would be developed for shopping centers or shopping malls or sold to a developer who would use it for some other purpose and that there would be a large profit at the end.
* * *
I understood that the money that I could buy into these two-make these two investments with the same money that I would pay for taxes; in other words, the net amount to me was the same.
* * *
But then there was a—would be additional taxes in future years which are outlined on this document as a result of the stream of income in—presumably in future years when I would not have made anywhere near the amount of money that I made in 1986. So the attractiveness of this investment was that it was going to pay me back money in future years when presumably I would not be making—obviously not be making the money that I made in 1986 in a one-time windfall.
Indeed, hand written figures in the margins of the brochures describing the investments highlighted the cash distributions the Debtor expected to receive in the short-term from his investments in the two partnerships, which would then, in his view, be followed by substantial profit when the real estate owned by the partnerships was sold. Specifically, the Debtor expected to receive $42,000 from Rancho Madera Partners between 1987 and 1993 and $165,000 from Vista Ag–Realty Partners between 1989 and 1991, although those sums were insufficient to pay back the share purchase prices.
When asked on cross-examination whether the partnerships were tax shelters, Rossman responded that he had purchased the partnership units as investments, adding
[t]he write off was meaningless to me because I had—the net effect on my taxes was $300,000. So I would either have paid the $300,000 [for the investment]—had I not made the investment, I would have paid $300,000 more in taxes. I would have written the check; I had the money. I made this investment with the same $300,000 that I would have paid had I not made the investment. I had the same amount of money in the checkbook when I made the investment I had the same amount of money left as I would ... have had if I had paid the tax. So there was no financial advantage to me to buy this investment except for the purposes of receiving the money that was projected to be received down the road.
*4 Rossman testified that in the years following his investments, he received "[v]ery upbeat, very happy news," adding that "these investments were making money, that the crops were succeeding, ... the vineyard was a great success and that things were moving along and the—these two investments were increasing and they were moving ahead with plans to do the development for the shopping centers and the shopping malls."
According to the parties in their Joint Pretrial Memorandum, on or about September 14, 1987, Rossman filed his 1986 federal income tax return under the status of married filing separately.FN5 On his 1986 federal income tax return, which was prepared by the accounting firm of Cary & Johnson, Rossman reported wage income of $818,579, interest income of $8,757, non-excluded dividend income of $21,333, a capital loss of $1,500, and a $658,351 loss from "Rents, royalties, partnerships, estates, trusts, etc." The $658,351 reported loss from "Rents, royalties, partnerships, estates, trusts, etc." is described on Schedule E of Rossman's 1986 federal income tax return. The claimed loss consisted almost entirely of a $440,000 loss from Rancho Madera Partners and a $199,543 loss from Vista Ag–Realty Partners. The claimed partnership losses for Rancho Madera Partners and Vista Ag–Realty Partners reduced the amount of total income that Rossman reported on his 1986 federal income tax return to $188,818 and his reported tax to $33,573. The $33,573 in tax reported on Rossman's 1986 federal income tax return was 4.1% of the $818,579 in wage income reported on the return. Because of a $33,074 withholding credit, Rossman reported $499 in tax due on his 1986 federal income tax return
FN5. Rossman testified that he was divorced from his first wife in 1985. The Court presumes that testimony was mistaken and that the divorce was not final until after the return was prepared.
In late November or early December of 1989, the Debtor received correspondence from the "Amcor Limited Partners IRS Audit Committee ." The Committee in its Memorandum with respect to "Funding of Defense Costs to Protect Against Disallowance of Deduction," advised him and other investors that "[t]he IRS is conducting a criminal and civil tax investigation focused on the short term farming activities and first year deductions taken by the AMCOR sponsored partnerships."
The parities also agreed in their Joint Pretrial Memorandum that in March of 1990 the IRS issued Notices of Final Partnership Administrative Adjustment ("FPAA") for the 1986 partnership income tax returns of Rancho Madera Partners and Vista Ag–Realty Partners. The IRS through the FPAAs disallowed the losses that both partnerships had claimed on their returns. Additionally, the parties agreed that by letter dated April 5, 1990, Fred H. Behrens ("Behrens"), the partner in charge of tax matters for several AMCOR partnerships, provided the limited partners, including Rossman, with copies of the FPAAs disallowing the 1986 partnership losses that Rancho Madera Partners and Vista Ag–Realty Partners had claimed on their income tax returns.
Behrens, as the tax matters partner of Rancho Madera Partners and Vista Ag–Realty Partners, contested the FPAAs by filing petitions in the United States Tax Court on June 13, 1990. The cases were captioned Rancho Madera Partners v. Comm'r, Docket No. 12536–90, and Vista Ag–Realty Partners v. Comm'r, Docket No. 12539–90. The parties agreed in their Joint Pretrial Memorandum that Rossman understood that, if the Rancho Madera Partners and Vista Ag–Realty Partners Tax Court petitions were denied and the audit results upheld, he and the other limited partners would owe additional federal income taxes for 1986 than previously reported and paid. Additionally, Rossman agreed that Behrens represented his interests in the Tax Court cases. Although Rossman was solicited by the partnerships to contribute to defense costs, he did not participate in the litigation.
*5 The Tax Court entered decisions in the Rancho Madera Partners and Vista Ag–Realty Partners cases on July 19, 2001, adjusting certain partnership items, resulting in the disallowance of approximately half of the losses reported on the partnership returns. The decisions provided that the adjustments made to partnership income and expense "were attributable to transactions which lacked economic substance, as described in former I.R.C. sec. 6621(c)(3)(A)(v), resulting in a substantial distortion of income and expense, as described in I.R.C. sec. 6621(c)(3)(A)(iv), when computed under the partnership's cash receipt and disbursements method of accounting...." Section 6621(c)(3)(A)(v) of the Internal Revenue Code, which is cited in the text of the decisions, contains a definition of "tax motivated transactions" ("TMT") to include "any sham or fraudulent transaction." Additionally, the Tax Court decisions were the result of a settlement agreement between the IRS and several AMCOR partnerships that was effected through the filing of a "Motion for Entry of Decisions Pursuant to Rule 248(b)." FN6 Under Tax Court procedural rules, Rossman was considered a party to the partnership cases. He testified that he believed that he was bound by the decisions, although he stated he did not participate in the case.
