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Ladies and Gents,
Apologies, but you must wait for your bottomless mimosas under the tall trees and wavy blue expanses of sky in Malibu…or at least, you must wait to share them with this glorious 40-year-old. Don't cry. We'll post it up again for you soon.
Stay tuned for next weekend's adventure to Griffith Observatory…it appears that Saturn is on the menu instead of Jupiter, unless you wanna hide in the gift shop with me and sneak back into the big scope after it closes. I'll have my Mom en tow as a special guest for this celebration. Hey, that's TWO forty year olds for the price of one!
Details soon, Love Sandra

subset: commoncrawl


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Fuel Station
A fuel tracking system made for the rugged off-highway locations of quarries, mines and construction sites. Capture fuel transactions, equipment hours as well as engine working and idling logs.
Animation: Fuel Station
There are several types of Service Trackers that work with the Fuel Station:
ST-570 – RFID Cube – Asset identification, fuel and location
ST-990 – Cellular Service Tracker – Asset identification, fuel, hours, location as well as engine work, idling logs, cellular remote pinging, travel logs, and data logs
GoPOD Fuel Station – for remote fuel islands
Secure Option
By adding a ball valve or switch input, the fuel truck will not dispense unless the operator has a pass code and a valid piece of equipment.
Recent Posts
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The House and the Senate are each considering companion bills aimed at reducing the costs of financing renewable energy projects. In the Senate, Chris Coons (D-Del) introduced on June 7 the Master Limited Partnerships Parity Act. A bipartisan effort with Senator Jerry Moran (R-KS) and five others, this legislation would expand the definition of "qualified" sources in Section 7704(d)(1) of the Internal Revenue Code to include revenue from clean energy resources and infrastructure projects as qualifying income of a Master Limited Partnership or MLP. An MLP is a business structure that is taxed as a partnership, but whose ownership interests are traded on a market like corporate stock. Critics of the current law claim that the use of MLPs is difficult if not impossible for those seeking to invest in "inexhaustible" natural resources such as wind and solar, but at the same time recognizes investments in "exhaustible" resources like coal and natural gas. The proposed legislation would, according to its sponsors, level the playing field by specifically including energy technologies that qualify for special tax treatment under Sections 45 and 48 of the tax code, including wind, closed and open loop biomass, geothermal, solar, municipal solid waste, hydropower, marine and hydrokinetic, fuel cells, and combined heat and power. The bill, S. 3275, has been referred to the Senate Committee on Finance. A copy of Senator Coon's floor statement, which includes an illustrative description and history of MLPs can be accessed HERE.
On September 19, a bipartisan companion bill (identical to S. 3275) was introduced in the House by Representatives Ted Poe (R-Tx) and Mike Thompson (D-Ca) and referred to House Ways and Means. (View HERE)
Related information may be found as follows:
Our client, International District Energy Association's web site, www.districtenergy.org
"A Small Tax Change, Big Clean Energy Results"


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Here's to the crazy ones, the misfits, the rebels, the troublemakers, the
round pegs in the square holes... the ones who see things differently -- they're
not fond of rules... You can quote them, disagree with them, glorify or vilify
them, but the only thing you can't do is ignore them because they change
things... they push the human race forward, and while some may see them as the
crazy ones, we see genius, because the ones who are crazy enough to think that
they can change the world, are the ones who do.
Steve Jobs
US computer engineer & industrialist (1955 - 2011)
Sunday, January 16, 2011
Appeals and Democracy
Sir Winston Churchill, Hansard, November 11, 1947
British politician (1874 - 1965)
Wise words from a wise man who earned his knowledge through war and peace. Many times since those words were spoken have democracies been challenged, and in just as many cases she has prevailed. It is indeed a comment on our human nature - that we are less than perfect although we persist in the search of perfection. Those of us in Newfoundland and Labrador are getting our lesson in democracy, and it's rough edges, right now.
On the 24th of January, 2011, my son's 14th birthday, I will be presenting my appeal to the Rules Committee in St. John's of the Credentials Committee's decision to reject my candidacy for Leader of the PC Party. While there are many grounds submitted for the appeal, I believe the most important to be the unconstitutional interpretation of membership.
The Purpose, Aims, Objects section of the Constitution clearly states: ' i) to provide for democratic procedures and practices to effect the purpose, aims and objectives of the Party.' Two other parts of this section state: 'e) to elect a Leader of the Party; and (f) to provide for a nominating process for the selection of candidates for election as progressive Conservative members of the House of Assembly.' In other words,
democratic processes and practices must be used to elect the Leader, and nominate the candidates seeking to be MHAs. It does not speak of a dual status of membership. In fact, all memberships, and processes to get memberships, must be done in a democratic fashion. The basis for any definition of democracy is equality of the person. That despite your wealth and influence, or a lack of it, your vote shall have the same effect and influence as all others. There is no caste system in Canadian democracy.
It is an established fact that the District Association nomination meetings allow any interested resident of that area to vote for the candidate of their choice - with the proviso that they support the aims and principles of the Party. It is also an established fact that their membership is instantaneous upon their declaration of support, and that no other steps for membership are required.While this process may be considered open to manipulation, it is also the best guarantee of citizen influence on our democratic process. People simply are normally not that interested in politics, unfortunately, but should they feel their input is required, a process is in place to do that. It is a check on absolute power, and a wise process for any party that wants to stay in touch with the people. It also allows the Party to evolve politically as the people do.
If equality of the person is the foundation that democracy was built on, and if democratic procedures and practices must be followed in accordance with our Constitution, then the membership requirement for nominating leadership candidates must be the same as those requirements in place to nominate candidates for Members of the House of Assembly. To do otherwise would be a contravention of the aims and principles of the Party - an observance of which is necessary for membership.
As if to almost enforce this belief, the Candidate's Entitlement section of the Constitution states that a candidate is only entitled to a list of District Association members, ex-officio delegates, Executive members and the like once they have been accredited. The logical implication of this being that the signatures of endorsement by these people must not be required for nomination. If they were required it would constitute a violation of the principles and aims of the Party in that only people with extensive knowledge of the membership would be able to participate, thus ruling out any others - undemocratic in other words. It would be akin to not giving out voters lists until after the election.
There are clearly many contradictions in the Constitution. However, the one requirement, reinforced over and over again, is the necessity of recognizing the principles and aims. It is clearly the most dominant portion of the Constitution which all other sections are subordinate to. It is my belief that it was written that way to safeguard the democratic rights of the people of Newfoundland and Labrador - the membership at large.
de·moc·ra·cy /dɪˈmɒkrəsi/ Show Spelled[dih-mok-ruh-see] Show IPA
1.government by the people; a form of government in which the supreme power is vested in the people and exercised directly by them or by their elected agents under a free electoral system.
2.a state having such a form of government: The United States and Canada are democracies.
3.a state of society characterized by formal equality of rights and privileges.
4.political or social equality; democratic spirit.
5.the common people of a community as distinguished from any privileged class; the common people with respect to their political power.
Thank -you to all those people who have shown your support, whether in person or in action.
