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The IRS has released the annual inflation adjustments for 2020 for over 60 tax provisions, including the income tax rate tables. The IRS issues these cost-of-living adjustments (COLAs) each year to re...
The IRS has released the 2020 cost-of-living adjustments (COLAs) for pension plan dollar limitations, and other retirement-related provisions.Highlights of 2020 ChangesThe contribution limit for emplo...
The IRS has released guidance that updates Rev. Proc. 2010-51, I.R.B. 2010-51, 883 to reflect changes made to Code Secs. 67 and 217 by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). Rev. Proc. 2010-...
The IRS has released guidance listing the specific changes in accounting method to which the automatic change procedures in Rev. Proc. 2015-13, I.R.B. 2015-5, 419, apply. This guidance updates and sup...
The IRS has proposed updated life expectancy and distribution period tables under the required minimum distribution (RMD) rules. The proposed tables reflect the general increase in life expectancy, an...
The IRS Large Business and International Division (LB&I) and Small Business/Self-Employed Division (SBSE) have issued a joint directive to provide instructions to LB&I and SBSE examiners on th...
The IRS Large Business and International (LB&I) has added a new active campaign to the IRS website called "IRC 965." The campaign's goal is to promote compliance with Code Sec. 965, Treatmen...
The IRS urged taxpayers to act now to ensure the smooth processing of their 2019 federal tax return. This reminder, first in a series, was aimed to help taxpayers get ready for the upcoming tax filing...
A Pennsylvania the trial court's decision dismissing the petition of owners of lots within a subdivision (subdivided owners) to set aside the treasurer's sale of a private street and priva...
Do you ever have an invoice that is paid but it is showing that a client owes you a payment or it was mistakenly applied incorrectly? Well QuickBooks has a feature to solve this issue. The feature is "Fix Unapplied Customer Payments and Credits".
Do you ever have an invoice that is paid but it is showing that a client owes you a payment or it was mistakenly applied incorrectly? Well QuickBooks has a feature to solve this issue. The feature is "Fix Unapplied Customer Payments and Credits".
- Within QuickBooks Desktop, go to "Company" along the top in the gray bar.
- When the drop down appears, please select "Fix Unapplied Customer Payments and Credits" then a window will appear with all unapplied payments & open invoices.
- Please match the payment to the bill/invoice & select "Apply"
- After all unapplied payments and bills are correctly selected, please save this information.
This will help keep all customer balances current and have provide an accurate Accounts Receivable aging summary if you track your receivables.
If you have any trouble with QuickBooks and want professional training please do not hesitate to contact our office.
On June 21, 2018, the U.S. Supreme Court issued its opinion in South Dakota v. Wayfair, a landmark sales and use tax nexus case that will have implications for many online sellers and multistate businesses. The Court ruled, in a 5-4 decision, that a state can require an out-of-state seller to collect sales or use tax on sales to customers in that state, even though the seller lacks an in-state physical presence. Under certain circumstances, an economic or virtual presence can create nexus (a sufficient connection with the state), subjecting a seller to tax collection and remittance requirements in a state.
On June 21, 2018, the U.S. Supreme Court issued its opinion in South Dakota v. Wayfair, a landmark sales and use tax nexus case that will have implications for many online sellers and multistate businesses. The Court ruled, in a 5-4 decision, that a state can require an out-of-state seller to collect sales or use tax on sales to customers in that state, even though the seller lacks an in-state physical presence. Under certain circumstances, an economic or virtual presence can create nexus (a sufficient connection with the state), subjecting a seller to tax collection and remittance requirements in a state.
In Wayfair, The U.S. Supreme Court considered the constitutionality of a South Dakota law (S.D. Codified Laws § 10-64-1, et al.) that requires certain remote sellers to register for, collect, and remit South Dakota sales tax. Under the law, a remote seller has sales tax nexus with South Dakota if the seller, in the current or previous calendar year:
- had gross revenue from sales of taxable goods and services delivered into the state exceeding $100,000; or
- sold taxable goods and services for delivery into the state in 200 or more separate transactions.
The Commerce Clause of the U.S. Constitution requires that a seller have "substantial nexus" with a state before the state can require the seller to collect and remit sales and use taxes. Historically, under a precedent affirmed in the 1992 case of Quill Corp v. North Dakota, this nexus depended on whether the seller had a physical presence in the state. The presence could be through the company's activities or property, or through the activities of its agents in the state. Over time, states have stretched the boundary of this standard by asserting "click through" nexus and affiliate nexus. Now "economic" nexus policies, like the South Dakota law in Wayfair, stretch it further still, with states asserting jurisdiction to impose sales tax collection responsibilities on companies that meet certain sales thresholds.
Considerations for Sellers
Sales and Use Tax Obligations
The Wayfair decision affects companies doing business in thousands of state and local tax-collecting jurisdiction across the country. The most immediate impact will be on sellers with a significant virtual or economic presence in a state that asserts economic nexus. Sellers delivering taxable products or services into South Dakota (and other economic nexus states) will need to determine if they surpassed the dollar amount or transaction volume thresholds for establishing nexus with the state.
Sellers will need to do this analysis for each state that has adopted an economic nexus threshold policy, including determining whether each product sold is taxable or nontaxable.
Sellers should be prepared for states to adopt and aggressively enforce expanded nexus provisions, although future legal challenges or Congressional action could limit the scope of the Court's decision.
Notice and Reporting Requirements
A growing number of states, led by Colorado, recently enacted complex use tax notice and reporting requirements for remote sellers. Under these laws, remote sellers must provide information to customers about potential use tax liability and report transaction data to the state. Noncompliance can result in stiff per-occurrence penalties.
Other Considerations
Expanded sales tax nexus may have far-reaching effects for businesses, beyond collection and remittance of the sales tax itself.
In the realm of business acquisitions, state "successor liability" laws typically impose notice, withholding, and tax clearance requirements that limit the purchaser's liability for unpaid sales tax liabilities of the seller in certain business asset acquisitions. As states begin to more aggressively assert sales tax nexus, companies contemplating business acquisitions should consult with a tax professional for assistance in navigating complex successor liability laws.
Companies should also consider potential financial statement impacts related to sales tax nexus issues.
Next Steps
We expect state revenue departments to issue guidance regarding the South Dakota v. Wayfair decision in the coming weeks and months, and we will be following those developments closely. In the meantime, if you would like to discuss how the decision may impact your business, please do not hesitate to contact us.
The IRS has announced a significant increase in enforcement actions for syndicated conservation easement transactions. This is a "priority compliance area" for the agency.
The IRS has announced a significant increase in enforcement actions for syndicated conservation easement transactions. This is a "priority compliance area" for the agency.
Throughout the IRS, coordinated examinations are being conducted in the Small Business and Self-Employed (SB/SE) Division, Large Business and International (LB&I) Division, and Tax Exempt and Government Entities (TE/GE) Division. The IRS Criminal Investigation (CI) Division has also been initiating investigations. The audits and investigations cover billions of dollars of potentially inflated deductions, as well as hundreds of partnerships and thousands of investors.
"We will not stop in our pursuit of everyone involved in the creation, marketing, promotion and wrongful acquisition of artificial, highly inflated deductions based on these aggressive transactions. Every available enforcement option will be considered, including civil penalties and, where appropriate, criminal investigations that could lead to a criminal prosecution," said IRS Commissioner Charles "Chuck" Rettig. "Our innovation labs are continually developing new, more extensive enforcement tools that employ advanced techniques. If you engaged in any questionable syndicated conservation easement transaction, you should immediately consult an independent, competent tax advisor to consider your best available options. It is always worthwhile to take advantage of various methods of getting back into compliance by correcting your tax returns before you hear from the IRS. Our continued use of ever-changing technologies would suggest that waiting is not a viable option for most taxpayers," he added.
Syndicated Conservation Easements
The IRS issued Notice 2017-10, I.R.B. 2017-4, 544, in 2016, which designated certain syndicated conservation easements as listed transactions. In these types of transactions, investors in pass-through entities receive promotional material which offer the possibility of a charitable contribution deduction worth at least two-and-a-half times their investment. The deduction taken in many transactions has been significantly higher than 250 percent of the investment.
Syndicated conservation easements were included on the IRS's 2019 "Dirty Dozen" list of tax scams to avoid.
Not only do these transactions grossly overstate the value of the easement that was purportedly donated to charity, they often also fail to comply with the basic requirements for claiming a charitable deduction for a donated easement.
Taxpayers may avoid the imposition of penalties for improper contribution deductions if they fully remove the improper contribution and related tax benefits from their returns by timely filing a qualified amended return or timely administrative adjustment request.
Enforcement Actions
The IRS has prevailed in many cases involving the charitable deduction basic requirements, and has established a body of law that it believes supports disallowance of the deduction in a significant number of pending conservation easement cases. The IRS will soon be moving the Tax Court to invalidate the claimed deductions in all cases where the transactions fail to comply with the basic requirements, leaving only the final penalty amount to be determined.
In addition to auditing participants in syndicated conservation easement transactions, the IRS is pursuing investigations of promoters, appraisers, tax return preparers and others, and is evaluating numerous referrals of practitioners to the IRS Office of Professional Responsibility. The IRS will develop and assert all appropriate penalties, including:
- penalties for participants (40 percent accuracy-related penalty);
- penalties for appraisers (penalty for substantial and gross valuation misstatements attributable to incorrect appraisals);
- penalties for promoters, material advisors, and accommodating entities (penalty for promoting abusive tax shelters, and penalty for aiding and abetting understatement of tax liability); and
- penalties for return preparers (penalty for understatement of taxpayer's liability by a tax return preparer).
Rettig, Desmond Highlight Heightened Focus
Rettig and IRS Chief Counsel Michael J. Desmond have each highlighted the IRS's heightened, agency-wide focus on syndicated conservations easements.
While speaking at the American Institute of CPAs (AICPA) 2019 National Tax Conference in Washington, D.C., Rettig and Desmond both separately underscored the IRS's increased enforcement efforts toward abuses of certain tax-advantaged land transactions under Code Sec. 170(h).
"We appreciate the value of conservation easements," Rettig said. "We do not appreciate the activities that have gone on with respect to the syndicated conservation easements—there are some artificial appraisals there… some fatal flaws."
Reiterating the IRS's tough stance on the matter, Rettig said that the IRS is not going to "stand down." The information in IR-2019-182 issued on November 12 was "fair warning," Rettig said.
Likewise, Desmond stressed that the challenges surrounding syndicated conservation easements are an "institutional concern" for the IRS, "one that we will be responding to," he emphasized.
Treasury and the IRS are expected to release proposed rules in "early 2020" that would clarify certain limitations on the carried interest tax break, according to David Kautter, Treasury's assistant secretary for tax policy. Kautter briefly addressed the proposed regulations' timeline while speaking at the American Institute of CPAs (AICPA) 2019 National Tax Conference in Washington, D.C.
Treasury and the IRS are expected to release proposed rules in "early 2020" that would clarify certain limitations on the carried interest tax break, according to David Kautter, Treasury's assistant secretary for tax policy. Kautter briefly addressed the proposed regulations' timeline while speaking at the American Institute of CPAs (AICPA) 2019 National Tax Conference in Washington, D.C.
Carried Interest Limitation
The forthcoming regulations are expected to restrict S corporations from taking advantage of a carried interest exemption provision under the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The TCJA requires certain money managers to hold investments for at least three years before becoming eligible for the lower, 20 percent capital gains rate. However, it exempted corporations from this holding period, which Treasury and many lawmakers on Capitol Hill say resulted in an unintended "loophole."
The proposed regulations are expected to clarify the law's intent that S corporations are subject to the three-year holding period for carried interest, according to Treasury's last press release on the matter issued in March 2018 (see "Treasury, IRS Issue Guidance On Carried Interest," at https://home.treasury.gov/news/press-releases/sm0302).
Legal Questions May Arise
Most notably, however, the TCJA does not expressly contain this limitation on S-corporations, which has left some on Capitol Hill questioning Treasury and the IRS's authority to implement such a restriction via regulations. The IRS on November 15 directed Wolters Kluwer to Treasury for confirmation on this anticipated rule and projected timeline. As of press time, Treasury had not responded to Wolters Kluwer's request for comment.
Hopes for a year-end tax extenders package appear to be dwindling on Capitol Hill.
Hopes for a year-end tax extenders package appear to be dwindling on Capitol Hill.
Tax Extenders Need a Legislative Vehicle
Over 30 expired or soon-to-be expired tax breaks known as tax extenders were originally considered a top contender for hitching a ride on a larger, must-pass government funding bill. Considering the lack of time left on the legislative calendar this year, a stand-alone tax bill has been considered an unlikely initiative. Thus, a must-pass appropriations bill was seen by several lawmakers as the likely legislative vehicle for tax extenders and other tax items such as technical corrections to Republicans' 2017 tax reform law.
However, a spokesperson for Senate Finance Committee (SFC) Chair Chuck Grassley, R-Iowa, confirmed to Wolters Kluwer on October 28 that Grassley believes there is "no hope" for action this year on a tax extenders package if lawmakers do not move quickly with respect to its legislative driver. Many within the practitioner community following these developments have said that the chances of providing taxpayers with certain tax breaks retroactively significantly decrease if Congress moves into next year leaving them expired.
Another Stopgap Spending Bill Appears Likely
Currently, the federal government is operating on a stopgap spending bill temporarily extending fiscal year (FY) 2019 funding levels through November 21. Previously, several lawmakers, in particular Grassley, had hoped that a tax extenders package would be attached to a larger, more comprehensive appropriations bill next month. However, Senate Appropriations Committee Chair Richard Shelby, R-Ala., told reporters that another short-term stopgap spending bill is the more likely option to keep the government open after November 21. "Unless a miracle happens around here with the House and Senate, we will have to put forth another [continuing resolution] CR," Shelby told reporters.
Notably, another short-term government funding bill is considered unlikely to have any policy riders. Generally, stop gap spending bills are usually considered "clean," for the most part. Also playing a role in tax extenders' fate is whether President Trump would sign a more comprehensive appropriations bill. At this time, his support for a larger FY 2020 funding bill, apart from tax policy reasons, remains unclear.