FN6. The terms of the settlement agreements in the Rancho Madera Partners and Vista Ag–Realty Partners cases required the partners to object or otherwise be bound. The terms are contained in paragraph 2(j) of Attachment C to the "Motion for Entry of Decisions Pursuant to Rule 248(b)," and provide in part the following:
Effective upon entry of the Decisions submitted herewith and such Decisions becoming final, and in consideration of the parties' consent to the assessment of interest at the rate prescribed by former I.R.C. sec. 6621(c), respondent [IRS] expressly waives all claims against the limited partners for any additions to tax that might be due under I.R.C. secs. 6653 and 6661 to the extent such claims for additions to tax are based upon the adjustment to partnership items set forth in the Decisions.
The reference in the settlement agreement to I.R.C. sec. 6653 is to the Internal Revenue Code (26 U.S.C.) section codifying the civil fraud penalty, which is now codified at 26 U.S.C. sec. 6663.
D. The Adjustment of Rossman's 1986 Income Tax Liability
In their Joint Pretrial Memorandum, the parties agreed that the IRS notified Rossman by letter dated October 8, 2002 that it had adjusted his personal 1986 federal income tax liability as a result of the decisions in the Rancho Madera Partners and Vista Ag–Realty Partners cases.FN7 Form 4549A, "Income Tax Examination Changes," which was enclosed with the IRS's letter of October 8, 2002, shows that the IRS adjusted Rossman's 1986 income by adding $226,413.00 in income relating to Rancho Madera Partners and $88,409 .00 in income relating to Vista Ag–Realty Partners, resulting in an additional tax amount due of $157,132.00, plus IRC sec. 6601 interest in the amount of $658,607.89 computed to "11/07/2002" November 7, 2002, and TMT interest computed to "1/07/2002 [sic]" in the sum of $195,796.61. According to Form 4549A, the total amount due was $815 .739.89.FN8
FN7. The letter, which was signed by a "Tax Technician," provided:
If you owe additional tax and/or penalties, we will send a billing notice including interest. The interest computation shown on the enclosed report is an estimate. It does not reflect any credits or payments. When the additional tax has been added to your account, you will receive a correct billing. You may want to pay the amount shown on our report, as interest will continue to accrue on any unpaid balance. If you are due a refund, it will be sent to you.
According to the settlement agreement, Internal Revenue Code Section 6621(c), interest at 120 percent of the normal rate applies to the partnership adjustment.
(emphasis supplied).
FN8. The "Amount due" of $815,739.89 set forth on Form 4549A (Plaintiff's Exhibit 24) reflects the addition of $157,132.00 and $658,607.89; it does not include the TMT Interest of $195,796.61. Had the amount of TMT interest been added, the total amount due would be $1,011,536.50. In addition, the Debtor received correspondence from Behrens referencing Form 4549A. In a memorandum dated June 16, 2002, he stated:
Although in some cases the settlement numbers seem unreasonable, please note the following: (1) Recapture Income has been credited, as the net settlement number (the amount disallowed and added to your original year taxable income) has been reduced by the present value of all the partnership income that you reported in subsequent years, and (2) Interest Netting has been factored into the calculation of interest due.
From the date of the actual tax (and interest) bill, you generally have a 21–day, interest free, grace period. As we have no issue with the actual tax amount due (assuming the calculation is correct), we encourage the tax amount to be paid as soon is practicable.
Approximately two months before he received correspondence from the IRS, Behrens, in an August 21, 2002 memorandum, outlined options available to limited partners in receipt of, in his words, "obscene interest assessments," particularly where the decision to settle "was the much-awaited passage of the 1998 tax law, which gave the IRS full authority to mitigate runaway interest in these old, delayed cases" and where, according to Behrens, "[i]n what can only be characterized as a malicious and intentional emasculation of the law the IRS has chosen to ignore the will of Congress." Behrens referenced the following options available to the limited partners: 1) Offer in Compromise (Based on Equitable Relief); 2) Offer in Compromise (Based on Lack of Collectibility); 3) Interest Abatement; 4) Innocent Spouse; and 5) Bankruptcy. In a "Reply Form" attached to the August 21, 2002 memorandum, Rossman, on October 7, 2002, as part of a request for additional information about his eligibility for an offer in compromise, indicated that his IRS liability exceeded his net worth and that he was considering filing a bankruptcy petition.
*6 When asked on cross-examination if he followed the advice proffered by Behrens, Rossman stated that it was "financially impossible" for him to pay the tax, let alone the interest which he discovered on October of 2002 would amount to $658,607.89 pursuant to IRC sec. 6601 and $195,796.61 for TMT interest, in addition to the additional tax amount due of $157,132.00.
The Debtor subsequently received additional communications from the IRS pertaining to his account. On May 12, 2003, he received a notice that he owed $338,897.06, including interest, calculated as follows:
Account balance before this change $810,393.48
Decrease in tax because of this change ($13,207.00)
Additional late penalty since prior change $5,037.37
Decrease in Interest previously charged ($463,326.79)
Amount you now owe $338,897.06
The Debtor received no explanation with respect to the computation. Several months later, on July 14, 2003, he received a similar notice, again without an explanation, indicating that he owed $235,836.31 because of a reduction in the late payment penalty previously charged.FN9 Then, on September 15, 2003, the IRS issued "CP 504" Notice, advising Rossman of the IRS' intention to levy his assets, which reflected a penalty of $658.88 [sic], but no current balance. The Debtor testified that those documents, plus the Notice of Federal Tax Lien, discussed below, were the only documents which set forth the amount of the debt owed the IRS.