Brad Cabana
8 comments:
- AnonymousJanuary 16, 2011 at 11:54 AM
You're not in Saskatchewan anymore, we have our own rules and unless you decide to abide by them don't bother to run for politics.ReplyDelete
anonymous needs his mommy to remind him of his manners. making threats in front of a mans family in his home is one of those 'old rules' we don't take too kindly to around the bay.ReplyDelete
since the rules depend on who you are here, and whether or not you classify as a political entity or not i say let the man be since he wants to take it to the political level.
he's just doing what he thinks is right, and that's good enough for the majority of us.
- AnonymousJanuary 16, 2011 at 8:19 PM
Brad - you should focus on your appeal (in part) on the basis that the constituion differentiates between "district association" and "district association executive"ReplyDelete
Nowhere, absolutely nowhere does it ever say you need to be a member of a "district association executive" in order to vote, or nominate.
The party is trying to blur the line between one and the other.
Thank-you for that advice, I will add it to my already large list. Much appreciated! Brad.ReplyDelete
- AnonymousJanuary 17, 2011 at 12:20 AM
Don't forget the fact that they never actually called the convention, which they were obligated to do in the first place.ReplyDelete
Thank-you, and yes that is true. The convention is suposed to be called prior to nominations according to the Constitution. BradReplyDelete
Good luck with your appeal Brad.ReplyDelete
Democracy, the wheels turning of the machine, is wonderful non?
Thank-you Grey Lady, I've found that democracy works in mysterious ways, oui.ReplyDelete
Comments are welcome that contribute to the discussion or foster further debate.
In the interests of ensuring that people take responsibility for their own words, individuals can make comments using their Blogger ID or OpenID.
Profiles should be open to the public and reveal an e-mail address so that people may contact the commenter directly.
Anonymous comments, including those from people using fake, apparently fake identities, or profiles without contact information may be deleted. Spam will be deleted as soon as it is identified.


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Tuesday, 8 November 2011
And I was reminded again of what a fucking miserable business it all is. From the moment you start queueing for checking, through the several pointless and unpleasant "security checks" where bored cunts are clearly just seeing how far they can go and keep a straight face.
Take your belt off (It's leather and has a tiny buckle), take your shoes off, take out your laptop, do this, do that, stand over here, have you got your toothpaste in a bag, blah blah blah. It's all fucking bollocks. I'm bloody sure if I put my mind to it, I could find a way to subvert it, and I'm the least devious, most open person I know.
So I'm amused to hear that not only has Theresa May had to defend herself because someone at the UK Borders Agency decreed that people should be waved through to reduce queues, but that there is also an immigration debate (I caught the tail end of the exposé on the idiot lantern and there was the predictable bollocks that they had let through some people who were claiming benefits and weren't entitled to them - why is this UKBA's problem and not the problem of the FUCKING WELFARE DEPARTMENT?)
Now there has been a 100,000-signature e-petition which means that the government needs to debate tightening up border controls. This is fucking bollocks. Most of the migration coming into the UK is from the EU and there's nothing that anyone can do about that. And the vast majority of immigrants who come here, add something to the UK.
Yes, there are dole-bludging cunts and murderers and rapists, but fuck knows, we have more than enough home-grown of all of the above. I'd rather have a hard-working Somali cock-washer than a dole-bludging Northern gimp any day of the fucking week.
This is just more pandering to people who won't or can't think about what is going on here, or are just old-fashioned bigots. And conclusive proof that even the most direct democracy is just a festering pile of cock. Just because the majority or a significant minority believe some horseshit, doesn't give them the right to force it on the rest of us.
12 comments:
- Mark Wadsworth said...
Agreed. This island could easily cope with a population of a couple of hundred million, we'd just have to organise ourselves properly.
- 8 Nov 2011, 09:04:00
- RantinRab said...
And once again the 'great British public' have been played like a fucking fiddle.
- 8 Nov 2011, 10:21:00
>have you got your toothpaste in a bag, blah blah blah.
"Are you carrying any liquids or creams?"
Why, yes. Would you like to see?
- 8 Nov 2011, 10:35:00
"This island could easily cope with a population of a couple of hundred million"
Agreed - but why should we?
- 8 Nov 2011, 11:36:00
- Michael Fowke said...
Reminds me of a scene in Airplane 2, where they let a load of terrorists through carrying guns then throw an old lady up against the wall.
- 8 Nov 2011, 13:39:00
"And the vast majority of immigrants who come here, add something to the UK."
Er ... evidence.
Even if true it doesn't justify giving a free ticket to those whose object is to take something away.
- 8 Nov 2011, 16:22:00
- Cingoldby said...
The majority of the British public may well be retarded gimps, but they are still less retarded and less gimpish than the professional political class, which is why direct democracy would be an imporvement and which is why the politicians will do anything possible to block it.
- 9 Nov 2011, 00:43:00
- Cingoldby said...
- 9 Nov 2011, 00:44:00
Fuck right off with that. There are half a million Somalis here and almost all of them are on the dole. You pay for them. And that's without mentioning their horrible predatory 'religion'.
- 9 Nov 2011, 01:04:00
- JuliaM said...
"... why is this UKBA's problem and not the problem of the FUCKING WELFARE DEPARTMENT?"
Because prevention is usually considered better than cure?
I take your point about the EU free movement though.
- 9 Nov 2011, 05:18:00
- JuliaM said...
"This island could easily cope with a population of a couple of hundred million"
Agreed - but why should we?"
Oh, this! A thousand times, this...
- 9 Nov 2011, 05:19:00
- Duncan @ Trabasack said...
Hahaha! All true. This is why I like you.
- 11 Nov 2011, 10:07:00


text:
The four hour journey passed quickly and we arrived at Termini to blue skies and warmth. We picked up our new e-Roma cards which we had ordered online & topped up with weekly tickets then took the metro to Spagna.
Our apartment is literally five minutes walk away. It is on the fifth floor and has an elevator - what luxury!
A quick turnaround and we are out again to see the sun set from Ponte Umberto.
Colappichioni is our next port of call where we admire the festive windows before picking up a pangiallo for our Italian Christmas feast back home.
Constantini is looking very jolly & here we stock up on Villa Simone Cesanese wine from their own vineyards
A quick bus trip brings us to Piazza Augusto Imperatore from where we stroll around the Christmas lit streets.
We arrive at Pizzeria Leoncini unfashionably early but are keen to sample our first Roman pizza this trip. It doesn't disappoint - the sausage, bean & red onion topping is delicious
Our evening ends with a night time view from the apartment.


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Text of the U.S. Supreme Court's Decision In the Bob Jones and Goldsboro Cases
Following is the text of the U.S. Supreme Court's decision in the cases Bob Jones University v. U.S. and Goldsboro Christian Schools v. U.S., in which the Court upheld rulings by the U.S. Court of Appeals for the Fourth Circuit. The entire texts of the majority opinion by Chief Justice Burger and the dissenting opinion by Associate Justice Rehnquist are included; the concurring opinion by Associate Justice Powell has been excerpted. In the pages that follow, single asterisks in brackets, [
- ], denote footnotes that have been omitted; double asterisks, [
- ], denote legal citations omitted. Remaining footnotes appear at the end of each opinion.
