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Docket Nos. 3335-69 2240-70.
William J. Currer, Jr., for the petitioners. Norman H. McNeill, for the respondent.
William J. Currer, Jr., for the petitioners. Norman H. McNeill, for the respondent.
Petitioner husband suffered permanent injuries as the result of an accident. After a protracted period of hospitalization and recuperation, he returned to work and, except for a certain portion of each day, when he engaged in necessary physical exercise, he devoted his full time and attention to his work. he continued to receive his full salary. Held, no part of the payments received was excludable from gross income under sec. 105(c), 105(d), or 106 I.R.C. 1954. TANNENWALD, Judge:
Pursuant to a notice of reassignment sent to counsel for both parties, and to which no objections were filed, this case was reassigned by the Chief Judge on Aug. 9, 1973, from Judge Austin Hoyt to Judge Theodore Tannenwald, Jr., for disposition.
Respondent determined the following deficiencies and additions to petitioners' income tax:
+---+ ¦¦¦¦¦ +---+
Docket No. Year Deficiency Addition to tax (sec. 6653(a)) 3335-69 1965 $3,112.30 $155.62 2240-70 1966 2,177.36 108.87
Petitioners claim overpayments of tax in the amount of 5,770.75 for 1965 and $5,885.79 for 1966. Due to concessions by the parties, the only issue to be decided in the consolidated Dockets is whether section 105(c), section 105(d), or section 106 allows petitioner Robert E. Laverty to exclude from his gross income payments he received from his employer in 1965 and 1966.
Statutory reference are to the Internal Revenue Code of 1954, as amended and in effect during the years in issue.
Some of the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Petitioners are husband and wife who resided in Los Angeles, Calif., during the taxable years involved herein and at the time they filed their petitioners in this case. They filed joint Federal income tax returns for 1965 and 1966 with the district director of internal revenue, Los Angeles, Calif. Robert E. Laverty will hereafter be referred to as the petitioner.
During the years in issue, petitioner was a vice president and director of Thriftimart, Inc. (hereinafter Thriftimart), a corporation engaged in the wholesale and retail grocery business through approximately 150 outlets in southern California and Nevada. Petitioner's father had the dominant voice in the operations of the corporation. He was president until his death in 1968, and petitioner succeeded him in that office. Petitioner's brother was also a vice president of Thriftimart during the years in issue. The Laverty family owned a substantial portion of Thriftimart's stock.
Petitioner began to work for Thriftimart on a full-time basis in 1946. In 1957, he held the position of sales manager. On May 7, 1957, while traveling on business for Thriftimart, petitioner was seriously injured in an airplane crash. He was hospitalized for about 5 months and confined to bed at his home for several months thereafter. He lost the sight of his right eye. Fractures of his jaw, left clavicle, right humerus, and three vertebrae all mended satisfactorily but left him with a permanent partial loss in his range of motion. Severe disfigurement of his face was repaired by extensive plastic surgery so that by 1965 and 1966 petitioner was able to appear in television commercials for Thriftimart, but scars were to a degree still visible on his face and body.
When petitioner had recovered sufficiently from the accident, his physician initially prescribed light exercise with weights in a gym under the supervision of a physical therapist. By May of 1958, petitioner was following a prescribed daily regimen of physical therapy. As his condition improved, his doctor allowed him to substitute regular participation in sports such as golf, tennis, and swimming in place of the physical therapy activities that he found less enjoyable. His physical condition was such that failure to engage in regular physical activity for more than a few days at a time caused the return of certain symptoms he had experienced after the accident, including numbness and a tingling sensation in his lower extremities, muscles spasms, pain and stiffness in his back, and the consequent impairment of his ability to move about. As the years passed, petitioner's familiarity with the prescribed routine of exercise progressed to the point where it was unnecessary for him to visit the doctor regularly. He would consult with his physician only in the event that something new or unusual arose in his condition. During the years in issue, he was able to determine, by the way he felt, the need for any changes in the extent or nature of his physical activity.
Petitioner was unable to return to work for some 10 or 11 months following the accident. When he first returned to his office in Thriftimart's executive office building, it was only for 2 hours a day. As his condition improved, he progressively increased his regular working hours. In 1965 and 1966, he followed the regular weekly schedule described below in regard to his office hours and physical activity. Petitioner frequently had to rearrange this usual schedule, however, in order to accommodate the needs of Thriftimart. For example, he often found it necessary to rearrange his normal schedule in order to meet with other officers and employees of Thriftimart's distant locations such as Thriftimart's warehouses, markets, meatpacking plant, and other facilities.
On Mondays and Fridays during the years in issue, petitioner would usually spend about 20 minutes doing calisthenics before breakfast. He would arrive at his office about 8:15 a.m. and work until 11:30 a.m. At about that time, he would change into a running suit, do some calisthenics to limber up, and then run about a mile in the streets around Thriftimart's office building. He returned to his office about 12:15 p.m., showered, relaxed, and ate lunch. He would then work in his office until about 4:45 p.m. On Tuesdays and Thursdays during the years in issue, he would arrive at his office about 8:15 a.m. and work until 11:30 a.m. He would then leave to play a round of golf, walking the course rather than riding a cart and returning home at about 6 p.m. On Wednesday, he would normally work in his office from 8:15 a.m. to 2:15 p.m., play paddle tennis at the beach from about 3 p.m. to 5 p.m., and return home at 6 p.m. On Saturdays, he would usually spend the morning and afternoon until about 3 p.m. checking Thriftimart's retail stores. He would also spend about a half hour doing calisthenics and swimming in his pool. During the years in issue, petitioner would often fly to San Diego or Las Vegas on Saturday evening, check on Thriftimart's operations in those cities on Sunday morning, and play golf or tennis in the afternoon.