Senate Finance Committee (SFC) Chair Chuck Grassley, R-Iowa, and other top Senate tax writers are calling for Senate action on the bipartisan Setting Every Community Up for Retirement Enhancement Secure bill (HR 1994) (SECURE Act). The House-approved, bipartisan retirement savings bill has remained stalled in the Senate since May.
Senate Finance Committee (SFC) Chair Chuck Grassley, R-Iowa, and other top Senate tax writers are calling for Senate action on the bipartisan Setting Every Community Up for Retirement Enhancement Secure bill (HR 1994) (SECURE Act). The House-approved, bipartisan retirement savings bill has remained stalled in the Senate since May.
SECURE Act's Route to Senate Floor Remains Unclear
Grassley's communications director Michael Zona told Wolters Kluwer on October 21 that it remains "unclear at this point" whether the SECURE Act will move through committee, reach the Senate floor by unanimous consent, or be attached to a larger, year-end tax package. "Grassley supports the House-passed SECURE Act. There are several holds on the bill, and he is working to get them lifted," Zona said.
The SECURE Act cleared the House on May 23 by a 417-to-3 vote. The bipartisan measure, which proposes sweeping changes to retirement savings tax policy, was originally expected to quickly clear the Senate after its approval in the House. However, Sen. Ted Cruz, R-Tex., blocked the bill from reaching the Senate floor. Cruz blocked the bill in protest of House Democrats' 11th hour-removal of a provision from the original bill that would have expanded tax-advantaged Section 529 education savings plans to include homeschooling and certain elementary and secondary expenses. Cruz and Sen. Patty Murray, D-Wash., are reportedly still holding up the measure from reaching the Senate floor.
Catch-All Tax Package
However, the SECURE Act, among other bipartisan tax-related items including tax extenders, could be attached to a catch-all tax package that is expected on Capitol Hill to hitch a ride on a year-end government funding bill. A "must-pass" appropriations bill, like the one currently being negotiated to keep the government open after funding expires on November 21, could serve as the tax package's legislative vehicle, thus fast tracking its approval.
"As the economy continues to change, the way we approach retirement savings must change as well. Otherwise, too many Americans will be left behind," Grassley said on October 21, noting that the SECURE Act is under "active consideration."
Similar to Grassley's push, Sen. Tim Scott, R-S.C., led a letter sent to Senate Majority Leader Mitch McConnell, R-Ky., urging immediate Senate consideration of the SECURE Act. "This bipartisan legislation would expand access to retirement plans for millions of Americans, allow older workers and retirees to contribute more to their retirement accounts, increase 401(k) coverage to part-time employees, prevent as many as 4 million people in private-sector pension plans from losing future benefits, protect 1,400 religiously affiliated organizations whose access to their defined contribution retirement plans is in jeopardy, and do the right thing for Gold Star families," according to Scott.
The Senate blocked a Democratic resolution on October 23 to overturn Treasury rules preventing certain workarounds to the $10,000 state and local tax (SALT) federal deduction cap.
The Senate blocked a Democratic resolution on October 23 to overturn Treasury rules preventing certain workarounds to the $10,000 state and local tax (SALT) federal deduction cap.
SALT Cap Workaround
Senate Democrats' resolution, S.J. Res. 50, forced a vote on Wednesday to nullify Treasury regulations that block taxpayers from circumventing the SALT cap through certain states' programs that convert state and local taxes into fully deductible charitable contributions. The resolution failed by a largely party-line vote of 43-to-52.
Sen. Michael Bennet, D-Colo., voted against the Democratic measure while Sen. Rand Paul, R-Ky., supported it. While the resolution would not repeal the SALT cap itself, House Democrats are reportedly crafting legislation to do so. Democrats and some Republicans, particularly from high-tax states, have criticized the SALT cap since its enactment in 2017 under the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97).
Debate on SALT Cap, Treasury Rules
"Without any clear authority to do so, the Treasury Department reversed a long-standing IRS position that had allowed taxpayers a full deduction for charitable contributions to state tax credit programs," Senate Finance Committee (SFC) ranking member Ron Wyden, D-Ore., said on the Senate floor before the vote. "My view is the Treasury Department should not be putting its thumb on the scale on behalf of Republican interests, and it shouldn't be using phony regulatory justifications to fix Republicans' extraordinarily poorly drafted law."
However, several Republicans cited to a recent report from the nonpartisan Joint Committee on Taxation (JCT), which estimated that repealing the SALT cap beginning in 2019 would result in over $40 billion of the associated tax cut going to taxpayers with incomes of at least $1 million ( JCX-35-19).
"It's bad enough that my Democratic colleagues want to unwind tax reform, but it's downright comical that their top priority is helping wealthy people in blue states find loopholes to pay even less," Senate Majority Leader Mitch McConnell, R-Ky., said from the Senate floor on October 23. "Repealing the SALT cap would give millionaires an average tax cut of $60,000. Meanwhile, the average tax cut for taxpayers earning between $50,000 and $100,000 would be less than ten dollars."
Vaping Tax
In other news, the House Ways and Means Committee approved a bipartisan vaping tax bill, ( HR 4742), on October 23 by a 24-to-15 vote. The bill would establish a $27.81 tax per gram of nicotine used in vaping devices.
Treasury and the IRS on October 31 announced the release of a new, draft form implementing certain reporting requirements under the Tax Cuts and Jobs Act Opportunity Zone program.
Treasury and the IRS on October 31 announced the release of a new, draft form implementing certain reporting requirements under the Tax Cuts and Jobs Act Opportunity Zone program.
The proposed Form 8996 for Qualified Opportunity Funds (QOFs) comes after numerous calls on Capitol Hill for more transparency within the Opportunity Zone program. "The form is designed to collect information on the amount of investment by opportunity funds in business property by census tract," according to a Treasury press release.
Opportunity Zones' Architect Applauds Treasury's Steps Toward Reporting Requirements
Ken Farnaso, press secretary for Sen. Tim Scott, R-S.C., chief architect of the TCJA's bipartisan Opportunity Zone program, told Wolters Kluwer on October 31 that reporting requirements, "an important piece of the puzzle," were, in fact, originally in the bill. "Unfortunately, during the tax reform process, Senate Democrats blocked these requirements from being included in the Tax Cuts and Jobs Act. Since then, Senator Scott has continued working to restore those reporting requirements," Farnaso said.
Additionally, Farnaso told Wolters Kluwer that Scott applauds Treasury's steps to ensure a clearer picture of the impact the Opportunity Zones initiative can have on the country. "Senator Scott will also continue to push for his current bill restoring robust reporting requirements to create a holistic picture of how the initiative is functioning," Farnaso said. "Overall, today is a good day for Opportunity Zones. We look forward to the more than $44 billion in currently anticipated investment being deployed in distressed communities across the nation, and that number growing even larger in the future."
Opportunity Zones Tax Incentive
The Opportunity Zone Program enacted under TCJA ( P.L. 115-97) is considered on Capitol Hill as one of the most generous and ambitious tax incentives for investors in distressed communities. Under Code Sec. 1400Z-2, investors may defer taxation of capital gains that are invested in a QOF.
Generally, the following investor tax benefits were created under the Opportunity Zone program:
- a temporary tax deferral for capital gains realized on the sale of appreciated assets and reinvested within 180 days in a QOF;
- the elimination of up to 10 or 15 percent of the tax on the capital gain that is invested in the QOF and held between five and seven years; and
- the permanent exclusion of tax when exiting a qualified opportunity fund investment held for at least 10 years.
Draft IRS Form 8996
Specifically, the new, draft Form 8996 for the 2019 tax year requires QOFs to report the following information:
- the Employer Identification Number (EIN) of each business in which the QOF has an ownership interest;
- the census tract location of the tangible property of the business;
the value of the QOF's investment; and
- the value and census tract location of qualified business property directly owned or leased.
"This is an important step towards a thorough evaluation of the Opportunity Zone tax incentive," Treasury Secretary Steven Mnuchin said. "We want to understand where Opportunity Zone investments are going and strengthening the economy so that investors and communities can learn from the successes of this bipartisan, pro-growth policy."
Generally, the collection of this information will play a role in allowing lawmakers and the public to evaluate the effects of the tax incentive and to understand why some locations may be more successful than others at attracting investment, according to Treasury.
Opportunity Zones Criticism
The Opportunity Zone program has not come to fruition without its share of criticism, however. Although lawmakers have called for reporting requirements related to QOFs since the TCJA's enactment, the program has recently come under increased scrutiny and criticism. Senate Finance Committee (SFC) ranking member Ron Wyden, D-Ore., has said that the lack of reporting requirements are "inexcusable."
"Requiring taxpayers to prove they're actually following the rules of the Opportunity Zone program is a positive first step, but it's one that should have been taken two years ago…," Wyden said in an October 31 statement. "The Opportunity Zone program has been operating without any effort to ensure compliance and that's inexcusable."
A California-based medical marijuana dispensary corporation's motion for summary judgment challenging the constitutionality of Code Sec. 280E was denied. The Tax Court also addressed whether Code Sec. 280E applies to marijuana businesses legally operating under state (California) law, and whether the prohibition on deductions is limited to ordinary and necessary business expenses.
A California-based medical marijuana dispensary corporation's motion for summary judgment challenging the constitutionality of Code Sec. 280E was denied. The Tax Court also addressed whether Code Sec. 280E applies to marijuana businesses legally operating under state (California) law, and whether the prohibition on deductions is limited to ordinary and necessary business expenses.
Section 280E
Congress enacted Code Sec. 280E after the court had allowed certain deductions for expenses incurred in connection with an illegal drug trade. Generally, Code Sec. 280E disallows any deductions attributable to a taxpayer's illegal drug related trade or business. Taxpayers may reduce their income by the cost of goods sold (COGS), and Code Sec. 280E does not generally disallow deductions attributable to a taxpayer's non-drug-related business.
The Eighth Amendment of the Constitution prohibits excessive fines or penalties. The dispensary in this case claimed that Code Sec. 280E is a punitive provision that violates the Eighth Amendment. However, because Congress generally has the power to levy taxes under the Sixteenth Amendment, the Tax Court found that the law's denial of certain deductions cannot be construed as a penalty.
Legality Under State Law
The dispensary also argued that its actions could not be considered "trafficking" for purposes of Code Sec. 280E because its activities were not illegal under California law. The court noted that because marijuana is still considered a Schedule I controlled substance and is banned under federal law, the application of Code Sec. 280E does not depend on the legality of marijuana sales under California law.
Additional Deductions
Finally, the dispensary argued that Code Sec. 280E only applies to deductions under Code Sec. 162, and that other deductions such as those under Code Secs. 164 and 167 should be permitted. However, the text of Code Sec. 280E broadly states that "no deduction or credit shall be allowed." It does not limit the deductions to those claimed under Code Sec. 162.
Dissenting Opinions
The Tax Court decision included several concurring and dissenting opinions, which primarily addressed the issue as to whether Code Sec. 280E is in fact a penalty provision that would violate the Eighth Amendment.
The dissenting opinions found that Code Sec. 280E is punitive in nature. One dissenter noted that rather than specify a narrow range of disallowed expenses, Code Sec. 280E attacks the entire marijuana industry with a broad denial of otherwise allowable deductions. The opinion stated that Congress passed Code Sec. 280E order to deter the sale of controlled substances and to penalize the drug trade. That intent was found to be "clearly in the nature of a penalty." Both dissents concluded with two additional questions, which the dissenters felt need to be addressed:
- Is the punitive nature of Code Sec. 280E excessive to the point where it violates the Eighth Amendment?, and
- Does the Eighth Amendment apply to corporation taxpayers?
The IRS has proposed regulations that define an eligible terminated S corporation (ETSC), and provide rules relating to distributions of money by an ETSC after the post-termination transition period (PTTP). The proposed regulations also extend the treatment of distributions of money during the PTTP to all shareholders of the corporation, and update and clarify the allocation of current earnings and profits to distributions of money and other property.
The IRS has proposed regulations that define an eligible terminated S corporation (ETSC), and provide rules relating to distributions of money by an ETSC after the post-termination transition period (PTTP). The proposed regulations also extend the treatment of distributions of money during the PTTP to all shareholders of the corporation, and update and clarify the allocation of current earnings and profits to distributions of money and other property.
Code Sec. 1371(f), as added by the Tax Cuts and Jobs Act ( P.L. 115-97) extends the period during which C corporation shareholders can benefit from the corporation's accumulated adjustment account (AAA) generated during its former status as an S corporation. Specifically, the provision allows the C corporation to source qualified distributions of money to which Code Sec. 301 would otherwise apply to in whole or part to AAA. The provision only applies if the corporation is an ETSC as defined in Code Sec. 481(d).
Under the proposed regulations, the revocation of S corporation status may be made during the two-year period beginning on December 22, 2017, even if the effective date for the revocation occurs after the conclusion of the two-year period.
Shareholder Identity Requirement
A former S corporation is not an ETSC unless the owners of its stock are the same owners (and in identical proportions) on December 22, 2017, and on the date of the S corporation revocation. The proposed regulations identify various categories of stock transfers that are not considered an ownership change for purposes of this rule.
ETSC Proration
A distributing ETSC's AAA is allocated to qualified distributions and the distributions are chargeable to the ETSC's accumulated earnings and profits (AE&P) based on the ETSC proration. The ETSC proration is implemented in a manner that facilitates the prompt distribution of AAA and full transition to C corporation status. Specifically, the proposed regulations:
specify the time at which amounts of AAA and AE&P are determined for purposes of the ETSC proration;
provide AAA and AE&P ratios used to the implement the proration; and
describe in detail the method of characterizing qualified distributions.
The proposed regulations adopt a "snapshot" approach under which amounts of AAA and AE&P are determined on a specified date. As a result, the same ETSC proration is applied to all qualified distributions. Under the proposed regulations, the determination date is the date when the S corporation revocation election is effective. A "dynamic" approach that recalculated the amounts before each qualified distribution was rejected as administratively cumbersome.
The proposed regulations provide two ratios for determining the part of a qualified distribution that is sourced from AAA and from AE&P. The AAA ratio is the ratio of historical AAA to the sum of historical AAA and historical AE&P. The AE&P ratio is the ratio of historical AE&P and the sum of historical AAA and historical AE&P. The qualified distribution is multiplied by these ratios to determine the amount sourced from AAA and AE&P.
The proposed regulations provide a priority rule under which ETSC proration first applies to qualified distributions during the tax year. The rules of Code Sec. 301 and allocation rules of Code Sec. 316 then apply to any nonqualified distributions that are not fully accounted for by the ETSC proration because the corporation's AAA or AE&P are exhausted.
Effective Date
The proposed regulations will be effective in tax years beginning after the date they are published as final regulations. A taxpayer may apply the regulations in their entirely to tax years that begin on or before the date of publication as final regulations.