Until 1970, the Internal Revenue Service granted tax-exempt status to private schools, without regard to their racial admissions policies, under 501(c)(3) of the Internal Revenue Service Code[
- ] [
- ] and granted charitable deductions for contributions to such schools under 170 of the Code. [
- ]
On January 12, 1970, a three-judge District Court for the District of Columbia issued a preliminary injunction prohibiting the irs from according tax-exempt status to private schools in Mississippi that discriminated as to admissions on the basis of race. Green v. Kennedy, 309 F. Supp. 1127 (D.D.C.), app. dismissed sub nom. Cannon v. Green, 398 U.S. 956 (1970). Thereafter, in July 1970, the irs concluded that it could "no longer legally justify allowing tax-exempt status [under 501(c)(3)] to private schools which practice racial discrimination." [
- ] At the same time, the irs announced that it could not "treat gifts to the schools as charitable deductions for income tax purposes [under 170.]" By letter dated November 30, 1970, the irs formally notified private schools, including those involved in this case, of this change in policy, "applicable to all private schools in the United States at all levels of education." [
- ]
On June 30, 1971, the three-judge District Court issued its opinion on the merits of the Mississippi challenge. Green v. Connally, 330 F. Supp. 1150 (D.D.C.) aff'd sub nom. Coit v. Green, 404 U.S. 997 (1971) (per curiam). That court approved the irs's amended construction of the Tax Code. The court also held that racially discriminatory private schools were not entitled to deductions for contributions to such schools under 170. The court permanently enjoined the Commissioner of Internal Revenue from approving tax-exempt status for any school in Mississippi that did not publicly maintain a policy of nondiscrimination.
The revised policy on discrimination was formalized in Revenue Ruling 71-447, 1971-2 Cum. Bull. 230:
"Both the courts and the Internal Revenue Service have long recognized that the statutory requirements of being 'organized and operated exclusively for religious, charitable, ... or educational purposes' was intended to express the basic common law concept [of 'charity']. ... All charitable trusts, educational or otherwise, are subject to the requirement that the purpose of the trust may not be illegal or contrary to public policy." [
- ]
Based on the "national policy to discourage racial discrimination in education," the irs ruled that "a private school not having a racially nondiscriminatory policy as to students is not 'charitable' within the common law concepts reflected in sections 170 and 501(c)(3) of the Code." [
- ]
The application of the irs construction of these provisions to petitioners, two private schools with racially discriminatory admissions policies, is now before us.
No. 81-3Bob Jones Universityv.United States
Bob Jones University is a nonprofit corporation located in Greenville, South Carolina.[
- ] Its purpose is "to conduct an institution of learning ..., giving special emphasis to the Christian religion and the ethics revealed in the Holy Scriptures." [
- ] The corporation operates a school with an enrollment of approximately 5,000 students, from kindergarten through college and graduate school. Bob Jones University is not affiliated with any religious denomination, but is dedicated to the teaching and propagation of its fundamentalist Christian beliefs. It is both a religious and educational institution. Its teachers are required to be devout Christians, and all courses at the University are taught according to the Bible. Entering students are screened as to their religious beliefs, and their public and private conduct is strictly regulated by standards promulgated by University authorities.
The sponsors of the University genuinely believe that the Bible forbids interracial dating and marriage. To effectuate these views, Negroes were completely excluded until 1971. From 1971 to May 1975, the University accepted no applications from unmarried Negroes,[
- ] but did accept applications from Negroes married within their race.
Following the decision of the United States Court of Appeals for the Fourth Circuit in McCrary v. Runyon [
- ] (1976), prohibiting racial exclusion from private schools, the University revised its policy. Since May 29, 1975, the University has permitted unmarried Negroes to enroll; but a disciplinary rule prohibits interracial dating and marriage. That rule reads:
There is to be no interracial dating.
1. Students who are partners in an interracial marriage will be expelled.
2. Students who are members of or affiliated with any group or organization which holds as one of its goals or advocates interracial marriage will be expelled.
3. Students who date outside their own race will be expelled.
4. Students who espouse, promote, or encourage others to violate the University's dating rules and regulations will be expelled. [
- ]
The University continues to deny admission to applicants engaged in interracial marriage or known to advocate interracial marriage or dating. [
- ]
Until 1970, the irs extended tax-exempt status to Bob Jones University under 501(c)(3). By the letter of November 30, 1970, that followed the injunction issued in Green v. Kennedy, supra, the irs formally notified the University of the change in irs policy, and announced its intention to challenge the tax-exempt status of private schools practicing racial discrimination in their admissions policies.
After failing to obtain an assurance of tax exemption through administrative means, the University instituted an action in 1971 seeking to enjoin the irs from revoking the school's tax-exempt status. That suit culminated in Bob Jones University v. Simon, 416 U.S. 725 (1974), in which this Court held that the Anti-Injunction Act of the Internal Revenue Code [
- ] prohibited the University from obtaining judicial review by way of injunctive action before the assessment or collection of any tax.
Thereafter, on April 16, 1975, the irs notified the University of the proposed revocation of its tax-exempt status. On January 19, 1976, the irs officially revoked the University's tax-exempt status, effective as of December 1, 1970, the day after the University was formally notified of the change in irs policy. The University subsequently filed returns under the Federal Unemployment Tax Act for the period from December 1, 1970 to December 31, 1975, and paid a tax totaling $21.00 on one employee for the calendar year of 1975. After its request for a refund was denied, the University instituted the present action, seeking to recover the $21.00 it had paid to the irs. The Government counter-claimed for unpaid federal unemployment taxes for the taxable years 1971 through 1975, in the amount of $489,675.59, plus interest.
The United States District Court for the District of South Carolina held that revocation of the University's tax-exempt status exceeded the delegated powers of the irs, was improper under the irs rulings and procedures, and violated the University's rights under the Religion Clauses of the First Amendment. [
- ] The court accordingly ordered the irs to pay the University the $21.00 refund it claimed and rejected the irs counterclaim.
The Court of Appeals for the Fourth Circuit, in a divided opinion, reversed. [
- ] Citing Green v. Connally, supra, with approval, the Court of Appeals concluded that 501(c)(3) must be read against the background of charitable trust law. To be eligible for an exemption under that section, an institution must be "charitable" in the common law sense, and therefore must not be contrary to public policy. In the court's view, Bob Jones University did not meet this requirement, since its ''racial policies violated the clearly defined public policy, rooted in our Constitution, condemning racial discrimination and, more specifically, the government policy against subsidizing racial discrimination in education, public or private." [
- ] The court held that the irs acted within its statutory authority in revoking the University's tax-exempt status. Finally, the Court of Appeals rejected the petitioner's arguments that the revocation of the tax exemption violated the Free Exercise and Establishment Clauses of the First Amendment. The case was remanded to the District Court with instructions to dismiss the University's claim for a refund and to reinstate the Government's counterclaim.
No 81-1Goldsboro ChristianSchools, Inc.v.United States
Goldsboro Christian Schools is a nonprofit corporation located in Goldsboro, North Carolina. Like Bob Jones University, it was established "to conduct an institution of learning ..., giving special emphasis to the Christian religion and the ethics revealed in the Holy scriptures." [
- ] The school offers classes from kindergarten through high school, and since at least 1969 has satisfied the State of North Carolina's requirements for secular education in private schools. The school requires its high school students to take Bible-related courses, and begins each class with prayer.