FN9. This new figure was computed as follows:
Account balance before this change $338,897.06
Decrease in tax because of this change ($100,000.00)
The late payment penalty that was previously charged has been reduced ($3,060.75)
Amount you now owe $235,836.31
The IRS, in its cross-examination of the Debtor, sought to explain the discrepancies in the amount owed by pointing to a "Brief in Support of sec. 6621(c) Penalty Interest Defense and sec. 6404(e) Interest Abatement" filed on the Rossman's behalf in the Collection Due Process ("CDP") hearing he requested on October 12, 2004. In that brief, his attorney noted that when Rossman was initially sent a Form 4549A (Income Tax Examination Changes) in October of 2002 the Tax Court decision in the Rancho Medera Partners case was not final because of a pending motion to vacate. In other words, the the assessment of penalty interest was not final.FN10 The decision in that case did not become final until sometime in 2003.FN11
FN10. The IRS also pointed to a statement made by Behrens in his June 17, 2002 memorandum that "Redding's actions on behalf of one limited partner has effectively stalled our settlement for two partnerships...." Thomas E. Redding is Rossman's tax attorney.
FN11. The last docket entry in Case No. 12356–90 is June 10, 2003. The Brief filed in the CDP matter references a September 8, 2003 date.
On October 21, 2003, Rossman submitted a claim for a refund to the IRS with regard to the 1995 federal income tax year in the amount of $27,999. Specifically, he requested that that sum be offset against his 1986 federal income tax liability. By letter dated June 3, 2005, the IRS informed Rossman that the claim for a refund had been disallowed and that he could file suit in U.S. District Court if he wished to challenge that result.FN12
FN12. On June 4, 2007, Rossman filed a lawsuit, Rossman v. United States, Case No. 1:07–cv–346–LB, in the United States Court of Federal Claims, seeking a judgment that he was entitled to the $27,999 refund for the 1995 income tax year. He voluntarily dismissed this suit on June 22, 2011.
On June 18, 2004, the IRS issued another Form 4549A. That form reflected an increase in the Debtor's 1986 taxable income with respect to Rancho Madera Partners by $226,413.00, the same amount as set forth in the October 8, 2002 Form 4549A, for a total tax due of $113,206.30, without setting forth any penalties, sec. 6601 interest or TMT interest. The IRS sent this Form 4549A to the Debtor after the Rancho Madera Partners Tax Court decision was final. The IRS did not include an explanation with the 2004 Form 4549A.
E. Administrative Proceedings Initiated by Rossman
*7 On September 15, 2004, the IRS issued a Final Notice of Intent to Levy with respect to the 1986 income tax year, and, on September 16, 2004, it filed a Notice of Federal Tax Lien in the Southern Essex District Registry of Deeds in the amount of $764,701.77. The parties agreed that in response to the Final Notice of Intent to Levy, Rossman, on October 12, 2004, requested a CDP hearing, identifying four issues: (1) whether he was entitled to an abatement of the tax-motivated interest that the IRS had assessed against him pursuant to former I.R.C. sec. 6621(c); (2) whether he was entitled to an abatement of interest pursuant to 26 U.S.C. sec. 6404(e) between 1989 and 1993; (3) whether his claim for refund for the 1985 federal income tax year FN13 should be granted with the refund amount applied toward his 1986 federal income tax liability; and, (4) whether the IRS would accept an offer in compromise.
FN13. The parties recognized that the year 1985 appears to have been a typographical error, as Rossman intended to request a refund for the 1995 income tax year.
Over two and one-half years after Rossman requested a CDP hearing, the IRS sent him a Notice of Determination dated May 10, 2007, informing him that the relief that he had requested in his CDP hearing had been denied and that his remedy was to file a petition with the United States Tax Court within 30 days. In the Notice of Determination, the Appeal Team Manager, Julia D. Whited, stated:
Appeals has verified that all applicable laws and procedures have been followed in your case. The issuance of the Final Notice of Intent to levy is appropriate in your case....
Appeals has determined that you are not permitted to challenge the liability in this CDP proceeding as you had prior opportunity to challenge the liability as defined in IRC sections 6320 and 6330(c)(2)(B). The liability (including the 6621(c) addition to tax) was determined via the entry of a decision in a TEFRA Partnership case (AMCOR). You did not avail yourself to any of the opportunities you had after the decision was entered to challenge the decision. Appeals has no authority to change/alter/modify or otherwise adjust a final decision of the tax court....
With regard to the fourth issue, whether the IRS would consider an offer in compromise, the IRS denied the relief because Rossman had indicated that he had made the determination not to proceed with an offer in compromise at that time.
In the meantime, the Debtor attempted to refinance his home located on Puritan Road, which he and his spouse had purchased in 1993 as tenants by the entirety for $535,000.FN14 They had financed the purchase with a mortgage from the National Grand Bank of Marblehead. In January of 2007, the Debtor and his spouse completed a Uniform Residential Loan Application to obtain a $600,000 loan to refinance the existing mortgages on the Puritan Road property for the purpose of satisfying the federal tax lien which was recorded in September of 2004. They submitted applications to the National Grand Bank of Marblehead and to the Ipswich Cooperative Bank. On March 19, 2007, the Ipswich Cooperative Bank denied the request for a $600,000 loan because the amount of the tax lien was in excess of $700,000 and there was no agreement to subordinate. The Debtor testified that he did not personally submit a request to the IRS to subordinate its lien, but a loan officer at the National Grand Bank was active on his behalf.
FN14. The Debtor testified to this amount. The loan application set forth an amount of $545,000. The difference in the amount is not material.