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We must first ensure we are able to live with dignity: Vale Stella Young
A few years ago Stella Young interviewed me for a TV program on disability, following the release of my book Defiant Birth: Women Who Resist Medical Eugenics. I found her intelligent, articulate, feisty, charming, with a wild sense of humour. We had to keep stopping the interview because she made me laugh so much.
Here's a powerful and poignant piece she wrote only a month before her passing.
Dying with dignity: let's focus more on the latter
By Stella Young
And so when people ask me why I am opposed to legalising assisted suicide, this is what I tell them: The medical industrial complex has an inaccurate, but incredibly powerful, view on my life. Disability is often framed, in medical terms, as the ultimate disaster and certainly as a deficit.
Indeed, some of my most profound experiences of ableism have taken place in the context of a hostile hospital environment…
Death is not treatment, even if it's medically facilitated.
Doctors are not fortune tellers and neither am I. Having lived with disability since birth does not afford me immunity from illness. Of course, when the time comes, I would like a dignified death. But while I'm alive, I also want a medical profession that is just as willing to keep me alive as they are to assist me to die….
Conversations about dying with dignity are important. But we must first ensure we're all able to live with dignity. Read full article
And this, Stella's letter to her 80-year-old self
"… Mum and Dad, who never wanted me to be anything other than what I am. Who never expressed a scrap of disappointment that I wasn't quite what they were told to expect. Who, despite being told not to have any more children because of the risk they'd have my condition, went on to have my two beautiful sisters. I think that's the thing I love them for the most; that they didn't see disaster, when those around them could speak of little else." Read full article