Since its incorporation in 1963, Goldsboro Christian Schools has maintained a racially discriminatory admissions policy based upon its interpretation of the Bible. Goldsboro has for the most part accepted only Caucasians. On occasion, however, the school has accepted children from racially mixed marriages in which one of the parents is Caucasian.
Goldsboro never received a determination by the irs that it was an organization entitled to tax exemption under 501(c)(3). Upon audit of Goldsboro's records for the years 1969 through 1972, the irs determined that Goldsboro was required to pay taxes under the Federal Insurance Contribution Act and the Federal Unemployment Tax Act.
Goldsboro paid the irs $3,459.93 in withholding, social security, and unemployment taxes with respect to one employee for the years 1969 through 1972. Thereafter, Goldsboro filed a suit seeking refund of that payment, claiming that the school had been improperly denied 501(c)(3) exempt status.[
- ] The irs counterclaimed for $160,073.96 in unpaid social security and unemployment taxes for the years 1969 through 1972, including interest and penalties.[
- ]
The District Court for the Eastern District of North Carolina decided the action on cross-motions for summary judgment. [
- ] In addressing the motions for summary judgment, the court assumed that Goldsboro's racially discriminatory admissions policy was based on a sincerely held religious belief. The court nevertheless rejected Goldsboro's claim to tax-exempt status under 501(c)(3), finding that "private schools maintaining racially discriminatory admissions policies violate clearly declared federal policy and, therefore, must be denied the federal tax benefits flowing from qualification under Section 501(c)(3)." [
- ] The Court also rejected Goldsboro's arguments that denial of tax-exempt status violated the Free Exercise and Establishment Clauses of the First Amendment. Accordingly, the court entered summary judgment for the Government on its counterclaim.
The Court of Appeals for the Fourth Circuit affirmed [
- ]. That court found an "identity for present purposes" between the Goldsboro case and the Bob Jones University case, which had been decided shortly before by another panel of that court, and affirmed for the reasons set forth in Bob Jones University.
We granted certiorari in both cases, 454 U.S. 892 (1981), and we affirm in each.
In Revenue Ruling 71-447, the irs formalized the policy first announced in 1970, that 170 and 501(c)(3) embrace the common law "charity" concept. Under that view, to qualify for a tax exemption pursuant to 501(c)(3), an institution must show, first, that it falls within one of the eight categories expressly set forth in that section, and second, that its activity is not contrary to settled public policy.
Section 501(c)(3) provides that "[c]orporations ... organized and operated exclusively for religious, charitable, ... or educational purposes" are entitled to tax exemption. Petitioners argue that the plain language of the statute guarantees them tax-exempt status. They emphasize the absence of any language in the statute expressly requiring all exempt organizations to be "charitable" in the common law sense, and they contend that the disjunctive "or" separating the categories in Section 501(c)(3) precludes such a reading. Instead, they argue that if an institution falls within one or more of the specified categories it is automatically entitled to exemption, without regard to whether it also qualifies as "charitable." The Court of Appeals rejected that contention and concluded that petitioners' interpretation of the statute "tears section 501(c)(3) from its roots." United States v. Bob Jones University, supra, 639 F. 2d, at 151.
It is a well-established canon of statutory construction that a court should go beyond the literal language of a statute if reliance on that language would defeat the plain purpose of the statute:
"The general words used in the clause ..., taken by themselves, and literally construed, without regard to the object in view, would seem to sanction the claim of the plaintiff. But this mode of expounding a statute has never been adopted by any enlightened tribunal--because it is evident that in many cases it would defeat the object which the Legislature intended to accomplish. And it is well settled that, in interpreting a statute, the court will not look merely to a particular clause in which general words may be used, but will take in connection with it the whole statute ... and the objects and policy of the law. ...'' Brown v. Duchesne, 19 How. 183, 194 (1857) (emphasis added).
Section 501(c)(3) therefore must be analyzed and construed within the framework of the Internal Revenue Code and against the background of the Congressional purposes. Such an examination reveals unmistakable evidence that, underlying all relevant parts of the Code, is the intent that entitlement to tax exemption depends on meeting certain common law standards of charity--namely, that an institution seeking tax-exempt status must serve a public purpose and not be contrary to established public policy.
This "charitable" concept appears explicitly in 170 of the Code. That section contains a list of organizations virtually identical to that contained in 501(c)(3). It is apparent that Congress intended that list to have the same meaning in both sections.[
- ] In 170, Congress used the list of organizations in defining the term "charitable contributions." On its face, therefore, 170 reveals that Congress' intention was to provide tax benefits to organizations serving charitable purposes.[
- ] The form of 170 simply makes plain what common sense and history tell us: in enacting both 170 and 501(c)(3), Congress sought to provide tax benefits to charitable organizations, to encourage the development of private institutions that serve a useful public purpose or supplement or take the place of public institutions of the same kind.
Tax exemptions for certain institutions thought beneficial to the social order of the country as a whole, or to a particular community, are deeply rooted in our history, as in that of England. The origins of such exemptions lie in the special privileges that have long been extended to charitable trusts.
More than a century ago, this Court announced the caveat that is critical in this case:
"[I]t has now become an established principle of American law, that courts of chancery will sustain and protect ... a gift ... to public charitable uses, provided the same is consistent with local laws and public policy. ..." Perrin v. Carey, 24 How. 465, 501 (1861) (emphasis added).
Soon after that, in 1878, the Court commented:
"A charitable use, where neither law nor public policy forbids, may be applied to almost any thing that tends to promote the well-doing and well-being of social man." Ould v. Washington Hospital for Foundlings, 95 U.S. 303,311 (1878) (emphasis added). [
- ]
In 1891, in a restatement of the English law of charity[
- ] which has long been recognized as a leading authority in this country, Lord MacNaghten stated:
"'Charity' in its legal sense comprises four principal divisions: trusts for the relief of poverty; trusts for the advancement of education; trusts for the advancement of religion; and trusts for other purposes beneficial to the community, not falling under any of the preceding heads." Commissioners v. Pemsel, [1891] A.C. 531, 583 (emphasis added). [
- ]
These statements clearly reveal the legal background against which Congress enacted the first charitable exemption statute in 1894;[
- ] charities were to be given preferential treatment because they provide a benefit to society.
What little floor debate occurred on the charitable exemption provision of the 1894 Act and similar sections of later statutes leaves no doubt that Congress deemed the specified organizations entitled to tax benefits because they served desirable purposes. [
- ] In floor debate on a similar provision in 1917, for example, Senator Hollis articulated the rationale:
"For every dollar that a man contributes to these public charities, educational, scientific, or otherwise, the public gets 100 percent." [
- ]
In 1924, this Court restated the common understanding of the charitable exemption provision:
"Evidently the exemption is made in recognition of the benefit which the public derives from corporate activities of the class named, and is intended to aid them when not conducted for private gain." Trinidad v. Sagrada Orden, 263 U.S. 578, 581, (1924).[
- ]
In enacting the Revenue Act of 1938 [
- ], Congress expressly reconfirmed this view with respect to the charitable deduction provision:
"The exemption from taxation of money and property devoted to charitable and other purposes is based on the theory that the Government is compensated for the loss of revenue by its relief from financial burdens which would otherwise have to be met by appropriations from other public funds, and by the benefits resulting from the promotion of the general welfare."[
- ] [
- ].