*8 At the time the Debtor was attempting to refinance his home, his tax attorney, Thomas E. Redding ("Redding") with the firm of Redding & Associates, located in Houston Texas, sent a letter, dated March 8, 2007, to Ms. Elizabeth M. Johnson ("Johnson"), an IRS Appeals Officer in Houston. In addition to advising Johnson that Rossman intended to defer submitting an offer in compromise until resolution of a potential appeal, Redding stated:
Mr. Rossman further proposes to begin making $5,000 per month installment payments on his liability. He is endeavoring to raise additional funds to make a substantial cash payment in addition to the $5,000 per month installments. This has become more difficult than originally contemplated because of having to resolve issue regarding the marital rights of his spouse. Please advise whether the $5,000 payment should be made directly to you or tendered by him as partial payments on the liability as we proceed.
Rossman testified that he did not receive a reply from the IRS to his offer to make monthly payments of $5,000 and that, although he had anticipated obtaining loans in the range $325,000 to $350,000 to pay the IRS, his loan applications were rejected. The Appeals Officer, however, did reply to Redding on April 11, 2007. She stated that if the Debtor wished to make monthly payments he should send them to the IRS center at which he filed his returns with a cover letter identifying the tax year and how the payments were to be applied.
Rossman admitted that he never made any $5,000 payments stating that he could not get the funds necessary to ensure that he could honor the agreement. He explained:
... I was going to make a substantial down payment with part of the refinancing money and I was going to have a reserve of money to ensure that I could meet my obligations each month to make the-to honor the $5,000–a–month installment plan because it was pointed out to me that once you enter into an installment plan or an installment payment you have to honor it and if you deviate from it or miss a payment the IRS will cancel the agreement. So I needed to have a fund of money that could ensure that if I was short in my cash flow each month that I could honor the agreement that I was about to enter into.
Rossman testified that although two banks agreed to refinance the Puritan Road property, the transaction was not consummated because the IRS would not agree to subordinate its lien.
The parties agreed in their Joint Pretrial Memorandum that on June 13, 2007, Rossman filed a "Petition for Lien and Levy Action Under sec. 6330(d)(1)(A) and for Review of Failure to Abate Interest Under Code Section 6404" with the United States Tax Court, namely, Rossman v. Comm'r., Case No. 13515–07L. Through his petition in the Tax Court, Rossman requested "a redetermination of the Commissioner's determinations in his Collection Due Process Hearing." In his prayer for relief, he requested that the Tax Court abate the former sec. 6621(c) penalty interest assessed against him with regard to his 1986 federal income tax liability, abate all interest assessed against him with regard to his 1986 federal income tax liability "from March 19, 1989 to April 1, 1993 under sec. 6404(e)," and allow his 1995 claim for refund as an offset against his 1986 federal income tax liability.
*9 Rossman testified that the purpose of the suit was to provide him relief with respect to the following:
approximately three-quarters of a million dollars in interest and penalty that have been assessed against whatever tax I might owe because through no fault of my own it took 11 and 13 years for the decision to be made on the original 1986 tax returns and so it's looking to challenge the penalty interest and interest that has continued to accrue on whatever original tax I might have owed.
On cross-examination, Rossman testified that although he was aware of the issues in the pending case, he was not familiar with the arguments raised by Redding or the IRS. He did not challenge the increase in the actual amount of tax due for his 1986 federal income tax, which was assessed against him based upon the Tax Court decisions in the Rancho Madera Partners and Vista Ag–Realty Partners cases or the imposition of interest at the standard underpayment rate for any period of time outside of 1989–1993.
The IRS filed an answer in the Debtor's Tax Court case. In March 2008, Rossman and the IRS filed a "Stipulation to be Bound with Respect to Section 6621(c) Issue" in which the parties recognized that the issue of whether Rossman is liable for interest computed using the increased rate of interest for substantial underpayments attributable to tax-motivated transactions under former I.R.C. sec. 6621(c) for the tax year 1986 is the same issue submitted to the Tax Court in cross motions for summary judgment filed in the case of Houston v. Comm'r, No. 001445–06, and that a final decision in that case would bind Rossman and the IRS in Rossman's case. At the commencement of his bankruptcy case and at the time of the filing of the Joint Pretrial Memorandum, Rossman's Tax Court petition was pending, as is the Tax Court matter Houston v. Comm'r. Indeed, the matter has been under advisement for over five years as the last docket entry in the Houston case was on August 20, 2007.
F. Rossman's Income
As noted above the Debtor receives the bulk of his income from his law practice. During the period from 2001 to 2010 inclusive, the Debtor's law firm, Rossman & Rossman made distributions to Neil Rossman, P.C, which in turn, paid compensation to its officers. Rossman reported that compensation as wage income on Form 1040s which he filed jointly with his wife. Although plaintiff's wife had some wage income during this period, her wage income was substantially less than Rossman's income and did not earn any wage income between 2004 and 2009 when she cared for her mother who lived with the family. The tax returns show the following:
Partnership Distribution
Compensation of Officers
Wage Income
Fed. Tax Paid
*10 The Debtor also receives income from a pension from the Town of Swampscott. The amount of the pension currently is approximately $17,000 per year and has increased from $14,000 per year over the past decade.
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BEVERLY, Mass. - The Endicott women's volleyball team got out to a quick start against UMass Boston and wound up claiming a 3-1 win over the Beacons to record the 20th win of the season. The Gulls improved to 20-7 overall after winning by set scores of 25-9, 25-27, 25-16 and 25-19.
Endicott was able to hold the UMass attack to negative hitting percentages in sets one (7-8-34, -.029) and four (6-9-32, -.094), and only .027 (9-8-37) in the third, as the defense anchored the effort in the win. Libero Mackenzie Kennedy (Andover, Mass.) led all players with 20 digs in the win while Zoey Gifford (Natick, Mass.) and Remi Quesnelle (Sunderland, Mass.) recorded 12 digs each. Gifford also added 39 assists and five aces to her night, while Quesnelle matched her with five aces of her own to go with seven digs.