subset: commoncrawl


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"ANZAC Square War Memorial and Parkland, dedicated to Australia's military heritage, features the Shrine of Remembrance with Eternal Flame. Also included are war memorials, honour rolls, unit plaques, mosaic and soils from WWII cemeteries. Touch-tell systems explain the significance of the ANZAC Square War Memorial. The centrally-located Square is a peaceful sanctuary for reflection within the busy Brisbane City precinct."
- 4位当地人推荐


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JGE 1996 - Volume 44
JanuaryAnalysis of Bubble Sizes in Vesicular Basalt
Jason Turflinger and Carl Drummond, Indiana University - Purdue University, Fort Wayne
Vertical variation in basalt vesicle size and abundance has traditionally been utilized as a relative-age indicator in deformed volcanic terrains. However, there is more to be learned from vesicles than simply which way is up. Recent study of vesicle size-frequency distributions has resulted in quantification of rates of volatile exsolution in pre-eruption magmas, flow motion and cooling processes, as well as the elevation of lava emplacement.
Through analysis of vesicle size-frequency distributions from a series of slabs cut from a single basalt hand-sample, students are introduced to simple rock preparation techniques and subsequent numerical analysis. Additionally, comparison of size-frequencies between sequential slabs allows for introduction of these techniques and the mathematics of bubble growth in fluids.
From our example analysis, it was determined that vertical variation in the size-frequency distribution of basalt vesicles over short distances implies multiple processes of bubble growth. In our sample, bubble enlargement occurred largely through coalescence during buoyant assent. Systematic vertical variation in negative exponential distributions of vesicle sizes indicates that initial coalescence of bubbles is followed by minor inflation and selective combination of only the largest bubbles as lava cools.
URL for this article: http://www.nagt.org/nagt/jge/abstracts/1996.html#v44p22
NovemberFunding Opportunities for Undergraduate Science Education at the National Science Foundation
David William Mogk, National Science Foundation
URL for this article: http://www.nagt.org/nagt/jge/abstracts/1996.html#v44p340
The Place of Formative Evaluations in Assessment and Ways to Reap Their Benefits
Edward B. Nuhfer, University of Colorado at Denver
URL for this article: http://www.nagt.org/nagt/jge/abstracts/1996.html#v44p385
Ground-Water-Simulation Apparatus for Introductory and Advanced Courses in Environmental Geology
Alexander Gates, Richard Langford, Richard Hodgson, and John Driscoll, III Rutgers University
URL for this article: http://www.nagt.org/nagt/jge/abstracts/1996.html#v44p459
Funding Opportunities for Science Education at NSF Instruments of Change
David William Mogk, National Science Foundation
Abstract Not Available
URL for this article:http://www.nagt.org/nagt/jge/abstracts/1996.html#v44p469
Partnerships in Geoscience Education through National Science Foundation Programs
David William Mogk, National Science Foundation
Abstract Not Available
URL for this article:http://www.nagt.org/nagt/jge/abstracts/1996.html#v44p603


text:
Dear new mum of a premature baby or baby with special needs,
I know this isn't what you expected – a baby born too early or with some medical complication/s following his/her birth, but this is now you & your family's reality.
You're feeling a myriad of feelings & emotions at the moment, not to mention the normal postpartum/postnatal mood swings. You're tired, overwhelmed, in shock, sad, relieved (if your pregnancy was medically challenging & you worried about your baby each day), feeling robbed & at the same time dealing with all the unexpected & unplanned for scenarios you're now living with. Of course you're relieved your baby is alive & makes it harder to rationalise your negative feelings & disappointment over your situation because so many others are not 'this lucky'. Welcome to the equation, guilt.
All these thoughts & feelings are shoved (read, suppressed) into an imaginary box of emotions. The 'box' is not tied up because new contents will added on a daily, & sometimes hourly, basis. You hold onto these thoughts & feelings tightly because sharing them would deem you self-centred & selfish & none of this is about you. It's all about your baby – you looking after him/her & taking care of your newborns' extra needs.
You're going through the motions of feeding, expressing, vising PICU, NICU or special care & not even stopping to think about how you're feeling about any this. You just keep busy & keep moving because you are a mother now & this is your job.
What you have time to digest any of what's going on, or as you're trying to sleep, thoughts race in & out of your mind. You might be thinking some or all of the following:
- You feel guilty that your body failed to carry your baby to term. You failed at the one thing your body was meant to do once becoming pregnant & the pregnancy being viable.
- You feel guilty that your body didn't create a 'perfect' & 'healthy' baby & that you've caused all the medical complications that may or may not occur following the birth.
- You feel immensely guilty for causing any developmental deficits or developmental delays to your baby.
- You feel angry & robbed that you are not having the postpartum/postnatal period you imagined during your pregnancy.
- You feel sad that you don't have the balloons, stuffed toys, cards & flowers like the other rooms because you've told visitors that they cannot come to visit your baby since he/she's in care.
- You feel robbed for not being allowed to hold you baby after the birth, because it needed to go to NICU, PICU or special care. And then guilty for not having all that skin-to-skin contact that all the books & websites say is essential for bonding with your baby.
- You feel invisible at times as others take over the basic care (not medical) of your baby right in front of you – the midwives that pick up & undress your baby, change it's nappy all while you're craving to just be its mother.
- You're envious of all your friends that have had 'normal' postpartum/postnatal periods & brought home healthy babies home after a few days in hospital, because you're not going to have this experience.
- There is an air of sadness about & around your newborn that everyone's ignoring or avoiding.
- You feel as though you don't matter – people have forgotten that you're also recovering from having a baby & don't think to ask how you're doing.
- You're sad because you missed your imagined 'newborn' photo shoot because by the time you get home from hospital your baby is no longer a newborn.
- You feel immensely sad seeing your friends' newborn & toddler photos in your newsfeed because you're unable to have/do this yet or at all.
- You get upset when you see other babies feed well & are content following a feed because every feed you do is emotional torture. That's if of course you are able to feed your baby because the midwives do most of the feeding when your baby's in their care.
- If you have a toddler, you're angry that he/she can't go visit their new baby sibling because of germs they may have picked up at daycare that might jeapordise the health of your baby (or worse other babies in care). You completely respect & understand this rule in your head, but your heart seems to be taking longer.
- You feel a pang of sadness seeing mothers walk their babies in prams because your imagined postpartum/postnatal period is nothing like you imagined or hoped for.
- You get annoyed that people have no understanding or (at least) compassion for just how much harder you have it (& possibly for the foreseeable future).
- You often feel like your baby's nurse at times & not his/her mother.
- You get angry when you hear women complain how uncomfortable the last weeks/months of a pregnancy is, because you would take their place in a heartbeat.
- You want to ask yourself, 'why me', but you don't feel you've got permission to do so.
- You get annoyed & defensive when questioned about your babies health or developmental delays because of the guilt you feel about it.
- You life is on hold & you don't know how long this will be for.
- When you hear, 'it doesn't matter if it's a boy or girl, as long as it's healthy' said to someone around you, your stomach turns in knots because people don't realise just how meaningful that sentiment is & how much you wished for the full term baby or good health.
- Images with mums & their newborns will forever upset you, as this was not the experience you had.
- People are quick to ask you about extending the family again, with little or no regard for anything you went through or are still going through on a daily basis with your baby.
- The mothers in your mothers group seem like distant strangers because the only thing you have in common is that you both own prams/strollers. Nothing about your experience is the same.
- You get agitated when other mothers discuss seemingly insignificant things around you, because your priorities are miles apart.
- You feel lonely.
Your nervousness can be debilitating, you're always on edge & absolutely everything overwhelms you. You don't feel as though you're allowed to feel anything other than being grateful & blessed with this little life. You're unable to sleep when you can – that is, after all the expressing, steralising, cleaning, administering & monitoring – & the sleep deprivation is all too much to cope with. You don't know how to just be a mum to your baby because of all his/her other needs & all the things you have to do & deal with. The adrenaline of your situation keeps you going & going until you finally crash. And when you do, you STILL don't think you have permission to do so.
To my dear (new) mum, please know & understand that you have a lot to deal with now (& possibly in the future*) & your feelings about your situation are understandable, permissible & valid.
When you're later diagnosed with postpartum/postnatal depression & /or anxiety, (because you were finally honest with yourself on how you were really feeling), you will feel immense relief because you'll be able to get the help you need in order look after yourself. You will be able to discuss the racing & irrational thoughts you're having & the trauma with someone that will listen& cares & they'll be able to provide you with strategies to turn the voices down, & in time, turn off for good. You might need the aid of medication, or as I call it Ventolin, because it too will help you breath. There is absolutely no shame in getting help or admitting you're not ok because what you've been through & what you're going through is hard & at times, frankly, just suck.
Your reasons or circumstance for suffering any postpartum/postnatal mood disorder doesn't matter, but what I'm about to tell you does. I will keep reminding you in each & every post I ever write about postpartum/postnatal mood disorders because it's true & you need to hear it.
I want you to know that you're not alone.
I want you to know that help is out there.
I want you to stop believing everything you think.
I want to tell you that you will get through this.
Be gentle with yourself, as you will be delicate for some time. You must give yourself this time. Allow yourself to grieve over the loss of your imagined post-birth experience & if you have this experience more than once, allow yourself to grieve the fact that you will never have the post-birth experience that others do & that you always wished for.
I hope that the passage of time treats you well & your recovery is triumphant. Be patient with this process – your recovery will be full of highs & lows, achievements & regressions. The ride will be bumpy my friend, but we'll be here for you cheering you on & supporting you on your good days & holding your hand & throwing you a lifeboat on the hard ones. No matter what the future holds, you're strong, you're fierce & an admirable woman & mother.
Sending you love & hope always & forever,
Yuz (Warrior mum & survivor)
* Research has shown that mothers with premature babies or babies with special needs often suffer from Post-Traumatic Stress Disorder (PTSD) which often goes undiagnosed until many years after the initial trauma or experience.
I'll be Climbing out of the Darkness (COTD) in Melbourne Australia on June 21. To join her team or to make a donation, click here: http://www.crowdrise.com/yuzrozenblum-COTD2014
Sunday May 11th, is the 6th annual Mother's Day Rally for Mums' Mental Health. This Rally will feature 24 letters from survivors of postpartum/postnatal depression, postpartum/postnatal anxiety, postpartum/postnatal OCD, post-adoption depression, depression after weaning &/or postpartum/postnatal psychosis. The purpose of these posts is to inform & encourage pregnant & new moms who may be struggling with their emotional health. The Rally is hosted by Postpartum Progress, the most widely-read blog in the world on postpartum depression & other mental illnesses related to pregnancy & childbirth. To read the other posts on this Mother's Day Rally, click here.