A corollary to the public benefit principle is the requirement, long recognized in the law of trusts, that the purpose of a charitable trust may not be illegal or violate established public policy. In 1861, this Court stated that a public charitable use must be "consistent with local laws and public policy," Perrin v. Carey. Modern commentators and courts have echoed that view.[
- ] [
- ]
When the Government grants exemptions or allows deductions all taxpayers are affected; the very fact of the exemption or deduction for the donor means that other taxpayers can be said to be indirect and vicarious "donors." Charitable exemptions are justified on the basis that the exempt entity confers a public benefit--a benefit which the society or the community may not itself choose or be able to provide, or which supplements and advances the work of public institutions already supported by tax revenues. History buttresses logic to make clear that, to warrant exemption under 501(c)(3), an institution must fall within a category specified in that section and must demonstrably serve and be in harmony with the public interest.[
- ] The institution's purpose must not be so at odds with the common community conscience as to undermine any public benefit that might otherwise be conferred.
We are bound to approach these questions with full awareness that determinations of public benefit and public policy are sensitive matters with serious implications for the institutions affected; a declaration that a given institution is not "charitable" should be made only where there can be no doubt that the activity involved is contrary to a fundamental public policy. But there can no longer be any doubt that racial discrimination in education violates deeply and widely accepted views of elementary justice. Prior to 1954, public education in many places still was conducted under the pall of Plessy v. Ferguson, 163 U.S. 537 (1896); racial segregation in primary and secondary education prevailed in many parts of the country. [
- ] This Court's decision in Brown v. Board of Education, 347 U.S. 483 (1954), signalled an end to that era. Over the past quarter of a century, every pronouncement of this Court and myriad Acts of Congress and Executive Orders attest a firm national policy to prohibit racial segregation and discrimination in public education.
An unbroken line of cases following Brown v. Board of Education establishes beyond doubt this Court's view that racial discrimination in education violates a most fundamental national policy, as well as rights of individuals.
"The right of a student not to be segregated on racial grounds in schools ... is indeed so fundamental and persuasive that it is embraced in the concept of due process of law." Cooper v. Aaron, 358 U.S. 1, 19 (1958).
In Norwood v. Harrison, 413 U.S. 455, 468-469 (1973), we dealt with a non-public institution:
"[A] private school--even one that discriminates--fulfills an important education function; however, ... [that] legitimate educational function cannot be isolated from discriminatory practices ... [D]iscriminatory treatment exerts a pervasive influence on the entire educational process." (Emphasis added). [
- ]
Congress, in Titles IV and VI of the Civil Rights Act of 1964 [
- ], clearly expressed its agreement that racial discrimination in education violates a fundamental public policy. Other sections of that Act, and numerous enactments since then, testify to the public policy against racial discrimination. See, e.g., the Voting Rights Act of 1965 [
- ]; Title VIII of the Civil Rights Act of 1968 [
- ]; the Emergency School Aid Act of 1972 [
- ].
The Executive Branch has consistently placed its support behind eradication of racial discrimination. Several years before this Court's decision in Brown v. Board of Education, President Truman issued Executive Orders prohibiting racial discrimination in federal employment decisions [
- ] and in classifications for the Selective Service [
- ]. In 1957, President Eisenhower employed military forces to ensure compliance with federal standards in school desegregation programs. [
- ] And in 1962, President Kennedy announced:
"[T]he granting of federal assistance for ... housing and related facilities from which Americans are excluded because of their race, color, creed, or national origin is unfair, unjust, and inconsistent with the public policy of the United States as manifested in its Constititution and laws." [
- ]
These are but a few of numerous Executive Orders over the past three decades demonstrating the commitment of the Executive Branch to the fundamental policy of eliminating racial discrimination. [
- ]
Few social or political issues in our history have been more vigorously debated and more extensively ventilated than the issue of racial discrimination, particularly in education. Given the stress and anguish of the history of efforts to escape from the shackles of the "separate but equal" doctrine of Plessy v. Ferguson, it cannot be said that educational institutions that, for whatever reasons, practice racial discrimination, are institutions exercising "beneficial and stabilizing influences in community life," Walz v. Tax Comm'n [
- ] or should be encouraged by having all taxpayers share in their support by way of special tax status.
There can thus be no question that the interpretation of 170 and 501(c)(3) announced by the irs in 1970 was correct. That it may be seen as belated does not undermine its soundness. It would be wholly incompatible with the concepts underlying tax exemption to grant the benefits of tax-exempt status to racially discriminatory educational entities, which "exer[t] a pervasive influence on the entire educational process." Norwood v. Harrison [
- ]. Whatever may be the rationale for such private schools' policies, and however sincere the rationale may be, racial discrimination in education is contrary to public policy. Racially discriminatory educational institutions cannot be viewed as conferring a public benefit within the "charitable" concept discussed earlier, or within the Congressional intent underlying 170 and 501(c)(3).
Petitioners contend that, regardless of whether the irs properly concluded that racially discriminatory private schools violate public policy, only Congress can alter the scope of 170 and 501(c)(3). Petitioners accordingly argue that the irs overstepped its lawful bounds in issuing its 1970 and 1971 rulings.
Yet ever since the inception of the tax code, Congress has seen fit to vest in those administering the tax laws very broad authority to interpret those laws. In an area as complex as the tax system, the agency Congress vests with administrative responsibility must be able to exercise its authority to meet changing conditions and new problems. Indeed as early as 1918, Congress expressly authorized the Commissioner "to make all needful rules and regulations for the enforcement" of the tax laws. [
- ] The same provision, so essential to efficient and fair administration of the tax laws, has appeared in tax codes ever since [
- ], and this Court has long recognized the primary authority of the irs and its predecessors in construing the Internal Revenue Code. [
- ]
Congress, the source of irs authority, can modify irs rulings it considers improper; and courts exercise review over irs actions. In the first instance, however, the responsibility for construing the Code falls to the irs Since Congress cannot be expected to anticipate every conceivable problem that can arise or to carry out day-to-day oversight, it relies on the administrators and on the courts to implement legislative will. Administrators, like judges, are under oath to do so.