Middle Colleen McAvoy (Coventry, Conn.) produced match-high efforts in kills (15), hitting percentage (.440), and blocks (5), while tying with Gifford and Quesnelle for the match-high of five service aces. Freshman Krystina Schueler (Trumbull, Conn.) finished second on the team with nine kills to go with her three blocks while Amanda Gilbert (Hopkinton, Mass.) finished with six kills and five digs.
- Endicott, the seventh ranked team in the region in the most recent NCAA DIII rankings, is now 5-6 all-time against UMass Boston as the Gulls have won two of the last three.
- The Gulls held the edge in kills (45-36), assists (44-34), aces (17-7), digs (68-62), blocks (8-6) and points (70-49).
- This is the 11th time the Endicott women's volleyball team has reached the 20-win plateau under head coach Tim Byram, who is in his 20th season.
Endicott (20-7, 7-0 CCC) will play host to Western New England tomorrow at 1 PM to wrap up the regular season. UMass Boston (8-18, 5-3 LEC) will play host to Brandeis tomorrow at 1 PM.
For the latest on Endicott Athletics, follow the Gulls on social media on Facebook, Instagram, Twitter, and YouTube.>
(Photo Credit - Nick Grace '20)


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Thanks for your interest in MailChimp Video!
I'm currently working on a detailed video to get you the latest information on this…
But in the meantime…
Checkout the best ClickFunnels offers, benefits, and features below.
In this day and age, the method your organisation operates online can make or break you.
Just how do most businesses currently have a visibility online?
The truth of the matter is, nonetheless, that web sites have substantially progressed over the past decade – and also the techniques of old are no more functional for modern business.
Back then, it would certainly be sufficient to have a straightforward website with a home page, solutions, prices, regarding us, as well as speak to pages.
A prospective consumer would certainly most likely to your site, scroll about, go to the different pages as well as eat content as they please.
Nonetheless, if you are a service investing any money on advertising and marketing, you intend to manage exactly what consumers are learning more about on your website, present deals at the correct time, as well as optimize the income you make from each individual.
How does one accomplish this?
Using sales funnels.
Enter ClickFunnels
ClickFunnels is the most convenient method making high converting sales and also advertising funnels.
It is an one-of-a-kind device produced especially to turn possible clients into customers.
It truly is an all-in-one service to produce sales funnels and also consists of touchdown web pages, email assimilation, billing, webinars, subscription websites, and so a lot more. Not surprising that it has rapidly end up being a preferred device for online marketers.
Below is my thorough ClickFunnels Testimonial, including favorite features, rates, pros/cons, and also contrasts against competitors.
MailChimp Video: However First, Exactly What Is a Sales Channel?
Sales funnels (likewise called marketing funnels) are multi-step campaigns that are created to move prospective leads with your sales process, and transform them into buyers.
Picture a real-life funnel. On top, you pour fluid in, which narrows down towards one fixed location.
In sales, a similar occasion takes place. At the top, visitors arrive at your site, however not all that get in make it out of the various other end as buyers.
Numerous points need to happen from the time a site visitor enters your channel, to the time they take action and successfully finish a purchase.
By damaging down the consumer's journey into smaller sized actions, you could be extra accurate concerning how and when you provide a deal to your audience.
The thorough action in a channel may look something like this:
- Unqualified lead reaches touchdown page
- Web page interacts the very first deal (something complimentary to accumulate an e-mail).
- Once email is collected, main deal is pitched.
- Lead becomes a paying client.
- Even more email interaction providing client worth.
- Further connection structure
- Recurring sales.
ClickFunnels additionally has a graphic that explains this in an easy means:.
What is ClickFunnels?
As pointed out previously, ClickFunnels is the best sales funnel software application around today.
The company makes the vibrant claim of offering you everything you should market, sell, as well as provide your products online – as well as they absolutely supply.
A typical funnel will use an opt-in page (to gather email addresses), an email automobile responder (to send e-mails to your customers), plus an additional sales web page with some content as well as an order kind, potentially adhered to by added web content, a subscription site, and so on
. Previously, you would certainly need to utilize various platforms as well as devices to accomplish all these jobs such as:
- Create a web site
- Locate Hosting
- Find an autoresponder solution
- Find membership site software program
- Discover split-testing software application … etc
However ClickFunnels cares for every little thing with their system. You not only conserve a lots of cash by not having to get various products/services, but you likewise avoid the technological mess of having to set every little thing up, and also could concentrate on exactly what's truly essential – expanding your organisation.
ClickFunnels offers a Complimentary 14-Day Trial, so you get to check out the tool as well as really see if it's appropriate for your organisation.
Preferred Functions
* Promptly Create Pages Using Themes and also Components *.
Before obtaining too far, it's important to understand that a funnel is a collection of pages put together in a calculated order, with the objective of transforming as lots of potential customers into customers. And a page is simply a collection of different aspects made to get a person to take a specific action.
ClickFunnels provides more compared to 50 different aspects to assist you build the excellent web page. The editor is very simple to make use of as well as all you have to do is drag as well as drop various components on to the page, as well as update the text and also look to fit your requirements – no coding abilities required!
ClickFunnels also makes your life simpler by giving you with a lots of complimentary themes.