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UFC's Jon Jones: 'War gods' made Anderson Silva pay
UFC light heavyweight champion Jon Jones was openly critical of recently deposed middleweight champ Anderson Silva during a press conference Tuesday in support of his fight with Alexander Gustafsson at UFC 165.
"I think he's got to the point where he really believes in his gift, and he abused his gift," Jones said in Toronto, where he next will fight Sept. 21 at Air Canada Centre. "He disrespected the gift by disrespecting his opponent."
REFEREE:Couldn't tell if Silva was faking
The 25-year-old champ has a reason to be upset with Silva, who was knocked out by Chris Weidman in mid-showboat at this past Saturday's UFC 162 in Las Vegas. The No. 1 and No. 2 pound-for-pound greats were expected to meet in a blockbuster pay-per-view if successful in their upcoming fights. They stood to reap millions from revenue sharing with the UFC.
Immediately after Silva's KO, Jones tweeted two words: "This sucks."
On Tuesday the young champ expanded on his feelings about the lost opportunity, and while he said he still considers Silva one of the greats, he said the former champ's approach to Weidman got him in trouble.
UFC 162 FIXED?:Dana White blasts skeptics
"Martial arts is traditionally a sport that is based on honor and integrity and treating people with respect, and he somehow lost sight of that and he paid the ultimate price for it," Jones said. "So I'm not going for the Anderson Silva hype train. I know exactly where he's at; you can tell exactly where he's at by the way he's fighting.
"I think he just got disrespectful, and the war gods just made him pay for it. He's still that great Anderson Silva in my book."
Now, Jones must beat back another young contender looking to shock the world by taking his belt. Despite winning his past six inside the octagon, Gustafsson is a 4-to-1 underdog in the fight. But the champ said Weidman's performance is a reminder that nothing is safe when the stakes are high.
"It actually motivates me a lot, too, to watch somebody who I look up to lose," Jones said. "It's just a reality check. I try to keep my ego in check when it comes to the fight game, and watching Anderson lose like that – first of all, it's something I would never do, put my hands down and fight my opponent that way. But watching Chris Weidman's dream come true, I have to make sure to be a dream crusher."
A grisly toe injury Jones suffered while defending his title against Chael Sonnen this past April is on the mend, and he's now training boxing in shoes that protect his healing foot. He said the focus would come in handy for Gustafsson, who's a slick boxer.
Although Silva has dropped from the No. 1 spot on several pound-for-pound lists, Jones said he won't believe he's taken the former champ's spot until he beats Gustafsson in September.
"At this point, it doesn't really feel real," he said. "My goal is definitely to become No. 1, and because Anderson lost doesn't really make me feel like I accomplished anything. So I'm going to continue to work extremely hard to become the No. 1 light heavyweight in the sport, and eventually, I'll creep up on some of the things Anderson Silva has done in history.
"So, it doesn't really do too much for me. It doesn't feel real, it doesn't feel earned, and winning this fight will make me feel a little bit better about it."
Steven Marrocco writes for MMAJunkie.com, a property of USA TODAY Sports Media Group.


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WESTCHESTER COUNTY, N.Y. - A funeral mass has been set for 43-year-old Lauren Denninger , a special education teacher and facilitator at Isaac E.Young Middle School in New Rochelle, who died on Friday, Aug. 18.
The mass has been scheduled for 10 a.m. on Tuesday at Saints John and Paul Roman Catholic Church on Weaver Street in Larchmont, with an interment to follow at St. Joseph's Cemetery in Toms River, New Jersey.
Denninger served the district for 19 years after being hired in 1998.
"Lauren was a dedicated special educator who touched hundreds of children's lives," Yvette Goorevitch, the City School District of New Rochelle Director of Special Education.
Goorevitch hired Denninger.
"Early on in her career, she sought training in the intensive Wilson Reading System teaching program, because she understood the importance of helping adolescents learn to read in order to forever change their lives, Lauren was a trusted colleague and friend. She was among the 'coalition of the committed.'"
Isaac E. Young Principal Anthony Bongo added; "Lauren's capacity to love students and staff created a climate of compassion and understanding that made it easier to accomplish very difficult tasks. Her humor, mixed with her fierce commitment to our school, made students and staff better."
Memorial donations in lieu of flowers can be made to New York Medical College of Cancer Research. In addition, donations can be made to a college fund for Denninger's daughter, Margaret.
To view Daily Voice's previously published obituary, click here.
Click here to sign up for Daily Voice's free daily emails and news alerts.


text:
Coachella 2014: Pharrell Williams Brings Out Jay Z, T.I. and Usher
Pharrell Williams has a lot of friends in the music business. During last week's Coachella performance, the veteran producer brought out Nelly, Gwen Stefani and Snoop Dogg. For his second weekend show, Skateboard P brought out hip-hop heavyweights Jay Z and T.I. to rock with him onstage.
According to Billboard, Hov joined Williams for a medley of hits including 'Frontin',' 'Excuse Me Miss,' 'La La La (Excuse Me Miss Again)' and 'I Just Wanna Love U (Give It 2 Me).'
Tip appeared with Williams to perform his rap on their ubiquitous hit 'Blurred Lines.' The Atlanta rapper was then followed by Pusha T who performed the Clipse banger 'Grindin'.' Finally, R&B crooner Usher had the ladies screaming during his rendition of the Williams-penned 'U Don't Have to Call.'
Unlike last week, Williams didn't go too far back into his catalog, but he did perform his latest chart-topping hits including 'Get Lucky,' and of course, 'Happy.'
Overall, Pharrell Williams presented a great show that left Coachella fans very happy that they came.


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PALM BEACH GARDENS, Fla. — The PGA of America, World Golf Foundation and Executive Women's Golf Association (EWGA) have partnered to present Welcome to Golf-Get Golf Ready Clinics for women at 10 sites across the country. Events will be hosted at facilities in the Atlanta, Boston, Chicago, Dallas, New York City, Los Angeles, Phoenix, Seattle and Washington, D.C., markets.
Get Golf Ready is designed to bring people into the game in a fast, fun, affordable manner. It targets the millions of adults in the United States who have never played golf or who have minimal experience in the game. The typical Get Golf Ready program consists of five lessons that concentrate on basic skills, instruction and information on the Rules of golf, etiquette and values. Most facilities offer the program for an affordable $99, although price varies by facility.
These events will provide women with a fun experience in a one-day format, including clinics on putting, chipping and pitching, iron shots, driver and fairway woods, and on-course management, followed by a cocktail reception.
"It is critical that women be invited into the game the right way to make the experience welcoming," says Pam Swensen, CEO of the EWGA. "Women will experience a networking event that just happens to center around golf," Swensen continued. "It is a great place to have fun with friends and colleagues and also a great opportunity to meet new friends."
The cost for the event is $25.00 (New York is complimentary) and is limited to the first 100 people who register. The one-day clinic includes golf instruction, equipment rentals if needed, giveaways and the cocktail reception.
"We are proud to team with the World Golf Foundation and EWGA and encourage women to bring their friends and get a taste of what the Get Golf Ready program has to offer," said Allen Wronowski, President, The PGA of America. "Women are taking advantage of these programs, because they understand the many benefits that the game of golf has to offer – both personally and professionally. We hope these clinics continue to bring more women to golf."
In 2011, more than 32,000 people participated in Get Golf Ready programs nationwide, an average of 41 students per facility, and 60 percent were female. There are additional Play Golf America programs, which offer unique opportunities for women to connect with PGA/LPGA Professionals allowing women to learn and develop their game as a way to join their friends and family on the course. The game of golf provides hours of quality time outdoors, as well as offers numerous health benefits, making golf a great game for spouses and families to enjoy together for a long time.
The social benefits don't stop with friends and family. Women are also finding that golf is great for building business relationships. According to a survey conducted by the Golf Digest Companies Research Center, more than 22 percent of executive women golfers have closed business deals on the golf course, and overall, women report that golf has helped them network in their business and be more assertive in the workplace.
Below is a list of EWGA Get Golf Ready events that will be held in May as part of Welcome to Golf Month.
2012 EWGA Get Golf Ready Events (listed by date)
LOS ANGELES- Westchester Golf Course
May 15, 4-6 p.m.
6900 W. Manchester Ave.
Los Angeles, CA 90045
PHOENIX- McDowell Mountain
May 17, 5:30-8:15 p.m.
10690 East Sheena Dr.
Scottsdale, AZ 85255
DALLAS – Las Colinas Country Club
May 22 – 5-8 p.m.
4400 North O'Conner Rd.
Irving, TX
BOSTON – Norwood Country Club
May 22 – 5:30 – 8 p.m.
400 Providence Hwy.
Norwood, MA
WASHINGTON, D.C. – Northwest Golf Course
May 23 – 6:30-8 p.m.
15711 Layhill Rd.
Silver Spring, MD
PHOENIX – Palm Valley Golf Club
May 25-5:30-8:15 p.m.
2211 N. Litchfield Rd.
Goodyear, AZ 85395
ATLANTA – City Club of Marietta
May 30 – 5-8 p.m.
510 Powder Springs St.
Marietta, GA
SEATTLE – The Golf of Newcastle
May 30 – 5-8 p.m.
15500 Six Penny Lane
Newcastle, WA
NEW YORK – Philip J. Rotella Memorial Golf Course
May 31 – 5-7:30 p.m.
200 Thiells Mt. Ivy Rd.
Thiells, NY
CHICAGO – Bolingbrook Golf Club
Date and time TBD
2001 Rodeo Dr.
Bolingbrook, IL