Thriftimart's executive offices were open for the transaction of business every Monday through Friday, except holidays, from 8 a.m. to 4:45 p.m. As an executive of Thriftimart, petitioner had no formal work day as such and was not required to account for his absences during business hours regardless of the business or personal nature of the absence. He had a personal secretary, who was usually aware of where petitioner might be reached at all times during business hours. During the years in issue, petitioner was contacted and conducted Thriftimart's business away from his office or at his home after normal business hours when special matters or emergencies required his attention. He was not paid additional compensation by Thriftimart for 'overtime' work. During the years in issue, petitioner took 4 weeks of paid vacation, including 2 weeks of skiing during the winter.
In 1965 and 1966, petitioner experienced no new or unusual complaints related to the aircraft accident and he had no contact with his physician other than routine examinations and consultations unrelated to his previous injuries.
At all times material herein, Thriftimart was a self-insurer with respect to its workmen's compensation obligations under the laws of California. Pursuant to its workmen's compensation plan, in 1957 Thriftimart paid petitioner's physicians or reimbursed petitioner for medical expenses in the amount of $14,667.85 incurred in connection with injuries suffered in the aircraft accident. On October 9, 1959, petitioner released Thriftimart of all further workmen's compensation claims related to the aircraft accident and received a payment of $2,700. At that time, petitioner's father, who was president of Thriftimart; indicated to petitioner that he would continue to receive his full salary regardless of the amount of time he would be absent from work because of the injuries he suffered in the aircraft accident and his resulting need for a prescribed routine of physical activity.
Petitioner's compensation was fixed annually by Thriftimart's board of directors without petitioner's participation. Since the time of the accident on May 7, 1957, he has received his full salary unreduced for any of his absences from work due to the injuries sustained in the accident. Over the years as he advanced to positions of increased responsibility with Thriftimart's management, his salary has increased commensurately. In 1965 and 1966, his base annual salary was $37,700, plus incentive pay based on Thriftimart's sales. Petitioner's total compensation from Thriftimart was $55,922.52 in 1965 and $54,873.28 in 1966. These amounts were recorded on the books, records, and tax returns of Thriftimart simply as salary.
During the years in issue, Thriftimart had a wage continuation plan for its salaried employees who were absent from work due to sickness or injury. Thriftimart paid each such employee his full salary, reduced by the amount of State disability insurance benefits received, for a period determined by paying 1 week's salary for each year he had been employed by Thriftimart. These payments were recorded by Thriftimart in its payroll records as 'sick leave payments' or 'sick pay.'
In addition to the wage continuation plan, Thriftimart had an unwritten arrangement, known to the employees who might be eligible, that a long-time salaried employee of the corporation who held a responsible position would be paid his full salary when he returned to work after an illness or injury, although such employee may have been unable to be present at work for the entire business day or his productivity may have been impaired by the illness or injury. If such an employee was not expected to recover sufficiently from his illness or injury to permit him adequately to fulfill the duties of his position, he would be given the choice of immediate retirement or reassignment to a new position of lesser responsibility and a correspondingly reduced salary. There were no established rules during the years in issue regarding the implementation of this arrangement— whether or not a particular employee would be entitled to benefits thereunder and for how long was a decision within the discretion of Thriftimart's president.
During the taxable years in issue, petitioner was covered by State disability insurance but submitted no claims to Thriftimart or the State Department of Employment for any illness or disability connected with the 1957 accident.
Petitioner estimated that his need to engage in a daily routine of physical activity caused a 25-percent decrease in his working time for Thriftimart during the years in issue. For that reason, petitioners stated in their Federal income tax returns for 1965 and 1966 that petitioner 'worked on a part-time basis receiving 25% sick pay and 75% salary,' and they excluded from their gross income in each of those years $1,300 of petitioner's salary from Thriftimart, or 25 percent of the maximum exclusion specified in the first sentence of section 105(d). Respondent disallowed the exclusions in their entirety.
Petitioner was a vice president and director of Thriftimart, a large supermarket chain, during the years in issue. As a result of injuries sustained in an airplane crash while traveling on business for Thriftimart several years before, petitioner suffered a total loss of sight in one eye and a permanent partial disability in the range of motion of his arms, back, and lower extremities. For a number of hours in each business day, petitioner was away from his office at Thriftimart in order to engage in a prescribed routine of physical activity necessitated by his injuries. He received salary and incentive bonuses from Thriftimart in the total amount of $55,922.52 in 1965 and $54,873.28 in 1966.
Petitioner now claims the right under section 105(c) or 106 to exclude from gross income a full 25 percent of the total compensation he received from Thriftimart in 1965 and 1966. In the alternative, he asserts the right to an exclusion under section 105(d), as originally claimed in his returns for those years.
Petitioners make a claim in passing that the payments in question are excludable under sec. 104, dealing with workmen's compensation. But they do not press the point and, in any event, it is not a sustainable position. American Foundry, 59 T.C. 231, 237 (1972).