In 170 and 501(c)(3), Congress has identified categories of traditionally exempt institutions and has specified certain additional requirements for tax exemption. Yet the need for continuing interpretation of those statutes is unavoidable. For more than 60 years, the irs and its predecessors have constantly been called upon to interpret these and comparable provisions, and in doing so have referred consistently to principles of charitable trust law. In Treas. Reg. 45, art. 517(1) (1921), for example, the irs denied charitable exemptions on the basis of proscribed political activity before the Congress itself added such conduct as a disqualifying element. In other instances, the irs has denied charitable exemptions to otherwise qualified entities because they served too limited a class of people and thus did not provide a truly "public" benefit under the common law test. [
- ] Some years before the issuance of the rulings challenged in these cases, the irs also ruled that contributions to community recreational facilities would not be deductible and that the facilities themselves would not be entitled to tax-exempt status, unless those facilities were open to all on a racially nondiscriminatory basis. [
- ] These rulings reflect the Commissioner's continuing duty to interpret and apply the Internal Revenue Code. [
- ]
Guided, of course, by the Code, the irs has the responsibility, in the first instance, to determine whether a particular entity is "charitable" for purposes of 170 and 501(c)(3).[
- ] This in turn may necessitate later determinations of whether given activities so violate public policy that the entities involved cannot be deemed to provide a public benefit worthy of "charitable" status. We emphasize, however, that these sensitive determinations should be made only where there is no doubt that the organization's activities violate fundamental public policy.
On the record before us, there can be no doubt as to the national policy. In 1970, when the irs first issued the ruling challenged here, the position of all three branches of the Federal Government was unmistakably clear. The correctness of the Commissioner's conclusion that a racially discriminatory private school "is not 'charitable' within the common law concepts reflected in ... the Code," Rev. Rul. 71-447 [
- ] is wholly consistent with what the Congress, the Executive, and the courts had repeatedly declared before 1970. Indeed, it would be anomalous for the Executive, Legislative, and Judicial Branches to reach conclusions that add up to a firm public policy on racial discrimination, and at the same time have the irs blissfully ignore what all three branches of the Federal Government had declared. Clearly an educational institution engaging in practices affirmatively at odds with this declared position of the whole government cannot be seen as exercising a ''beneficial and stabilizing influenc[e] in community life," Walz v. Tax Comm'n [
- ] and is not "charitable" within the meaning of 170 and 501(c)(3). We therefore hold that the irs did not exceed its authority when it announced its interpretation of 170 and 501(c)(3) in 1970 and 1971.[
- ]
The actions of Congress since 1970 leave no doubt that the irs reached the correct conclusion in exercising its authority. It is, of course, not unknown for independent agencies or the Executive Branch to misconstrue the intent of a statute; Congress can and often does correct such misconceptions, if the courts have not done so. Yet for a dozen years Congress has been made aware--acutely aware--of the irs rulings of 1970 and 1971. As we noted earlier, few issues have been the subject of more vigorous and widespread debate and discussion in and out of Congress than those related to racial segregation in education. Sincere adherents advocating contrary views have ventilated the subject for well over three decades. Failure of Congress to modify the irs rulings of 1970 and 1971, of which Congress was, by its own studies and by public discourse, constantly reminded; and Congress' awareness of the denial of tax-exempt status for racially discriminatory schools when enacting other and related legislation make out an unusually strong case of legislative acquiescence in and ratification by implication of the 1970 and 1971 rulings.
Ordinarily, and quite appropriately, courts are slow to attribute significance to the failure of Congress to act on particular legislation. [
- ] We have observed that "unsuccessful attempts at legislation are not the best guides to legislative intent." [
- ] Here, however, we do not have an ordinary claim of legislative acquiescence. Only one month after the irs announced its position in 1970, Congress held its first hearings on this precise issue. [
- ] Exhaustive hearings have been held on the issue at various times since then. These include hearings in February 1982, after we granted review in this case. [
- ]
Non-action by Congress is not often a useful guide, but the non-action here is significant. During the past 12 years there have been no fewer than 13 bills introduced to overturn the irs interpretation of 501(c)(3).[
- ] Not one of these bills has emerged from any committee, although Congress has enacted numerous of the amendments to 501 during this same period, including an amendment to 501(c)(3) itself. [
- ] It is hardly conceivable that Congress--and in this setting, any Member of Congress--was not abundantly aware of what was going on. In view of its prolonged and acute awareness of so important an issue, Congress' failure to act on the bills proposed on this subject provides added support for concluding that Congress acquiesced in the irs rulings of 1970 and 1971. [
- ]
The evidence of Congressional approval of the policy embodied in Revenue Ruling 71-447 goes well beyond the failure of Congress to act on legislative proposals. Congress affirmatively manifested its acquiescence in the irs policy when it enacted the present 501(i) of the Code, Act of October 20, 1976. [
- ] That provision denies tax-exempt status to social clubs whose charters or policy statements provide for "discrimination against any person on the basis of race, color, or religion."[
- ] Both the House and Senate committee reports on that bill articulated the national policy against granting tax exemptions to racially discriminatory private clubs. [
- ]
Even more significant is the fact that both reports focus on this Court's affirmance of Green v. Connally, as having established that "discrimination on account of race is inconsistent with an educational institution's tax exempt status." [
- ] These references in Congressional committee reports on an enactment denying tax exemptions to racially discriminatory private social clubs cannot be read other than as indicating approval of the standards applied to racially discriminatory private schools by the irs subsequent to 1970, and specifically of Revenue Ruling 71-447.[
- ]
Petitioners contend that, even if the Commissioner's policy is valid as to nonreligious private schools, that policy cannot constitutionally be applied to schools that engage in racial discrimination on the basis or sincerely held religious beliefs.[
- ] As to such schools, it is argued that the irs construction of 170 and 501(c)(3) violates their free exercise rights under the Religion Clauses of the First Amendment. This contention presents claims not heretofore considered by this Court in precisely this context.
This Court has long held the Free Exercise Clause of the First Amendment an absolute prohibition against governmental regulation of religious beliefs. [
- ] As interpreted by this Court, moreover, the Free Exercise Clause provides substantial protection for lawful conduct grounded in religious belief. [
- ] However,"[n]ot all burdens on religion are unconstitutional. ... The state may justify a limitation on religious liberty by showing how it is essential to accomplish an overriding governmental interest." United States v. Lee, 455 U.S. 252-258 (1982) [
- ].
On occasion this Court has found certain governmental interests so compelling as to allow even regulations prohibiting religiously based conduct. In Prince v. Massachusetts [
- ], for example, the Court held that neutrally cast child labor laws prohibiting sale of printed materials on public streets could be applied to prohibit children from dispensing religious literature. The Court found no constitutional infirmity in "excluding [Jehovah's Witness children] from doing what no other children may do." [
- ] Denial of tax benefits will inevitably have a substantial impact on the operation of private religious schools, but will not prevent those schools from observing their religious tenets.
The governmental interest at stake here is compelling. As discussed in Part II(B), supra, the Government has a fundamental, overriding interest in eradicating racial discrimination in education[
- ]--discrimination that prevailed, with official approval, for the first 165 years of this Nation's history. That governmental interest substantially outweighs whatever burden denial of tax benefits places on petitioners' exercise of their religious beliefs. The interests asserted by petitioners cannot be accommodated with that compelling governmental interest [
- ] and no "less restrictive means," [
- ] are available to achieve the governmental interest.[
- ]
The remaining issue is whether the irs properly applied its policy to these petitioners. Petitioner Goldsboro Christian Schools admits that it "maintain[s] racially discriminatory policies," [
- ] but seeks to justify those policies on grounds we have fully discussed. The irs properly denied tax-exempt status to Goldsboro Christian Schools.