text:
Google Takes Traffic Maps Beyond Freeways
Back when I lived in Washington, D.C., I made every effort to avoid the Beltway and its constant ring of road-rage inspiring bumper-to-bumper traffic. Sometimes, however, it was unavoidable and I would have appreciated a quick way to assess whether it would take me 10 minutes or two hours to get to my exit.
Enter Google's "traffic" button. The search engine giant has added a traffic tool to the Web and mobile versions of its site that let drivers see how heavy traffic is in their area via a color-coded chart.
As you zoom in closer to a city, Google will highlight the main roads and code them red for heavy traffic, orange for medium traffic, and green for no traffic. A red/black color means stop-and-go traffic.
How will Google get this information? From you.
If you use Google Maps for mobile with GPS enabled, you can enable Maps with My Location, and send bits of information to Google about how fast you're moving.
"When we combine your speed with the speed of other phones on the road, across thousands of phones moving around a city at any given time, we can get a pretty good picture of live traffic conditions," Dave Barth, product manager for Google Maps, wrote in blog post.
Google pointed out that some phones like the T-Mobile myTouch 3G and the Palm Pre come pre-loaded with Google Maps and traffic crowd sourcing pre-installed, though the iPhone Maps application does not support crowd sourcing.
The company acknowledged that this feature might appear a tad Big Brother-ish, but insisted that privacy protections are in place to prevent Google from stalking you.
"We only use anonymous speed and location information to calculate traffic conditions, and only do so when you have chosen to enable location services on your phone," Barth said. "We use our scale to provide further privacy protection: When a lot of people are reporting data from the same area, we combine their data together to make it hard to tell one phone from another."
For those who are concerned, Google has provided details on how to opt out of My Location.Originally posted to AppScout.


text:
A South Florida man who told police his name was Ima Thief was met by a judge's laughter when he appeared in bond court Thursday on charges he tried to steal two televisions from a store.
Police in Sunrise say Thief tried to walk out of the store with more than a thousand dollars worth of merchandise.
"You're Ima Thief, sir," Broward Judge John Fry asked the man while laughing.
U.S. & World
"Yes, sir," Thief responded.
"And you're charged with grand theft," Judge Fry said while shaking his head. "I'm going to call you Mr. Ima, okay? Alright."
After exchanging good mornings, Judge Fry said, "I do sincerely wish you the best of luck. I just wasn't really anticipating seeing this name."
Police say the man tried to leave a store on the 3300 block of North University Drive in Sunrise with two television sets and three other items in his shopping cart. He was met by security at the door.
When he was told to go back in the store with the items, he refused, and when officers arrived and gave the same order, he tried to get past them and out of the area, police said.
The man refused to identify himself, other than to say his name was Ima Thief. He told police he was 34 years old.
In the arrest affidavit, Officer Andrew Hydes wrote, "the name and date of birth are fictitious and only provided in order for the subject to be processed at the Broward Sheriff's Office jail."
The man who identified himself as Thief faces charges of grand theft and resisting an officer. He's also being held on a no-bond probation violation warrant related to a burglary.


text:
EFI says it will have a sellout crowd for this week's EFI Connect 2014 Users Conference, with every one of its attendee slots filled during event pre-registration. The conference, which takes place between 21st and 24th January, will be the largest in Connect's history, with approximately 1,500 pre-registered attendees. The larger number of registrations - one-third more than Connect 2013 - reflects increased customer interest in high-level business and technical training offered at one of the graphic arts industry's most successful user group events.
The event, which takes place at the Wynn Las Vegas, is the industry's best venue for open dialogue and idea exchange. Now in its 15th year, Connect gives EFI customers from around the world a unique educational opportunity to make their businesses more efficient, profitable and competitive.
The conference offers more than 150 educational sessions, including technical expert training for MIS/ERP workflow, web-to-print, eCommerce, digital front end print management and inkjet production printing using EFI's award-winning product portfolio. This year's conference also features a business development track developed and led by senior consultants from industry analyst firm InfoTrends.
"We have worked harder than ever before to make this year's Connect a world-class conference and a must-attend event for print professionals looking to stay ahead in a competitive market," said Frank Mallozzi, senior vice president of worldwide sales and marketing at EFI. "The fact that we have reached maximum capacity for the event indicates that there is significant appetite in the market for a focused, comprehensive, educational event that gives attendees tangible information on improving their businesses."
In addition to the increased attendance, EFI also recorded growth in partner activity, with 100% of Connect's available exhibit space selling out in the weeks leading up to the event.
Participating partners and sponsors for Connect 2014 include 3M, Canon, Esko, honle UV America, Kodak, Konica Minolta, Lintec, MBM, NAPL, People's Capital Leasing, Ricoh, Xerox, xpedx and Zund.
In addition to partner exhibits, EFI Connect's sold-out exhibit floor includes some of EFI's most-advanced technologies, including EFI Wide-Format and VUTEk® printers, EFI Fiery® print workflow products and EFI Productivity Software MIS/ERP, web to print and eCommerce software.
New EFI products on display include the EFI Digital StoreFront® 7, which is making its debut at the conference. The exhibit floor also features a display of EFI SmartLinc software, a newly acquired product line offering comprehensive shipping management with integrated print MIS/ERP connectivity.
For more information about Connect 2014, visit www.efi.com/connect.


text:
by Tyler Peck, sports information graduate assistant
MILLEDGEVILLE, Ga.-
Sophomore Dani
Destiche (Snellville, Ga.) of the Georgia
College & State University women's cross country team was named
Georgia College Athlete of the Week. The announcement was made
today (Sept. 4) by the sports information office. The award honors
the top performance by a Bobcat during the week ending Aug. 31.
This is second time Destiche has received this honor as she won the
last year.
Destiche led the Bobcats at the New Hampshire Meet, competing against University of New Hampshire, Providence College, and Boston College. She covered the 5K course in 20:09, tying for the seventh-best time in school history and taking 34th overall.
The Bobcats are back in action Sept. 6 hosting the Pre-Conference Meet on the school's West Campus course.
Visit www.GCSU.edu/Athletics to nominate your favorite former Bobcats and Colonials to the GCSU Athletics Hall of Fame. The GCSU Department of Athletics sponsors 10 varsity athletic programs at the NCAA Division II level. As a Division II program, GCSU prides itself on balancing the life of the student-athlete, evidenced by the Bobcats' multiple appearances in post-season competition as well as documented academic success and community-service involvement.


text:
FUNKE, Cornelia
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Delivering live video to the most popular connected devices on the market is not that complicated-when you select the class-leading solution. The award-winning Cisco Media Processor Family of streaming appliances for live audio and video delivery eliminates the need for additional hardware to reach the Apple® iPhone® and iPad® with video.
How Does It Work?
HTTP and ABR
• HTTP is simple and is supported by nearly all platforms.
• The mechanism is easy to implement and maintain.
• HTTP POST is a "push" from the encoder, and it works from behind firewalls and Network Address Translation (NAT).
• There is very little protocol overhead, in terms of bytes or cycles.
• In many cases a persistent connection is maintained.
Setting It Up
• Cisco AS5100 Series Media Processor for standard-definition (SD) content, Cisco AS7100 or AS8100 Series Media Processor for high-definition (HD) content, or Cisco AS6000 for IPTV .
• Web server or CDN to serve the HTTP content.
• HTTP (POST/DELETE): Of all transfer mechanisms, HTTP is the preferred protocol for live ingest.
• FTP: FTP has more overhead, is more complex, and is more likely to cause problems with firewalls.
• RSYNC: RSYNC has more overhead, particularly as the number of files increases.
• Secure copy (SCP) and SSH File Transfer Protocol (SFTP): SCP and SFTP are much more complex to implement, and they also have more overhead than HTTP-but they may be desirable if your content requires higher levels of security during transit. Remember as well that our built-in segmenter can encrypt the segments using Advanced Encryption Standard (AES)-128 encryption.
Performance-Grade Reliability and Features
State-of-the-Art-and Beyond
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text: Mentoring Programme In order to establish a successful mentoring relationship between the mentor and mentee, several fundamental principles and codes of conduct must be observed by all participants. To fulfil our university's task of providing an integrated education, we deliberately set goals that go well beyond the pure transfer of knowledge. To this end, courses that reach above and beyond the core programmes are introduced in phases. The mentoring programme, which is available to all students at the Bachelor's, Master's and Ph.D. levels, is an important part of this concept. We also seek to more strongly anchor our university both on a local and national level by establishing networks among our students and notable figures in the fields of politics, economics, media, art, culture and science. This integration of experience into our degree courses not only promotes the development of our students – it also enriches university life as a whole. The Mentoring Programme is a cooperation between the University of St.Gallen (HSG) and HSG Alumni.


text: Monday -Saturday 10-3 Born and raised in Perrysburg. Packed up my life in 2007 and moved all the way to Toledo to a house in the OWE. Love this city full of incredible people. Hate it's road construction. Been in radio since college. Celebrating 13 years at WIOT. Went from overnights to APD and Mid Day person, never forgetting those who came before me. I have a few tattoos and a few too many cats. You'll find me either hanging out on Adams Street or in front of my record player. I grew up wearing headphones. I've always been into music. Never been quite right. I like to paint smoking birds. I also enjoy long walks on the beach wearing bunny ears.