We pause first ti dispose of petitioner's claim for any exclusion under section 106. His reliance on that provision is misplaced. Section 106 has no application to payments an employer makes directly to his employee, such as the compensation petitioner received from Thriftimart. It deals only with the treatment of contributions by an employer to an accident or health plan for the benefit of his employees, either in the form of contributions to a separate fund or trust or by the payment of premiums on a policy of accident or health insurance. H. Rept. No. 1337, 83d Cong. 2d Sess, pp. 15 A35 (1954); S. Rept. No. 1622, 83d Cong. 2d Sess, pp. 185-186 (1954); sec. 1.106-1, Income Tax Regs.
SEC. 106. CONTRIBUTIONS BY EMPLOYER TO ACCIDENT AND HEALTH PLANS.Gross income does not include contributions by the employer to accident or health plans for compensation (through insurance or otherwise) to his employees for personal injuries or sickness.
The main thrust of petitioner's argument centers upon section 105(c) and (d), which exclude certain types of payments under accident and health plans from the general rule of includability in gross income contained in section 105(a).
Insofar as pertinent herein, sec. 105 reads as follows;SEC. 105. AMOUNTS RECEIVED UNDER ACCIDENT AND HEALTH PLANS.(a) AMOUNTS ATTRIBUTABLE TO EMPLOYER CONTRIBUTIONS.— Except as otherwise provided in this section, amounts received by an employee through accident or health insurance for personal injuries or sickness shall be included in gross income to the extent such amounts (1) are attributable to contributions by the employer which were not includible in the gross income of the employee, or (2) are paid by the employer.(c) PAYMENTS UNRELATED TO ABSENCE FROM WORK.— Gross income does not include amounts referred to in subsection (a) to the extent such amounts—(1) constitute payment for the permanent loss or loss of use of a member or function of the body, or the permanent disfigurement, of the taxpayer, his spouse, or a dependent (as defined in section 152), and(2) are computed with reference to the nature of the injury without regard to the period the employee is absent from work.(d) WAGE CONTINUATION PLANS.— Gross income does not include amounts referred to in subsection (a) if such amounts constitute wages or payments in lieu of wages for a period during which the employee is absent from work on account of personal injuries or sickness; but this subsection shall not apply to the extent that such amounts exceed a weekly rate of $100. The preceeding sentence shall not apply to amounts attributable to the first 30 calendar days in such period, if such amounts are at a rate which exceeds 75 percent of the regular weekly rate of wages of the employee (as determined under regulations prescribed by the Secretary or his delegate). If amounts attributable to the first 30 calendar days in such period are at a rate which does not exceed 75 percent of the regular weekly rate of wages of the employee, the first sentence of this subsection (1) shall not apply to the extent that such amounts exceed a weekly rate of $75, and (2) shall not apply to amounts attributable to the first 7 calendar days in such period unless the employee is hospitalized on account of personal injuries or sickness for at least one day during such period. If such amounts are not paid on the basis of a weekly pay period, the Secretary, or his delegate shall by regulations prescribe the method of determining the weekly rate at which such amounts are paid.(e) ACCIDENT AND HEALTH PLANS.— For purposes of this section and section 104—(1) amounts received under an accident or health plan for employees * * * shall be treated as amounts received through accident or health insurance.
Petitioner contends that 25 percent of the total compensation he received from Thriftimart in 1965 and 1966 is excludable from his gross income under section 105(c). He argues as follows: (1) He suffered the permanent loss or loss of use of a member or function of the body; (2) this caused a decline in his productivity for Thriftimart, which can be measured as the percentage decrease in petitioner's normal office hours (which petitioner claims to be 25 percent) due to his absences for the exercise necessitated by his physical condition; (3) despite his loss of productivity, Thriftimart paid petitioner in 1965 and 1966 full salary for the position he held; and (4) 25 percent of such payments were necessarily computed with reference to the nature of the injury and without regard to the period petitioner was absent from work, because during the years in issue he was not absent from work within
Respondent does not dispute that petitioner suffered the permanent loss or loss of use of a member or function of his body within the meaning of section 105(c)(1). See sec. 1.105-3, Income Tax Regs. He takes the position however, that the amounts petitioner received from Thriftimart were simply taxable compensation for services rendered and not payments in the nature of indemnity for the losses specified in section 105(c)(1).
Assuming arguendo that fragmentation of a gross payment can, under certain circumstances, satisfy the requirements of section 105(c), we think it clear that petitioner must fail in respect of his claim. Subsection (1) of section 105(c) requires that the amount 'constitute payment for the permanent loss or loss of use of a member or function of the body, or the permanent disfigurement of the taxpayer.' In other words, the loss must be the cause of the payment. The record herein simply does not sustain the proposition that any portion of what petitioner received bears the necessary casual relationship. First, there is no indication as to what the 'full salary' for the position occupied by petitioner would have been if it were occupied by someone without his disabilities. Secondly, while we do not discount the handicaps petitioner was forced to overcome, there is no indication that his effectiveness as an officer of Thriftimart was in any way impaired during the years in issue. To the contrary, his eventual promotion to Thriftimart's presidency tends to indicate that he more than adequately fulfilled the duties of his position. Indeed, we are satisfied that there was no reduction in petitioner's productivity for Thriftimart. It appears that his practice of working on Thriftimart's business during the evening and on weekends adequately compensated for his absences from the office during the day and that longer hours at the office were not needed to better fulfill the duties of his position. Thirdly, and most importantly, there is no indication that Thriftimart meant to pay petitioner anything other than compensation for the services he rendered. Thus, it does not appear that Thriftimart ever considered a reduction in his salary during the years in issue or had reason to do so. Furthermore, petitioner testified that he was told by his father, who was Thriftimart's president at the time, that petitioner would continue to receive his full salary despite any absences related to the accident.