Petitioner Bob Jones University, however, contends that it is not racially discriminatory. It emphasizes that it now allows all races to enroll, subject only to its restrictions on the conduct of all students, including its prohibitions of association between men and women of different races, and of interracial marriage.[
- ] Although a ban on intermarriage or interracial dating applies to all races, decisions of this Court firmly establish that discrimination on the basis of racial affiliation and association is a form of racial discrimination, [
- ]. We therefore find the irs properly applied Revenue Ruling 71-447 to Bob Jones University.
The judgments of the Court of Appeals are, accordingly, Affirmed.
Section 170(a) allows deductions for certain "charitable contributions." Section 170(c)(2)(B) includes within the definition of "charitable contribution" a contribution or gift to or for the use of a corporation "organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes. ..."
Revenue Ruling 71-447, [
- ] defined "racially non-discriminatory policy as to students" as meaning that:
"The school admits the students of any race to all the rights, privileges, programs, and activities generally accorded or made available to students at that school and that the school does not discriminate on the basis of race in administration of its educational policies, admissions policies, scholarship and loan programs, and athletic and other school-administered programs."
According to the interpretation espoused by Goldsboro, race is determined by descendance from one of Noah's three sons--Ham, Shem, and Japheth. Based on this interpretation, Orientals and Negroes are Hamitic, Hebrews are Shemitic, and Caucasians are Japhethitic. Cultural or biological mixing of races is regarded as a violation of God's command. App. in No. 81-1, pp. 40-41.
After the Court granted certiorari, the Government filed a motion to dismiss, informing the Court that the Department of Treasury intended to revoke Revenue Ruling 71-447 and other pertinent rulings and to recognize 501(c)(3) exemptions for petitioners. The Government suggested that these actions were therefore moot. Before this Court ruled on that motion, however, the United States Court of Appeals for the District of Columbia Circuit enjoined the Government from granting 501(c)(3) tax-exempt status to any school that discriminates on the basis of race. Wright v. Regan, [
- ] Thereafter, the Government informed the Court that it would not revoke the revenue rulings and withdrew its request that the actions be dismissed as moot. The Government continues to assert that the irs lacked authority to promulgate Revenue Ruling 71-447, and does not defend that aspect of the rulings below.
The form and history of the charitable exemption and deduction sections of the various income tax acts reveal that Congress was guided by the common law of charitable trusts. [
- ] Congress acknowledged as much in 1969. The House Report on the Tax Reform Act of 1969, Pub.L. 91-172, 83 Stat. 487, stated that the 501(c)(3) exemption was available only to institutions that served "the specified charitable purposes," [
- ] and described "charitable" as "a term that has been used in the law of trusts for hundreds of years." [
- ] We need not consider whether Congress intended to incorporate into the Internal Revenue Code any aspects of charitable trust law other than the requirements of public benefit and a valid public purpose.
The dissent acknowledges that "Congress intended ... to offer a tax benefit to organizations ... providing a public benefit," [
- ] but suggests that Congress itself fully defined what organizations provide a public benefit, through the list of eight categories of exempt organizations contained in 170 and 501(c)(3). Under that view, any nonprofit organization that falls within one of the specified categories is automatically entitled to the tax benefits, provided it does not engage in expressly prohibited lobbying or political activities. [
- ] The dissent thus would have us conclude, for example, that any nonprofit organization that does not engage in prohibited lobbying activities is entitled to tax exemption as an "educational" institution if it is organized for the "instruction or training of the individual for the purpose of improving or developing his capabilities," 26 CFR 1.501(c)(3)-1(d)(3). [
- ] As Judge Leventhal noted in Green v. Connally, [
- ] Fagin's school for educating English boys in the art of picking pockets would be an "educational" institution under that definition. Similarly, a band of former military personnel might well set up a school for intensive training of subversives for guerilla warfare and terrorism in other countries; in the abstract, that "school" would qualify as an ''educational" institution. Surely Congress had no thought of affording such unthinking, wooden meaning to 170 and 510(c)(3) as to provide tax benefits to "educational" organizations that do not serve a public, charitable purpose.
In 1894, when the first charitable exemption provision was enacted, racially segregated educational institutions would not have been regarded as against public policy. Yet contemporary standards must be considered in determining whether given activities provide a public benefit and are entitled to the charitable tax exemption. In Wals v.Tax Comm'n, 397 U.S. 664,672-673 (1970), we observed: "Qualification for tax exemption is not perpetual or immutable; some tax-exempt groups lose that status when their activities take them outside the classification and new entities can come into being and qualify for the exemption."
Charitable trust law also makes clear that the definition of "charity" depends upon contemporary standards. [
- ]
In view of our conclusion that racially discriminatory private schools violate fundamental public policy and cannot be deemed to confer a benefit on the public, we need not decide whether an organization providing a public benefit and otherwise meeting the requirements of 501(c)(3) could nevertheless be denied tax-exempt status if certain of its activities violated a law or public policy.
Justice Powell misreads the Court's opinion when he suggests that the Court implies that "the Internal Revenue Service is invested with authority to decide which public policies are sufficiently 'fundamental' to require denial of tax exemptions," post, at 6. The Court's opinion does not warrant that interpretation. Justice Powell concedes that "if any national policy is sufficiently fundamental to constitute such an overriding limitation on the availability of tax-exempt status under 501(c)(3), it is the policy against racial discrimination in education." Post, at 2. Since that policy is sufficiently clear to warrant Justice Powell's concession and for him to support our finding of longstanding Congressional acquiescence, it should be apparent that his concerns about the Court's opinion are unfounded.
Bob Jones University also argues that the irs policy should not apply to it because it is entitled to exemption under 501(c)(3) as a "religious" organization, rather than as an "educational" institution. As discussed previously, the irs policy properly extends to all private schools, including religious schools. See n. 29, supra. The irs policy thus was properly applied to Bob Jones University.
Justice Powell, concurring in part and concurring in the judgment.
I join the Court's judgment, along with part III of its opinion holding that the denial of tax exemptions to petitioners does not violate the First Amendment. I write separately because I am troubled by the broader implications of the Court's opinion with respect to the authority of the Internal Revenue Service (irs) and its construction on 170(c) and 501(c)(3) of the Internal Revenue Code. ...
I ... concur in the Court's judgment that tax-exempt status ... is not available to private schools that concededly are racially discriminatory. I do not agree, however, with the Court's more general explanation of the justifications for the tax exemptions provided to charitable organizations. ...
With all respect, I am unconvinced that the critical question in determining tax-exempt status is whether an individual organization provides a clear "public benefit" as defined by the Court. Over 106,000 organizations filed 501(c)(3) returns in 1981. Internal Revenue Service, 1982 Exempt Organization/Business Master File. I find it impossible to believe that all or even most of those organizations could prove that they "demonstrably serve and are in harmony with the public interest" or that they are "beneficial and stabilizing influences in community life." Nor I am [sic] prepared to say that petitioners, because of their racially discriminatory policies, necessarily contribute nothing of benefit to the community. It is clear from the substantially secular character of the curricula and degrees offered that petitioners provide educational benefits.