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If this is against the rules here, please remove this topic.
I'm trying to join a new forum specifically for java games, but to activate your account you need to answer a small trivia quiz. Being the java noob I am, I'm unable to complete the trivia to activate my account. I can't find a way to email/message an admin on the site, so my idea was to ask the java masters here for the answers, if this is in the wrong topic/not allowed, please delete it as I don't want to break the rules here.
What is the returned value?int o = 2; int j = "JZG".hashCode() % 3000; int w = "DUY".hashCode() % 3000; for (int i = 0; i <= w; i++) o = (o ^ i) % j; return o;
What is the greatest common divisor of the previous two results?


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Wrestling gears up for Olympic battle
WASHINGTON -- Wrestling takes disparate forms around the globe and across cultures. But to prevail in any discipline, wrestlers need strength, the ability to gain and exploit leverage and, ultimately, a superior will to win. Those are the qualities that supporters of Olympic wrestling are tapping in waging a campaign -- part political, part public relations -- to preserve the sport's place in the Summer Games.
At the moment, wrestling is on the outside looking in, voted out of the Olympics as of the 2020 Games in a decision in February that left hard-core supporters and many casual sports fans baffled. The International Olympic Committee ousted an ancient sport that has been part of every modern Olympics since the inaugural 1896 Athens Games except one, and kept sports such as BMX cycling, synchronized swimming and beach volleyball.
Wrestling's only recourse is to defeat seven other sports vying for one slot in the 2020 Olympics. Its competition: baseball/softball, climbing, karate, roller sports, squash, wakeboard and wushu. With the IOC's executive board scheduled to hear the sales pitch of all eight and vote on its recommendation May 29-31 in St. Petersburg, Russia, the wrestling community is seeking to rally supporters and win converts.
Said Bill Scherr, a 1988 Olympic bronze medalist and chairman of the Committee for the Preservation of Olympic Wrestling (CPOW): "Our message to the IOC is, 'We respect you. We respect your process. We believe it's not the correct decision. And we will change, and change leadership, to make sure it's an attractive sport and remains part of the Olympic movement."
Scherr said he wasn't surprised by the decision, having been warned by IOC insiders that wrestling was at risk because FILA, its international governing body, didn't respond in earnest to a mandate that all Olympic sports raise more private money, modernize with an eye toward boosting TV coverage, leverage social media and develop gender equity.
Following the Feb. 12 vote, wrestling ousted FILA president Raphael Martinetti and hired consultants to help respond to the challenge IOC President Jacques Rogge issued as he set about reining in the bloated Summer Games and wooing younger TV viewers.
Among the changes Olympic wrestling is weighing: Simplifying its confusing tiebreak procedure, tweaking its rules to encourage more action and having Greco-Roman wrestlers compete shirtless.
Meantime, the fight has galvanized wrestling supporters at the grassroots level, too.
On Thursday at the Ronald Reagan Building in Washington, CPOW (which pronounces its acronym "Ka-POW!") will host a discussion of wrestling's role in tackling social, economic and political challenges around the world. Representatives from the U.S. Agency for International Development will take part, as will Scherr; Rulon Gardner, a 2000 Olympic gold medalist; and University of Maryland wrestling coach Kerry McCoy, a two-time Olympian.
Next week, New York's Grand Central Station will host "the Rumble on the Rails" -- a wrestling meet involving Olympians from the United States, Russia and Iran. Wrestling supporters have also launched a website, KeepOlympicWrestling.com.
"I'm optimistic we're getting a proper hearing and that we can do the right things," Scherr said. "But it's a tough situation because we're competing against seven other great sports. It's an uphill climb. If we achieve it, it will be against the odds."
Last Thursday at Hayfield High School in Alexandria, Va., Rep. Jim Moran, D-Va., dropped in on the Gunston Wrestling Club's practice to talk with wrestlers, coaches and parents about the sport's ouster from the Olympics. The club was formed in 1992 by Hayfield Coach Roy Hill to give young wrestlers a forum to train outside the traditional high school season and includes students from more than a half-dozen northern Virginia schools.
"The participation is very extensive," Moran said in a telephone interview. "We've got girls getting into wrestling now. These kids don't get credit for it, but they come from all over northern Virginia and are working hard. These athletes are in great shape. The coaches are unpaid. There is no incentive in terms of professional career or individual compensation, which I find to be more in the spirit of the Olympics."
Said Hill, a Hayfield graduate who wrestled at Virginia Military Institute: "Wrestling in the United States at the college level is on a tenuous basis, as it is. With the Olympic dream basically being washed away in one fell swoop, the fear is, 'What repercussions would this have on our college wrestling?' "


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11 Responses so far.
Man Karl REALLY HATES J.O. The Brandon Bass line made me laugh.
I wish I could show up at work once a month and suck and earn a grand. I've had enough.
tb727 says:
Earn a grand Karl lol? The guy's making like $5,765,000 this season alone. Try like $900,000 for work once a month lol...
Well in fairness to J.O. he doesn't seem more fragile than Marquis did last year and for his career he's missed less games. Marquis turned it around. Maybe JO can too.
at least Marquis has skill J.O is the worst basketball player I've ever seen.
Come on guys! JO doesnt suck! lol
Maybe Jermaine will do a 'Sheed-type Magic Act' and he will turn his game way up in the post season! (i hope)
At least he is healthy now. He can get his rhythm going again and he will be a reliable backup center (isnt that why Doc and Danny got him anyway?)
He won't Rondo, sadly he won't. But I hope you are right.
Still like the Weeks in review, but the music is sorta lousy this year. Just my opinion. Thanks for posting.
What would you rather hear? I aim to please.
tb727 says:
Bass may need surgery
Nice pic of Brandon Bass. lol. Otis Smith is a dingbat. What's he doing over there?


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The special edition box set for NetDevil's Jumpgate: Evolution certainly doesn't suffer from a lack of space and space by-products.
Discovered by a curious reader via a product listing at UK retailer Game's website, the Special Edition of Jumpgate: Evolution is packed with exactly the sort of things you'd expect to find in the special edition of a massively multiplayer online game. Galactic map? Check. Art book? Check. Official soundtrack? Check. It's one of the most by-the-book MMO special editions we've seen, right down to the 5 buddy postcards and the 2 in-game items, the experience enhancing Stella Ensign and Stella Citation.
No word yet on whether or not this £39.99 special edition will be coming to the states. I'm sure NetDevil will let us know if and when they're good and ready.
Jumpgate Special Edition [Game - Thanks CrowGoblin!]


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Bookends have probably been used since books became inexpensive. Early libraries kept books in cupboards, not on open shelves. By the 1870s bookends appeared, especially homemade fret-carved wooden examples. As books became more available during the 16th century, bookends were used so that books could be stored vertically on shelves. Most bookends listed here date from the twentieth century. Bookends are also listed in other categories by manufacturer or material. All bookends listed here are pairs.
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The most popular of all the soaps. This soap will help with any skin ailments--eczema, acne, poison ivy, itchy rash, you name it--it will get rid of it!
"P.S Your soaps have been doing wonderful things for my sons eczema! We love it!"
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Brass observation hole from St. Audry's Hospital, Suffolk, England, 1851-1900
Is somebody watching you? Mounted on a door at the Suffolk County Asylum a century ago, this brass peephole allowed doctors and warders to check on a patient locked in solitary confinement. Perhaps few objects communicate the stigma and the loneliness of living with mental illness as well as this one. An eye peering occasionally through the peephole may have been the only human contact the inmate received for days. It was carefully engineered to protect both patients and staff. It had no window glass, since broken glass could become a weapon for those intent on committing suicide or wounding their keepers. For the same reason, the room itself would probably have had no windows, or at least no glazed ones. Welded pegs also prevented the peephole's cover from being broken off or twisted open from inside the cell. The Suffolk County Asylum for Pauper Lunatics (later renamed St. Audry's Hospital) was founded in 1829. Around the same time, a small number of English asylums for mentally ill patients, inspired by the ideals of moral therapy, were renouncing the use of physical restraint. However, large government-funded institutions like Suffolk, with patients whose families could not afford to pay for exceptional care, continued to rely on straitjackets and solitary confinement to subdue patients whom doctors judged likely to harm themselves or others. Frequently, suicidal patients would be put in the cell naked, to prevent them from tying clothing around their necks or swallowing strips of fabric. While potentially life-saving, it stripped patients of their dignity. New laws in the 1800s required asylums to carefully record every time they confined or secluded a patient, and to state why. This curbed some of the abuses associated with earlier asylums such as Bedlam, where some patients could be kept in chains or solitary confinement for years. To a scared, unclothed, suicidal patient behind this peephole, however, such slow legislative changes must have felt worlds away.
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Glossary: psychiatric hospital
Psychiatric hospital specialising in the treatment of serious mental illness, usually for relatively long-term patients.
Glossary: asylum
A historic term for a psychiatric hospital. The term in this context was common in the 1700s and 1800s, but is no longer in use.
Glossary: observation hole
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"The Hills" may be alive for a few episodes longer than expected.
Kristin Cavallari told E!'s Marc Malkin that the MTV show may double its final season order.
"There's a possibility of them ordering 12 more episodes," the star said. "I would like to do it."
She added that making the show, which returns for its season premiere on Tuesday night, has just gotten interesting.
"I'm in such a rhythm with things and I'm having a great time," she told Malkin. "We're just now starting to get into some really good juicy stuff with a few new people. So I think we could do another 12 episodes and make it pretty good."
Amongst that juicy stuff – a potential rekindling with ex Brody Jenner – and even the possible return of Lauren Conrad.
"I can't deny the fact that he is one of the most good looking men in the entire world," Kristin said of Brody. "We have a lot of fun together. I don't know if we could ever really get back together and be serious, but we are sort of trying to see if we could."
As for Lauren, Kristin said she "would love" the former series star – now a best-selling author — to return.
"There are many different ways of bringing her back," she noted.
Ratings for the show dropped steeply after Lauren's departure in 2009.
In a separate interview with Zap2it, Kristin added that one cast member who wouldn't be returning was Spencer Pratt.
"Spencer got kicked off the show like a month and a half ago," she said. "He's done; he's completely done."
A rep for Spencer did not immediately respond to a request for comment from Access Hollywood. In recent weeks, he has lashed out at a number of celebs – including "Hills" star Audrina Patridge – on Twitter.
Kristin told Zap2it that Spencer's wife, Heidi, has been off the show as well.
"Heidi is in a legal battle with MTV right now, and she hasn't filmed in a month and a half," she said.
Earlier this month, reports emerged that Heidi was alleging that she was sexually harassed by "Hills" executive producer Adam DiVello, a report that MTV reps and Lauren Conrad denied.
Related Content from AccessHollywood.com:
VIEW THE PHOTOS: Stars Of 'The Hills'… Past & Present
VIEW THE PHOTOS: Lauren Conrad: From 'Hills' Queen To 'L.A.' Author!
PLAY IT NOW: Preview: 'The Hills' Season 6 - The Final Season
PLAY IT NOW: Kristin Cavallari On 'The Hills'' Final Season: 'It's Not Over Yet!'
MORE ACCESS ON THESE TOPICS: Kristin Cavallari - The Hills - Spencer Pratt - Lauren Conrad - Audrina Patridge