6. Sec. 1.105-4(a)(5) states:For the purpose of section 105(d), whether an employee is absent from work depends upon all the circumstances. * * * An employee is not absent from work when he performs any services for his employer at his usual place or places of employment, whether of not the services are the usual services performed by the employee. Furthermore, the employee is not absent from work when he performs substantial services for his employer, even though they are performed at a place other than his usual place of employment. Thus, if an employee returns to his usual place or places of employment and performs any services for his employer, he has returned to work, but if he merely holds occasional short conferences concerning his work with other employees or clients while hospitalized or at home recuperating, such conferences do not constitute a return to work.The only specific example of 'loss of productivity' to which petitioner could point a change in his golf handicap from 9 to 16.
Furthermore, the payments that petitioner received from Thriftimart do not satisfy the requirements of section 105(c)(2). The evidence indicates that, within broad guidelines established by his physician, petitioner was free to schedule the timing and duration of his physical activity at his own convenience and according to his own preferences. In fact, petitioner frequently rearranged his routine of physical activity in order to accommodate the business needs of Thriftimart. Thus, while petitioner may be correct on his contention that any payments he received from Thriftimart were necessarily computed without regard to the period he was absent from work (since he was not absent from work within the meaning of section 1.105-4(a)(5), Income Tax Regs.), it cannot be said that any such payments were computed with reference to the nature of his injuries as required by section 105(c)(2).
We turn next to petitioner's alternative claim for a 'sick pay' exclusion under section 105(d). See fn. 4 supra. That section allows an exclusion for payments made in the nature of indemnity for an employee's loss of wages on account of absences for personal injury or sickness. H. Rept. No. 2543; 83d Cong., 2d. Sess. p. 25 (1954). See also Sidman v. United States, 336 F. Supp. 474, 476 (S.D.N.Y. 1971), affirmed per curiam (C.A. 2, 1972).
The term 'wages' found in sec. 105(d) is used in the broad sense to include salary and other remuneration for employment. S. Rept. No. 1622, 83d Cong., 2d Sess., p. 184 (1954); sec. 1.105-4(e)(5)(iii), Income Tax Regs.
See also H. Rept. No. 749, 88th Cong., 1st Sess., p. 44 (1963), and S. Rept. No. 830, 88th Cong., 2d Sess., pp. 49-50 (1964) (the committee report reference to the amendment of sec. 105(d) made by the Revenue Act of 1964, Pub. L. 88-272, 78 Stat. 19)9
The sine qua non of the application of section 105(d) is that the employee be 'absent from work on account of personal injuries or sickness.' Petitioner contends that his absences from the office for a few hours each business day constituted absence from work within the meaning of that section. We think this claim must be rejected. It is clear to us that petitioner was not 'absent from work8' the payments he received were simply compensation for services rendered, and consequently the exclusion of section 105(d) does not apply. Estate of Leo P. Kaufman, 35 T.C. 663, 667 (1961), affd. 300 F.2d 128 (C.A. 6, 1962); Sidman v. United States, supra at 478. Cf. Hall v. United States, 242 F.2d 412, 414 (C.A. 7, 1957). See also secs. 1.105-4 (a)(2) (ii) and 1.105-4(a)(5), Income Tax Regs. See and contrast Niekamp v. United States, 240 F. Supp. 195 (E.C. Mo. 1965).
See also Frank A. Thomas, T.C. Memo. 1969-108; Stanley J. Piwowarski, T.C. Memo 1961-288.
In view of the foregoing, we need not reach the further issue, raised by respondent, as to whether the arrangement under which petitioner received the payments in question constituted an accident or health plan within the meaning of section 105.
To reflect the concessions of the parties in regard to other issues,
Decision will be entered under Rule 50.


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Performance assessment of OpenFOAM and FLOW-3D in the numerical modeling of a low Reynolds number hydraulic jump
|Autores UPV
|Vallés Morán Francisco José, Valero Huerta Daniel, López Jiménez Petra Amparo, García Bartual Rafael Luis, Bayón Barrachina Arnau
|Environmental Modelling & Software
A comparative performance analysis of the CFD platforms OpenFOAM and FLOW-3D is presented, focusing on a 3D swirling turbulent flow: a steady hydraulic jump at low Reynolds number. Turbulence is treated using RANS approach RNG k-ε. A Volume Of Fluid (VOF) method is used to track the airewater interface, consequently aeration is modeled using an EulerianeEulerian approach. Structured meshes of cubic elements are used to discretize the channel geometry. The numerical model accuracy is assessed comparing representative hydraulic jump variables (sequent depth ratio, roller length, mean velocity profiles, velocity decay or free surface profile) to experimental data. The model results are also compared to previous studies to broaden the result validation. Both codes reproduced the phenomenon under study concurring with experimental data, although special care must be taken when swirling flows occur. Both models can be used to reproduce the hydraulic performance of energy dissipation structures at low Reynolds numbers.