As a matter of fact, ClickFunnels supplies over 37 sorts of web pages for you to mix and also match with. These are broken down into the following 10 categories:
- Presell Pages: Study Web Page, Write-up Web Page, Presell Page, Clickpop Page
- Optin Pages: Squeeze Web Page, Reverse Press Web Page, Lead Magnet, Promo Code
- Thanks Pages: Thanks Page, Deal Wall Surface, Bridge Web Page, Share Page
- Sales Pages: Video Sales Page, Business Letter Page, Item Introduce Page
- OTO Pages: Upsell Web Page, Downsell Page
- Order Forms: 2 Step Order Page, Standard Order Web Page, Video Clip Sales Letter Order Web Page, Sales Letter Order Page, Item Introduce Order Page
- Webinar Pages: Webinar Enrollment Page, Webinar Verification Web Page, Webinar Broadcast Area, Webinar Replay Area
- Membership Pages: Gain Access To Web page, Participant's Area
- Affiliate Pages: Gain Access To Web Page, Affiliate Location
- Various Other Pages: Application Web Page, Ask Web Page, Store Front, Home Page, Hero Page, Hangout Web Page, Live Demonstration Page
The pre-built themes are fully customizable, as well as are exactly what most individuals utilize.
You have the ability to select a template, edit or change the aspects with your personal, as well as your brand-new web page prepares to go.
You can also connect any type of funnel you develop with your own email advertising solution (if you do not utilize the one included in ClickFunnels), and use the ClickFunnels constructed in invoicing system.
This is likewise a blast to mention that ClickFunnels offers really valuable and also easy to understand training video clips when you initially join. I highly recommend going through those due to the fact that they swiftly allow you to make use of the device at its full capacity, and you'll have much more enjoyable playing around. MailChimp Video
* Create One-Click Subscription Sites *.
Among the very best features with ClickFunnels is the capability to easily produce subscription websites and also deliver material to your audience in one location.
Your subscription website will certainly come complete with registration web pages, membership access pages, and web content pages which you can quickly secure or leak feed to your customers inning accordance with purchases they made in your channel.
ClickFunnels membership websites enable you to send emails, conveniently handle your e-mails, as well as develop a community all while eliminating the tension that's connected with various other options such as Kajabi, or WordPress platforms.
It's really useful to not need to purchase a different software program or plugin to produce membership sites.
* Email Integration & Actionetics *.
With every funnel comes e-mail checklist building opportunities.
ClickFunnels supports email combination with all the major e-mail automation systems such as:
- Active Campaign
- Aweber
- Constant Contact
- ConvertKit
- Drip
- Get Response
- Hubspot
- InfusionSoft
- Mad Mimi
- MailChimp
- Market Hero
- Ontraport
- Salesforce
- Sendlane
- And others
Nonetheless, ClickFunnels additionally has their very own powerful automation device called Actionetics.
Although you could develop, routine, as well as provide emails similar to other email advertising system, Actionetics is so much extra.
I enjoy Actionetics due to the fact that it not just changes your e-mail marketing yet messenger advertising and also SMS advertising and marketing software programs as well. This takes automation to an entire new level and aids you communicate the ideal message to your clients, exactly when they require it. A video introduction of Actionetics will certainly be provided even more listed below.
* Billing and also Payment Assimilation *.
A remarkable function within ClickFunnels is the ability to collect every one of the invoicing information from your customers right on your sales page. Offering is made so much less complicated when customers do not need to leave your website.
ClickFunnels incorporates with significant payment gateways such as PayPal, Red Stripe, and also InfusionSoft, among others.
ClickFunnels Rates.
While you can start with the Free 14-Day Test, there are 3 different rates alternatives with ClickFunnels:
- $ 97/month.
- $ 297/month.
- $ 997 mass price cut plan (advised).
I'll explain for each and every of these plans listed below.
1. ClickFunnels Requirement Strategy – $97/month.
The common strategy consists of all of the features you would certainly need within ClickFunnels, however with restrictions on the variety of funnels (20) as well as web pages (100) you can have in your account, in addition to how many site visitors (20K) can watch your web pages each month.
You additionally do not obtain sophisticated capability such as ClickFunnels very own e-mail advertising and marketing and also affiliate monitoring tools.
2. ClickFunnels Etison Collection – $297/month.
This strategy consists of all the bells as well as whistles of the common plan, without any limitations. It additionally has two added items produced by ClickFunnels called Actionetics (email advertising and marketing) as well as Backpack (affiliate monitoring platform).
In Actionetics – you could handle all your calls that subscribe to your list, send out e-mail programs, as well as create a host of various other automations. MailChimp Video
The difference in between both plans really is the limitations, and Actionetics/Backpack. If you are a basic individual and don't anticipate to make use of more than 20 funnels in your account – the Criterion Strategy ought to be sufficient.
Nevertheless, if you plan to have an associate program or wish to maintain your email advertising and marketing within ClickFunnels as well as not utilize a 3rd party software application, the Etison Collection is for you.
You can constantly begin on the lower strategy and upgrade if required.
3. Funnel Hacks System – $997
For anybody that's severe regarding their business, the ClickFunnels Funnel Hacks System is the deal of the century.
The $997 Funnel Hacks System contains durable training programs bundled with 6-month accessibility to the ClickFunnels Etison Collection.
This is an extraordinary deal because beyond this program, 6-months of Etison Collection alone would certainly cost you $1782.
Not just are you saving $785 but you're obtaining a ton of trainings and also guides to assist you get the most from ClickFunnels!
ClickFunnels Benefits And Drawbacks
- Developing funnels is really straightforward, simple, and also fast
- All-in-one system with everything your business needs to win
- Split testing and conversion monitoring included
- Email combination with every one of the major email autoresponder systems
- Settlement handling abilities within ClickFunnels
- ClickFunnels is constantly adjusting and also updating to the moments
- There is always support readily available (whether online or not).
- Incredibly active Facebook Group Neighborhood.
- Free 14-Day Test – permits you to try it take the chance of cost-free.
- As amazing as ClickFunnels is, it most definitely is not a cheap solution and requires a continuous subscription to make use of
- Assistance isn't really constantly the fastest as well as may take from 1 min to 1 Day relying on the concern.
ClickFunnels versus Everybody Else.
Lots of people ask just how ClickFunnels compares with other touchdown web page home builders such as Leadpages, Unbounce, and also Infusionsoft.