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text: › Academics » Earth and Environmental Sciences Home Program Overview Earth and Environmental Science, B.A. Earth and Environmental Science, B.S. Sustainability Science, B.S. Global Experience Prospective Students Career Opportunities Research Opportunities Meet Our Faculty Current Students Awards Graduate School Resources Facilities Contact Us Mineralogist / Petrologist - Tenure Track Position Plan a Visit ›Apply Now ›Give to Furman › EES blog Keep up with the latest news and research happening in our department. intro photo 1 intro paragraph boldHow do we achieve an environmentally safe and socially just space for humanity in a world of increasingly limited natural resources? intro paragraphThat is the quintessential challenge of the 21st century, and lies at the heart of Furman's Department of Earth and Environmental Sciences. Our department takes a holistic, systems-based approach to seek solutions to this challenge and examines the full range of geological, environmental, and sustainability issues. We offer degrees in Earth and Environmental Sciences, as well as the nation's only degree in Sustainability Science at a liberal arts institution. Our courses and undergraduate research programs are engaging, interdisciplinary, and include field-based experiences. We'll provide you with the theoretical and practical knowledge to understand the basis of the Earth's environmental and geological processes and their inextricable link to today's social challenges. Tenure Track position in Mineralogist / Petrologist call out photo 1 Major Requirements call out description 1Everything you need to know about the degrees offered in our department. Major in earth and environmental sciences. call out photo 2 Prospective Students call out description 2Interested in majoring in Earth and Environmental Sciences? Discover the possibilities. call out photo 3 Research Opportunities call out description 3Take your education beyond the classroom. Conduct research. call out photo 4 Meet Our Faculty call out description 4Our professors will help you discover Earth and Environmental Sciences in the classroom and beyond. Meet our faculty. Main Content Column 1


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Ain't Nothin' Card
Learn how to make this card using these free instructions. Handmade Birthday cards are the perfect way to show you care and with these card making steps creating this design is easy.
SUPPLIES: Cardstock: (kraft) Bazzill Basics Paper; (white) Neenah Paper; (black) American Crafts Patterned paper: (Numerical from Classic Calico Vol. 2 collection) Studio Calico Accents: (clear rhinestones) Creative Charms; (wood stars) Studio Calico Font: (Lobster) fontsquirrel.com Tools: (typewriter) Brother; (circle punch) Marvy Uchida Finished size: 4 1/4" x 5 1/2"
1 Make card from cardstock.
2 Circle-punch patterned paper, trim, stitch edges, and adhere to card.
3 Die-cut "Happy birthday" from cardstock using electronic die cutting machine and font. Adhere.
4 Type sentiment on cardstock with typewriter, trim, and adhere to card with foam tape.
5 Adhere stars and rhinestones.
Designer Tip
When machine stitching in a circle, use a long stitch length and sew slowly. You can also hand walk the needle one stitch at a time.
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A few days ago, we were able to catch up with Andrea Karnes, Curator at the Modern, as she was taking a short break from putting the final touches on Andy Warhol: The Last Decade. She spent a few minutes giving us her thoughts on the upcoming exhibition.
Q: What has it been like curating the Andy Warhol exhibition?
A: Actually, I'm acting as facilitator for the exhibition. It was originally curated by Joseph Ketner, at the Milwaukee Art Museum. I get to lay out the show in our gallery space. It's very much a collaboration.
Q: Will Joseph ever get to see the finished product?
A: Yes, he's actually coming here and giving a lecture on February 9, a few days before the exhibition opens. So he'll get to see it.
Q: So how have you laid out the exhibition? Is there any specific way that you've grouped the paintings together?
A: It's a blend between being thematically grouped, and grouped in chronological sequence. For example, there are Warhol pieces from the Modern's permanent collection, like our ten Campbell's Soup Cans, that don't fit chronologically within the time frame of the exhibition, so they're on the periphery. But the Modern also owns a Gun painting, which falls within the exhibition time frame, so it's prominently featured within the main part of the exhibition.
Q: What would you say is the overall theme for this exhibition?
A: Well, there are several themes. I think two major themes are mortality and legacy: Warhol's getting older and he's starting to think about his mark on the art world. It's also a departure from Pop Art and a return to painting. It's post-Pop, but it's still classic Warhol: tongue-in-cheek, but also more mature. He revisits a lot of different influences, from Leonardo DaVinci's Last Supper to Abstract Expressionism, and examines them through the lens of Pop Art, which creates a lot of new meanings for those works.


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Since the March announcement of Oracle dropping support for the Itanium chip from Intel, there has been much news coverage surrounding this topic. Latest one being that HP is now suing Oracle over this issue. (http://www.pcworld.com/businesscenter/article/230396/hp_sues_oracle_over_dropped_itanium_support.html)
The purpose of this blog entry is to preview that both IBM and HP will be coming out with formal statements stating IBM and more specifically Informix support for Itanium on HP-UX. Current Informix customers running on HP-UX Itanium should not have any doubts about continuing on this platform. HP has declared its HP-UX PA-RISC support will end in 2013 and is actively motivating its customer base on PA-RISC to migrate to HP Itanium. Informix has supported this migration. Besides the fact that Informix has had a long history of supporting the HP-UX operating system, there are specific features that will make this migration easier.
- An Informix customer currently running on HP PA-RISC does not have to unload and reload the data when moving to HP-UX Itanium. It is simply a direct upgrade of the hardware. This will save you a tremendous amount of time/resource for migration.
- If an Informix customer uses High Availability Data Replication (HDR), it can choose to have the primary on HP-UX PA-RISC and the secondary running on HP-UX Itanium. The reverse is also true. This provides the customer more options as it transitions to HP-UX Itanium while maintaining the ability for High Availability.
If you are an Oracle customer running on HP-UX Itanium today and wondering what you should do, there is a very simple choice. It will be more cost effective to switch data base than to switch hardware. You can switch to an Informix data base providing Enterprise class OLTP and Data Warehousing capabilities with a fraction of the data base administration needed, and at a much lower total cost. Best of all, you do not have to worry about the outcome the lawsuits between the two companies to decide what to do with your system.


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VANCOUVER – A dangerous offender who posed as a gynecologist and convinced one victim to tattoo a name across her stomach has lost an appeal of several sexual-assault convictions in British Columbia's highest court.
Kolten Mastronardi was convicted in November 2006 on 12 counts of sexual assault, as well as other charges related to assault, threats, fraud and extortion. He was declared a dangerous offender in June 2012 and given an indeterminate sentence.
Story continues below
Mastronardi appealed four of the sexual-assault convictions, arguing the trial judge erred in law by convicting him of four counts for fraudulent gynecological examinations.
He also argued the trial judge shouldn't have dismissed an application to sever counts of fraud and extortion and one count of sexual assault from the other charges.
B.C. Court of Appeal Justice Daphne Smith, writing for the three-member panel, dismissed the appeal in a ruling posted online Thursday.
"Irrefutably his admitted non-consensual touching of their genitals necessarily violated their sexual integrity and constitutes a sexual assault," she said.
Smith also said it was irrelevant that the "examinations" were consistent with medical exams.
"A fraudulent skill cannot legitimize non-consensual sexual activity."
Smith said the trial judge did not err in principle or fail to consider relevant factors when dismissing Mastronardi's severance application. She said the trial judge fairly weighed the risk of prejudice and considered the interests of justice.
"In all of the circumstance, it cannot be said that the ruling resulted in an injustice," she wrote.
Smith's ruling laid bare the details of Mastronardi's "fantasy world."
She said with slight variations he presented himself as a member of a Sicilian family that was organized in a Mafia-like manner, a medical doctor and widower seeking a wife. Mastronardi also told his victims his family required submissive wives and the amalgamation of finances, said Smith.
Her ruling said he broke the nose of one victim, sexually assaulted her with the butt end of a knife, and convinced her to tattoo the sentence, "Property of Nicolo Mastronardi," across her stomach, and in large black letters.
Mastronardi also accused his victims of giving him sexually transmitted infections after examinations and false diagnoses.
Smith said Mastronardi extorted intercourse from a young naive foreign student by threatening to inform her parents and reporting "her 'crime' of 'sexual teasing' to the immigration authorities and have her deported."
Mastronardi also defrauded his victims of money and credit, and one lost as much as $55,000, said Smith.
Continue reading B.C. dangerous offender loses sex-assault appeal – BC


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Verizon Wireless EV-DO
The Verizon Wireless EV-DO network is the clear leader among 3G high-speed wireless options. Already available in 32 U.S. metro areas, it's your best bet for getting the mobile Internet from anywhere at any time. It's powerful and addictive, and it's our Editors' Choice.
Read our full review of Verizon Wireless EV-DO.


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Passengers. 5000 of them, and over 200 crew, but Jim (Chris Pratt) is the only one woken up 90 years early by an incident through an asteroid field, so he's got a long time to wait before he reaches the planet, Homestead II. Left home alone with nothing to do other than grow a beard […]
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Passengers – The DVDfever Cinema Review
Posted by Dom Robinson on January 1st, 2017