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For his English-language debut "My Blueberry Nights," Wong Kar-wai didn't have to churn out a B-movie for a Hollywood studio. Instead, he called his own shots, working with his own production company to make a movie about an American road trip that drew some big stars: Jude Law, Natalie Portman, Rachel Weisz. Min Lee reports.
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L-G Jung scraps Wakf board, recommends CBI probe
Lieutenant Governor Najeeb Jung on Friday dissolved the Delhi Wakf Board and cancelled the appointment of Okhla legislator Amanatullah Khan as Wakf Board chairman and Mehboob Alam as its CEO.delhi Updated: Oct 07, 2016 22:44 IST
Lieutenant Governor Najeeb Jung on Friday dissolved the Delhi Wakf Board and cancelled the appointment of Okhla legislator Amanatullah Khan as Wakf Board chairman and Mehboob Alam as its CEO.
Jung also recommended a CBI probe into their appointments and the reconstitution of the board by the AAP government.
The development comes at a time when a three-member committee is reviewing all decisions of the Arvind Kejriwal government that were taken without prior approval of the city administrator. The committee was constituted following the Delhi High Court order on August 4, declaring L-G as the city's administrative head.
Amanatullah was appointed chairman in October 2015 while the board was reconstituted in March this year.
Read more: AAP MLA Khan resigns from govt posts, booked for sexual harassment
The L-G office declared the appointments "illegal and void ab initio", for not having the approval of the competent authority and revoked the notifications concerned.
The secretary (revenue) will now run the affairs till a new board is constituted. The L-G also directed the official to reconstitute the board, which is custodian of a majority of the city mosques, graveyards besides several charitable institutions and commercial properties.
Jung has directed divisional commissioner A Anbarasu to constitute a committee to review the legality and propriety of all decisions taken by the board after its constitution in March 2016 and submit a report within a month.
"In view of the deliberate and persistent acts of illegality, violation of rules, allegations of corruption, possibility of malafide etc, the whole matter related to Delhi Wakf Board is referred to the CBI for investigation," a statement from the L-G office said.
Sacked chairman Amanatullah termed the decision political vendetta. "Procedures were followed under the watch of the divisional commissioner. Why no questions were raised then. Even if the approval was mandatory, why dissolve the board. Post facto approval could be granted as everything was done as per the rules. We are being targeted, as I have been raising voices against the irregularities by previous board members," Amanatullah told HT.
Earlier this month, Amanatullah had filed a complaint with the anti-corruption branch (ACB) alleging irregularities in the development of 62 bighas of Wakf land in Narela in 2006.
Before his complaint, a plaint was filed in the ACB by Mohammad Mustafa alleging recruitment scam in the board in 2016. Two members of the board had resigned alleging "corruption" and "irregularities in appointments" in the regime of Khan, who denied the charges. A team of ACB had raided board office on September 9.
First Published: Oct 07, 2016 22:44 IST


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The latest nerve-shredding adventure thriller in the popular Isaac Bell series from international bestseller Clive Cussler As Van Dorn private detective Isaac Bell strives to land a government contract to investigate John D. Rockefeller's Standard Oil monopoly, the case takes a deadly turn. A sniper begins murdering opponents of Standard Oil, and soon the assassin-shooting with extraordinary accuracy at seemingly impossible long range-kills Bell's best witness, a brave and likable man. Then the shooter detonates a terrible explosion that sets the victim's independent refinery ablaze. Bell summons his best detectives to scour the site of the crime for evidence. Who is the assassin and for whom did he kill? But the murders-shootings, poisonings, staged accidents-have just begun as Bell tracks his phantom-like criminal adversary from the "oil fever" regions of Kansas and Texas to Washington, D.C., to the tycoons' enclave of New York, to Russia's war-torn Baku oil fields on the Caspian Sea, and back to America for a final, desperate confrontation. And this one will be the most explosive of all.Praise for Clive Cussler: Cussler is hard to beat - Daily Mail The guy I read - Tom Clancy The Adventure King - Sunday Express Clive Cussler is the author or co-author of a great number of international bestsellers, including the famous Dirk Pitt(R) adventures, such as Arctic Drift; the NUMA(R) Files adventures, most recently Zero Hour; the Oregon Files, such as Mirage; the Isaac Bell Adventures, which began with The Chase; and the highly successful most recent series, the Fargo Adventures. He lives in Arizona. Justin Scott is the author of twenty-six novels, including The Shipkiller and Normandie Triangle; the Ben Abbot detective series; and five modern sea thrillers under his pen name Paul Garrison. He lives in Connecticut. Find out more about the world of Clive Cussler by visiting www.clivecussler.co.uk or http://www.facebook.com/clivecussler
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Age of myth : Book One of The Legends of the First Empire. / Michael J Sullivan.
Electronic resources
Series InformationLegends of the First Empire.
View other formats and editions
Record details
- ISBN: 9781101965344 (electronic bk)
- Physical Description: 1 online resource.
- Publisher: [Place of publication not identified] : [publisher not identified], 2016.