Essentially it's not actually a fair contrast since each of these devices succeeds is one location or the various other.
The graph over offers an extensive analysis – yet I'll highlight a few of the major comparisons below.
ClickFunnels vs Leadpages
Before ClickFunnels, Leadpages was the huge canine.
Leadpages is simply a lead capture software program – nothing even more. You could produce landing web pages, lead boxes, gather leads … that's basically it. Additionally, the Leadpages design templates are additionally limited on customization.
ClickFunnels is even more flexible – it's a lot easier to utilize and also does so a lot more than create lead capture web pages.
Simply put, Leadpages is actually just a touchdown web page home builder, while ClickFunnels is concentrated around building extremely integrated funnels.
ClickFunnels vs Infusionsoft
Infusionsoft is not a touchdown page or sales page home builder. It has a few of that capability built it, but that's not what it's understood for.
At it's core, Infusionsoft is a CRM platform – one that allows you to manage your whole customer database. ClickFunnels has this ability with Actionetics, yet it's not nearly as progressed as Infusionsoft.
Infusionsoft is likewise very pricey as well as pressures every new consumer to pay $2000 for a mandatory kickstart coaching package simply to find out how to make use of the complex system (which is notoriously challenging to utilize).
ClickFunnels Associate Program
There are 2 major courses people decrease as ClickFunnels individuals.
Those that choose to make use of the tool for their organisation – in hopes of someday achieve both Comma Club (over $1M in income).
And those that have an interest in gaining easy revenue as a ClickFunnels Affiliate as well as winning the Desire Car Competition (where they pay $500/$1000 towards your dream car if you reach 100/200 active month-to-month signups, respectively).
With a monstrous 40% regular monthly reoccuring payment, ClickFunnels quickly has among the best associate programs of any type of platform around.
That's right – you get paid a continuous 40% commission on every affiliate signup you make through the ClickFunnels Associate Program. However, just what does that truly equate to?
The fundamental strategy is a $97/month investment as well as the Etison Collection strategy is a $297/month financial investment. for that reason you make $38.80 each basic strategy and $118.80 per Etison Suite strategy … every single month!
On average, every 100 signups will generate $4000/month in associate payments (basically relying on how many Etison Strategy users remain in there).
Go here to get more information regarding coming to be a ClickFunnels Affiliate.
The Bottom Line
ClickFunnels is pass on the best platform if you are seeking to easily construct high transforming sales funnels.
Because it was constructed from scratch to be the very best sales funnel home builder, it beats out all of the competitors in that respect.
Externally, it may not be the most affordable product out there – however if you use it to its full ability, your organisation will certainly come to be extra lucrative as well as you will conserve cash from not having to use various other tools. MailChimp Video
If you have actually reviewed this far right into my ClickFunnels Testimonial, I suggest you see for yourself with a Free 14-Day Test below.


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About FedEx Supply Chain
FedEx Supply Chain, a subsidiary of FedEx Corp. (NYSE: FDX), is a leader in the third-party logistics industry offering a diverse service portfolio that enables commerce for businesses. With a proven track record of innovation and operational excellence, FedEx Supply Chain takes a consultative approach to optimize logistics processes, implement innovative technology and drive continuous improvement. By leveraging best practices and the world-renowned FedEx network, FedEx Supply Chain delivers leading solutions that provide flexibility, enable scalability and improve cost-effectiveness for customers. Through more than 11,000 employees, 130 operations and 35 million square feet of warehouse space, FedEx Supply Chain manages nearly 150 million packages and processes 358 million returns each year. For more information, go to supplychain.fedex.com.
We Have….
- A strong FedEx brand consistently ranked among the world's most admired and trusted employers.
- A top notch leadership team with the experience needed to grow and develop your career.
- An open mind for new ideas and creative methods.
- A strong compensation and benefits package, including health, vision, dental, 401k with a strong match and much more!
General Summary
The EMR Technician 2 (EMR2) description applies to varied job functions in our facility; all with similar levels of skill required, responsibilities, and expectations. The EMR2 is responsible for tearing down and replacing parts in systems. An EMR2 will trouble shoot, diagnose, and determine the most cost-effective course to repair hardware and software issues for a wide range of Tablets, Notebooks, Desktops, and Servers dependent on which Line of Business the Teammate is assigned to. Key job functions may include EG1 DFS (Warranty & Floater), EG3 Conus (Wipe Down).
Primary Responsibilities
- Ability to run production in Burn area to fill in if needed.
- Communicates with operators from other shifts.
- Comply with OSHA and MSDS standards.
- Diagnose and determine issues with system that's needed to be routed to EMR for repair.
- Loads and unloads product in an efficient and safe manner.
- Moves product to storage areas with proper equipment and efficiently stack and store the merchandise in the appropriate area. May pick orders for shipment and assemble various types of merchandise to be shipped.
- Operates any material handling equipment safely and efficiently as required. May use radio frequency equipment or picking, receiving, and storing functions, as required. May drive factory vehicles, forklifts and pallet jacks.
- Ability to Cross train teammates in all currently responsible roles.
- Ensures inbound and outbound shipments are accurate and free of damage.
- Operates within standard operating procedures (SOPs) and Job Safety Analysis (JSAs).
- Participates in physical inventories.
- Performs labeling, sorting, wrapping, packing, and repacking as needed.
- Provides on-the-job training to new teammates.
- Training Burn techs to understand more failure types and how to proceed with specific failures. (Route to Staging and back to Burn to reset BOM, Rest unit, route to EMR for hardware failure).
- Responsible for 5S, maintain a clean, neat and orderly work area.
- Responsible for dispositioning inventory between recovery grades (retail, wholesale, sort and settle).
- Responsible for proper cosmetic inspection, cleaning of product, and following specific guidelines for label placement and orientation.
- Accurately document repair actions in the appropriate database, software tool, tracking log, etc.