Content descriptions
|Summary, etc.:
One of fantasy's finest next-generation storytellers continues to break new ground. Michael J. Sullivan's trailblazing career began with the breakout success of his Riyria series: full-bodied, spellbinding fantasy adventures whose imaginative scope and sympathetic characters won a devoted readership and comparisons to fantasy masters Brandon Sanderson, Scott Lynch, and J.R.R. Tolkien himself. Now Age of Myth inaugurates an original five-book series. Since time immemorial, humans have worshipped the gods they call Fhrey, truly a race apart: invincible in battle, masters of magic, and seemingly immortal. But when a god falls to a human blade, the balance of power between humans and those they thought were gods changes forever. Now only a few stand between humankind and annihilation: Raithe, reluctant to embrace his destiny as the God Killer; Suri, a young seer burdened by signs of impending doom; and Persephone, who must overcome personal tragedy to lead her people. The Age of Myth is over. The time of rebellion has begun.Don't miss any of Michael J. Sullivan's Legends of the First Empire novels: AGE OF MYTH | AGE OF SWORDS (Coming soon!)Praise for Michael J. Sullivan "Hair-raising escapes, flashy sword fights, and faithful friendship complete the formula for good old-fashioned escapist fun."-Publishers Weekly, on Theft of Swords "Filled with adventure and clever dialog and featuring a pair of not-quite-heroes whose loyalties to each other provide them with their greatest strength, this epic fantasy showcases the arrival of a master storyteller."-Library Journal, on Theft of Swords "With less gore and a smaller cast of characters than George R. R. Martin's Song of Ice and Fire but equally satisfying, Sullivan's epic fantasy will be gaining fans at exponential rates."-Library Journal, on The Rose and the Thorn
|Reproduction Note:
Electronic reproduction. New York : Del Rey, 2016. Requires OverDrive Read (file size: N/A KB) or Adobe Digital Editions (file size: 1859 KB) or Kobo app or compatible Kobo device (file size: N/A KB) or Amazon Kindle (file size: N/A KB).
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Opinions of Thursday, 22 September 2005
Today, road accident is a dominating issue in all over the places, crowding the pages of the press and the daily conversation of Ghanaians. It appears no single day goes off without you and I hearing about road accidents. I just returned from Lome and on the Ghana portion of the journey, road accidents have littered all the places. Our roads have become our graves; our roads our graves.
Just last two weeks, the country lost three of its doctors through a lorry accident on the Kumasi-Accra road. Less than forty eight hours and on the Kumasi-Obuasi road, fifteen passengers lost their lives. On the same road some four weeks ago, an articulated truck crushed a 207 Mercedex Benz, killing 20 people instantly. Then the re-nominated candidate for the Dangme East District Executive post, Mr Kabutey Caesar, died in a motor accident last Sunday evening, August 28, when he was traveling with his wife and son from Accra to Ada. The other day it got to the turn of Suzzy Williams. Never send to know whom the bell tolls for.
When the president visited survivors of the accident that killed the three urologists, he said ?this is a national tragedy.? The president fell short of talking about the accident that killed 20 Deeper Life Church members, nor did he talk about the death of the galamsey miners, which is also a tragedy to the nation. The issue here is not what the president said or what he did not say. The issue is what is killing us on our roads? Do we have to adopt a fatalistic philosophy, stipulating that whatever happens in life is predetermined and that all events are determined by necessity? Or do we have to accept this as a cynical notion that death is inevitable and that one way by which one can depart from this world to the other is through lorry accident? Certainly not! Accidents on our roads are not our fate; it is a human error.
Road accident is a serious national crisis because it is becoming very common and is robbing the nation of its valuable human resources. Some of the socio-economic impacts include disability, therefore a high dependency burden, and for some victims, the gravity of their disability could render them jobless. With men representing 67% of national casualty, it has serious implications. The casualty is made up of those killed and injured. The implications of this are increasing number of widows and female-headed households. The implications for children are the inability to complete their education or acquire skills for life, making them school dropouts, social destitutes and social delinquents.
There are other less tangible impacts as well, such as the loss of manpower, making society poorer by the loss. Road accidents affect the poor. The poor use the road as pedestrians and cyclists and often ride in open pick-ups and trucks. Although it cannot be said that all poor people are pedestrians and users of public transport, it is a fact that all poor people will be pedestrians and users of public transport, with little access to private modes of motorized transport.
In addition, long periods of hospitalisation worsen the plight of the poor. In situations where they are unable to pay for bills, they are detained, an experience which can affect them socially, psychologically and mentally. Economic impacts of road accidents cannot be glossed over. It is determined that road accidents cost developing countries, which includes Ghana between 1-2% of the GDP. Current estimates show that Ghana loses about US$300m every year through road accidents. The cost does not include pain, grief and suffering. Costs for road traffic accidents include direct costs, namely medical care, property damage and insurance administration and indirect costs include property damage, delays on the roadway, fuel consumption as a result of road accidents and resultant traffic jam, loss of earnings, lost household productivity and environment costs.
As many as 40% of the adult surgical beds in some urban teaching hospitals in developing countries are dented to the treatment of road accident victims. Medical facilities and resources that are to be used for sick patients are diverted for accident victims.
The time has come for us all to examine what is wrong with our roads, our cars and us the drivers and passengers. Without this, we will end up in answers that do not answer; explanations which do not explain and solutions which do not solve.


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Impact Pro Wrestling presents "SuperCup 2011"
New Brockton, Alabama (Old Town Hall)
May 7, 2011
Report by: Josh Boutwell
Tonight (May 07, 2011) Impact Pro Wrestling brought their 2011 SuperCup event to New Brockton, Alabama featuring the legendary Adrian Street. Before the show started B-Smoove came out and sang the "Star Spangled Banner." I swear I've seen this dude at EVERY local Indy show I've ever been to down here in the last several years.