- Determines the most cost-effective course of repair and updates disposition of systems
- May be required to perform minor part removal or replacement on product.
- May be required to load/unload and run units inside of an automated "etching" machine, to apply custom logos on product.
- Performs cosmetic repairs on Notebooks, Desktops, and LFF systems
- Ability to utilize the Dell Password Reset utility to unlock units that have bios password locks.
You might be a great fit if….
- High school diploma or GED and 0-2 years of relevant experience.
- Strong problem solving skills.
- Strong PC skills (Word and Excel).
- Excellent communication skills both written and verbal.
- Demonstrated ability to prioritize and handle multiple functions, or tasks.
- May be A+ certified.
- Technical ability to trouble shoot, diagnose and repair systems.
- Familiarity with materials handling and radio frequency equipment is beneficial
- Ability to read and comprehend technical work instructions
With or without accommodation:
- Ability to follow policies and procedures.
- Ability to read, write and interpret information.
- Ability to add, subtract, multiply and divide.
- Ability to use hands to finger, handle, or feel.
- Ability to sit/walk/stand for up to 10 hours per day.
- Ability to intermittently crawl, squat, climb, twist, bend, stoop, push or pull.
- Must possess visual acuity, i.e., close, distance, and color vision, depth perception and the ability to adjust focus.
- Ability to lift/carry items less than 25 pounds.
Working Conditions
Work is performed in a general warehouse environment on a concrete surface with adequate lighting. Temperatures can be very hot during the summer months and very cold during the winter months. Workspace can be very dusty and occasionally noisy due to traffic of motorized vehicles operating.
ADA – FedEx Supply Chain will make reasonable accommodations in compliance with the Americans with Disabilities Act of 1990. Reasonable accommodations are available for qualified individuals with disabilities throughout the subsequent application process.
Fed Ex Supply Chain is an equal opportunity employer. We evaluate qualified applicants without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability, veteran status, and other legally protected characteristics.
Job ID: 27543
Schedule: Full-time


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Latest News
Record numbers at TheYachtMarket.com Southampton Boat Show 2018
Posted on: 27/09/2018
High expectations were met with record numbers at TheYachtMarket.com Southampton Boat Show 2018 A record-breaking 171 new...Read more
Gill Merchandise Partnership
Posted on: 28/08/2018
With perfect timing for the Yachtmarket.com Southampton Boat Show, the CA has entered into a new merchandise partnership with the global sailing...Read more
Southampton Boat Show 2018 Previews
Posted on: 28/08/2018
Celebrating flying the CA burgee for 110 years! See us on our new stand at the...Read more
Daily Prize Draws at The YachtMarket.com Southampton Boat Show
Posted on: 28/08/2018
Throughout the The YachtMarket.com Southampton Boat Show we're giving away one fabulous prize EVERY DAY! Members & new joining members are...Read more
CA Facebook Focus 2018
Posted on: 20/08/2018
And the winners are...! We were delighted to receive over 60 Facebook Focus images fitting our entry criteria over the course of 12 weeks. These...Read more
VHF Radio Checks - who should you call
Posted on: 25/07/2018
The Cruising Association's RATS (Regulations and Technical Services) Committee has been in discussion with the Maritime and Coastguard Agency (MCA)...Read more
News alert from Trinity House: Differential GPS user survey
Posted on: 09/07/2018
The General Lighthouse Authorities of the UK and Ireland are conducting a survey to gauge current and future user requirements for their Differential...Read more
Golden Globe 50th Anniversary Celebration Facebook Competition
Posted on: 09/07/2018
In celebration of the 50th Anniversary of the Sunday Times Golden Globe Race 2018 and the CA's involvement with and support for its Patron Sir Robin...Read more
Failure of throw bag rescue line
Posted on: 18/06/2018
RATS draws the attention of Members to this important MAIB report, attached below. and for them to consider the points in it if they have these or...Read more
Cancellation of London Boat Show
Posted on: 16/05/2018
The Cruising Association responds to the demise of the London Boat Show British Marine, the owners and organisers of the London Boat Show (LBS),...Read more


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Recent Posts
April 1, 2015
I recently had the privilege of teaching the MIRROR MIRROR curriculum to a great bunch of kids here in Sioux Center. Every time I teach kids, I end up learning myself! At our last meeting, I kept the older kids and sent the younger ones with another teacher. The older kids were dramatically relieved to see the younger kids go until I told them why, "I kept you here to talk about sex and purity!" They quickly quieted down and we proceeded to have a great discussion about God's original intent for sex and marriage. I highly recommend having that discussion with your class once a year!
One point we covered was how to guard against the deception or perversion of Satan in this area. The kids gave some great answers, but one stuck out to me. A middle-school aged boy said we can guard against deception by taking the Word of God seriously. I paused then said, "Amen." What more can I say? I was in awe of how this young group valued the Word of God and quite frankly wished that more adults did.
It reminded me of some statistics I read about Chinese Christians receiving Bibles. After a person receives a Bible in China they usually read the entire Bible cover-to-cover in six weeks. Sometimes one Bible will be shared amongst an entire village with many people copying scriptures down on paper to memorize. On average, a Chinese Christian will share their Bible with five others and three of those five people will ask Jesus to be their Savior! Do I value my Bible this much? Do you?
Mark 13:31 says, "Heaven and earth shall pass away: but my words shall not pass away." God's Word has eternal value to us and others. We should take it seriously. Just like my young student said!


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This lovely and simple ceramic carafe by Michelle Organ has an unglazed exterior carafe and cup, and glazed on the inside. Food safe. Can hold both hot or cold beverages. Probably best to hand wash this one rather than put it in the dishwasher.
Carafe measures approximately 17.75cm x 10cm (7" x 4").
Cup measures approximately 7.5cm h x 5.5cm (3" x 2.5").
Handmade in Toronto.


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Plan Including
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