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I think this was billed as Cage vs. Lane Smart beforehand but I'm definitely not complaining about Rayz replacing him. I've seen Rayz several times and he's a fun high flyer. This was a relatively short but still good back and forth match which saw Cage get the win after Rayz went for a Springboard Cross Body and Cage caught him in midair and turned into a TKO for the pin.
-2011 SuperCup Semifinals: The California Kid def. "The Iconic Concept" Victor Cru
Cali Kid already won me over after he came out to Dr. Dre & Tupac's "California Love." Another good match which saw Cru (who won the 2010 SuperCup) go after Kid's arm the whole match and work it over. In the end he cockily went up to the top rope as he was dominating and dove off, but Kid caught him with a Superkick in midair to pickup the win. After the match Cru attacked Kid and slammed his arm into the ring post.
-At this point Chief Little Bear and one half of the SWAT Team, Trooper, came out to the ring. The Swat Team are considered legends here in the Gulf Coast. Trooper said that Cobra hadn't made it yet but he and Little Bear wanted Initial Shock right now. JT Angel & DJ Durst come out with the Monroe Twins (who are unbelievably HOT by the way). They said that they couldn't do the 6-Man Tag Team tonight because Xtreme G wasn't able to make it. Trooper suggests a Tag Match right here so Angel & Durst attack them from behind. As they're beating down the babyfaces Cobra runs out and makes the save. The IPW Commissioner, Uncle Wayne, comes out and says that tonight the 6-Man will happen regardless if Xtreme G is here are now. He says that Initial Shock needs to go find a partner or he will pick one of the Monroe Twins to be their partner!
-"Exotic" Adrian Street w/Miss Linda def. David Prime w/Mad Dog Murdock
How crazy is it that a state as Homophobic as Alabama loves a character like the legendary Adrian Street. They were all over him and he did all the comedic spots you'd figure from him (one of which saw Prime put him in a Bear Hug and Street break the hold by kissing him). Street even took him to school with some old school mat wrestling as well. Street got the win and everyone was happy.
-IPW Tag Team Titles #1 Contenders Gauntlet Match: Smash Mouth Kids (Jon Ryker & Michael DeSade) def. Chris Corbin & Doug "Chains" Williams, Little Luscious & Preston Vernon III, Pit Bull & Tim Haynie, "Pure" Doug Pitt & Michael Enfinger
This was a Gauntlet Match with the winners getting a Tag Titles shot. First two teams out were Corbin & Williams against Luscious & Vernon. The two teams had a decent little match which saw Luscious fly around until the heels (Corbin & Williams) got the win with a Diamond Cutter I believe. Next team in was the Smash Mouth Kids. This was a big man match right here but eventually SMK got the win. One thing is weird as that they were playing babyfaces at this point but then as the next team came out they became heels for the rest of the match. Pit Bull & Tim Haynie were out next. Pit Bull is a midget and as you can guess he got whooped on pretty good. After they were eliminated the next team out was Doug Pitt & Michael Enfinger. I've seen Pitt before but I don't think he was British the last time I saw him. Anyway the two teams had a pretty solid match and Enfinger was beyond awesome. Every time they would tag out he would scream "ROLL TIDE" and he was wearing all crimson with an Alabama t-shirt (and hat when he came to the ring). In the end the big men took the win and now will receive Tag Titles shots.
-The Monroe Twins and Initial Shock came out and gave Uncle Wayne birthday presents for his birthday (which was last week, they said). They gave him some depends and Fiber because, well, he's old. In return Uncle Wayne gave them some soap so they could "wash some of that skanky dirt" off themselves so they can get some work "on the street corners." That's some fine a** skanks if they're skanks, that's all I'm saying. He also gave them some paper bags to put over their heads as well.
-IPW Fusion Champ: Mike Freska (c) w/"Busti" Becki Kennedy successfully defended his title
I'm sorry I didn't catch his opponent's name. He was a really big guy though. He used his power to dominate Freska for most of the match. At one point the GORGEOUS Becki Kennedy got in the ring and actually hit Freska's opponent with a Spinning Headscissors Takeover. In the end they finished with the big guy locking Freska in a Full Nelson and dropping down to his mat as he kept the hold on. Freska tapped but before he tapped his opponent's shoulders were counted down for the 3 count giving Freska the win.
-6-Man Tag Team Match: The Swat Team & Chief Little Bear def. Initial Shock (JT Angel & DJ Durst) & Street Bandit
This was a pretty fun 6-Man Tag that got the crowd going pretty hot. Bandit got a ton of heat and I've seen him several times, he's very good. Initial Shock & Bandit spent the majority of the match picking Little Bear apart in their corner. In the end Cobra got the hot tag and they picked up the win after a Swat Bomb on Bandit. After the match Swat Team dragged the gorgeous Monroe Twins into the ring and started spanking them with their belts. I'm not even going to touch that one.
-IPW Heavyweight Champ: Cameron Frost def. Joshua "Bulldozer" Brewer w/Mad Dog Murdock to retain his title!
I've had a chance to see Frost before but this was my first time seeing Brewer, who was a really big guy that wrestled in bare feet. I'm serious. Pretty solid big man vs. little man (or smaller man) match which saw Frost use a couple high spots including a Slingshot Corkscrew Plancha over the top to the floor. In the end Frost retained his belt after a taking out Murdock and then hitting a Flying Cross Body off the top to get the pin. After the match David Prime ran out (he's tag partners with Brewer) and he and Brewer beat Frost down, hitting him with the Title Belt. Little Bear & Swat Team ran out and chased off the heels.
-Main Event SuperCup Finals: Bryan Cage def. The California Kid to win the Tournament!
This was another really fun match which saw Cage still selling his arm injury from his first match. They told a great story with Kid trying to use high spots to overcome the arm injury, but that ended up costing him to when he hit a Corkscrew Plancha over the top he landed hard on the floor and "injured" his leg. He sold the leg the rest of the match, everytime he would hit a big move he would sell it and Cage worked on the leg the entire match pulling out several submissions. After a final comeback attempt Cage stopped Kid again and locked in a Sharpshooter to force Kid to submit.
Overall, tonight was a really fun show that the fans seemed to really enjoy and everybody worked hard in the ring. This will definitely not be the last time I check out a IPW show.


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The Vietnam War... A Soul Destroyer?
By Darkwing
February 27, 2007 6:23am CST
This is a report sent to me by a friend in Arizona. He lost his brother as a result of the Vietnam War... I just wanted to share it with everybody, as I feel that people outside America, don't really understand the effects this war had on the American population... "We had a very unexpected & special visitor show up to see his brothers' Quilt block while we were in Orland Park. Most of time I have a pretty good idea of who we might be seeing or meeting on our trips with The Quilts but this time I was so surprised when Ed Littell introduced himself that I was speechless! It seemed that Ed was just as surprised as we were... Ed lives in Arizona but happened to be at a convention in Chicago on business when he got a message from his sister in law that we were nearby with The Quilts. Well, it turned out that Ed didn't get a lot of business done at the convention because it meant more to spend some time with us & The Quilts over the weekend, reflecting upon the memory of his brother Stephen. Although I've never met any of Stephen Littell's family in person before, I've always had a sense of personal attachment to this particular piece... Stephens' block...mainly because I know a lot of the history & personal story behind it. I've been in contact with Stephen Littell's widow Barb for quite some time now & she has been a very good friend to me since we lost our founder, Jennie LeFevre in 2004. Barb has given me a source of strength & purpose to carry on Jennie's work. As the weekend progressed Ed Littell, Henry & I got to share a lot of hugs along with many tears reflecting upon Stephens' battle with Non-Hodgkins Lymphoma caused from his Agent Orange exposure. The surprise of meeting & spending time with Ed was indeed an honor. However, there is one moment that absolutely broke my heart & I have made a promise to myself that I must try to work on a solution in the future... During closing ceremonies on the last night of the event they held a Candlelight Vigil where the family members of Veterans lost during Vietnam proceeded to The Wall with a candle which was left there in recognition of their loved one...as Ed stood beside me that night I could feel his heart breaking as he felt he should be doing the same for his brother. Ed left my side & went to stand inside by the Quilt that his brothers block is on. I know how sacred The Wall is to all of us but I believe in my heart that Ed Littell should have been among those recognizing there loved one that night..... Even though Stephen Littell came home from Vietnam he also died as a direct result of his tour of duty there...." This touched my heart, and affored my tears... so, as a tribute to all those who lost near and dear ones in, or as a result of this war. Indeed any war reaps these results, and it pains me to think about them. Please, the powers that be, let them end!
1 response
@samson1967 (7422)
• India
15 May 07
The after affect of war is always disaster! The Nuclear affect at Hiroshima and Nagasaki still persists, affecting even the newborns. Only Peace can put an end to war. May lord grant his peace to everyone.
1 person likes this
15 May 07
Oh boy... I hadn't realised the effects of Hiroshima and Nagasaki still persisted. I guess it all gets covered up by the media... and what was it all for? A small step in the strive for World Power... that all the citizens in those two areas should suffer a lifetime of misery, in seeing the effects in their children. It pains me so to think how some humans can make others suffer so. Samson... I've seen the memorial candles being floated in the river there... what an awesome and tearful sight. I watched in complete silence for ages; the distress and love which burned in those candle flames hit at my heart. I agree with you wholeheartedly... the World needs to live in harmony and respect its fellow World citizens, in order to create a war-free planet, where its children share and care for each other. That would be the ultimate achievement... World Peace. I'll join you in that prayer. xxx
15 May 07
I've found a picture of the Candle/Lantern Floating Ceremony which is held in Hiroshima, annually. An awesome sight indeed. I also would like to make you aware, if not already, of the fact that several areas of the UK remember Hiroshima in different ways, between August 6th and 9th each year. Events are organised by the CND (Campaign for Nuclear Disarmament)each year, the example, in 2006. If only the need for this hadn't arisen... too little too late, I know, but those guys who suffered and are still suffering are not forgotten. Norwich CND will be painting shadows on the pavements in the city centre on the evening of 5th August, and leafleting there the next day, alongside a stall which will have a display linking the Hiroshima/Nagasaki remembrance with U.S. plans for a new generation of nuclear weapons and missile defence. They will also help to organise a church service of remembrance on 9th August at one of the city centre churches, or in the Cathedral. Peace and love to all. x