Even more troubling to me is the element of conformity that appears to inform the Court's analysis. The Court asserts that an exempt organization must "demonstrably serve and be in harmony with the public interest," must have a purpose that comports with "the common community conscience," and must not act in a manner "affirmatively at odds with the declared position of the whole government." Taken together, these passages suggest that the primary function of a tax-exempt organization is to act on behalf of the Government in carrying out governmentally approved policies. In my opinion, such a view of 501(c)(3) ignores the important role played by tax exemptions in encouraging diverse, indeed often sharply conflicting, activities and viewpoints. As Justice Brennan has observed, private, non-profit groups receive tax exemptions because "each group contributes to the diversity of association, viewpoint, and enterprise essential to a vigorous pluralistic society." [
- ] Far from representing an effort to reinforce any perceived "common community conscience," the provision of tax exemptions to nonprofit groups is one indispensable means of limiting the influence of governmental orthodoxy on important areas of community life. ...
I do not suggest that these considerations always are or should be dispositive. Congress, of course, may find that some organizations do not warrant tax-exempt status. In this case I agree with the Court that Congress has determined that the policy against racial discrimination in education should override the countervailing interest in permitting unorthodox private behavior.
I would emphasize, however, that the balancing of these substantial interests is for Congress to perform. I am unwilling to join any suggestion that the Internal Revenue Service is invested with authority to decide which public policies are sufficiently "fundamental" to require denial of tax exemptions. Its business is to administer laws designed to produce revenue for the Government, not to promote "public policy." As former irs Commissioner Kurtz has noted, questions concerning religion and civil rights "are far afield from the more typical tasks of tax administrators--determining taxable income." [
- ] This Court has expressed concern that the scope of an agency's authorization be limited to those areas in which the agency fairly may be said to have expertise[
- ], and this concern applies with special force when the asserted administrative power is one to determine the scope of public policy. ...
The Court's decision upholds irs Revenue Ruling 71-447, and thus resolves the question whether tax-exempt status is available to private schools that openly maintain racially discriminatory admissions policies. There no longer is any justification for Congress to hesitate--as it apparently has--in articulating and codifying its desired policy as to tax exemptions for discriminatory organizations. Many questions remain, such as whether organizations that violate other policies should receive tax-exempt status under 501(c)(3). These should be legislative policy choices. It is not appropriate to leave the irs "on the cutting edge of developing national policy." [
- ] The contours of public policy should be determined by Congress, not by judges or the irs
Certainly 501(c)(3) has not been applied in the manner suggested by the Court's analysis. The 1,100-page list of exempt organizations includes--among countless examples--such organizations as American Friends Service Committee, Inc., Committee on the Present Danger, Jehovah's Witnesses in the United States, Moral Majority Foundation, Inc., Friends of the Earth Foundation, Inc., Mountain States Legal Foundation, National Right to Life Educational Foundation, Planned Parenthood Federation of America, Scientists and Engineers for Secure Energy, Inc., and Union of Concerned Scientists Fund, Inc. [
- ] It would be difficult indeed to argue that each of these organizations reflects the views of the "common community conscience" or "demonstrably ... is in harmony with the public interest." In identifying these organizations, largely taken at random from the tens of thousands on the list, I of course do not imply disapproval of their being exempt from taxation. Rather, they illustrate the commendable tolerance by our Government of even the most strongly held divergent views, including views that at least from time to time are "at odds" with the position of our Government. We have consistently recognized that such disparate groups are entitled to the privilege of tax exemption.
Vol. 02, Issue 36
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text:
Calling all local community groups - tell your stories of Preston!
What's your story? What would you like to feature in one of our display cases?
We're offering local community groups the chance to be featured in the new history gallery, Discover Preston, to tell their stories about Preston, its culture and its communities.
There will be two opportunities per year to be featured in the 'Changing Display Case' which is found in the Discovery Room in the Discover Preston gallery.
Displays will be on show for circa three months and local groups can show their own collections, or can choose things from the Harris' collection to bring their story to life.
This is a unique chance for local groups to work with museum staff and share ideas and skills. We will help groups to develop their story, put together their display, and then hold talks and activities that tell visitors more about their story and display.
To find out more about the selection process and to apply:
Visit the Changing Display case page on this website, and download and complete the proposal form, or
Call the Discover Preston Learning & Access Officer on 01772 905428, or
Pick up an application pack from the Harris Museum & Art Gallery in Market Square.
The deadline for proposals to be submitted to the selection panel for the first display is 31st December 2012 (display will be shown from July 2013).
So, if you've got a new story about Preston that you think everyone should know about, apply now!


text:
People spend more than 80% of their time indoors. In contrast to ambient air, no (legal) limits for indoor particulate matter exist, although there are WHO guidelines. In the Netherlands a measurement protocol to determine the PM2.5 in office buildings has been developed including 5 quality classes. However at the moment no simple guidelines or models are available which can support the design and in-use phases to predict the PM2.5 concentration in office buildings and schools.
The GK environmental house is the first office building in Norway built according to the passive house concept. In such buildings, it is crucial to develop a ventilation strategy to reduce the energy use outside of the operating time. An optimal operating strategy has been developed for cold days, when the outdoor temperature falls well below 0 °C, which is presented in this paper. Indeed, these conditions correspond to the largest heat loss.
An inherent element of the passive house is the system of exhaust ventilation in air supply. According to their class, air filters used in ventilation systems stop the contamination, but may also be the main source of secondary indoor contamination during long-term use.
In this paper, the change of energy use by telecommuting (working at home) is simulated for residential and office buildings by modeling the differences in the occupants' behavior. By summing up these results, the change in annual energy use in Osaka City caused by the saturation of telecommuting is evaluated in three dissemination scenarios for the transformation of office buildings.
Energy savings by integrating the daylighting availability in the electric lighting management contributes to the realization of 'Green Building'. This paper provides a simulation and calculation of office building in North China with RADIANCE software on the basis of theoretical analysis, which focuses on the influence of Window-to-Wall Ratio (WWR), sill height, glazing transmittance and window shape on Lighting Savings (LS). The study finds out the relationship between those window parameters and LS. The results may be reference for designers as daylighting is involved.
Cool roof is a well-documented passive cooling strategy for buildings in several climate conditions. The mechanism consists of the reduction of the heat load entering the roof, which is characterized by high solar reflectance and high thermal emittance. The purpose of this paper is to study the coupled effect produced by such a technology. First, the passive cooling contribution is quantified, then, the "active" contribution is investigated.
Utilizing a cool roof is an efficient way to reduce the cooling energy use of a building. Cool roofs, however, may increase heating energy use in winter. In cold climates, during the winter the sun angle is lower, days are shorter, sky is cloudy, and most heating occur during early morning or evening hours when the solar intensity is low. In addition, the roof may be covered with snow for most of the heating season. All these lead to a lower (than what is commonly thought) winter time heating penalties for cool roofs.
The airtightness of office and educational buildings influences energy use and thermal comfort. A leaky building is likely to have a high use of energy and thermal discomfort. The knowledge of real airtightness levels of entire buildings and their impact on the energy use is very low, except for a study carried out in the USA. Therefore two different methods of airtightness testing were applied to six entire Swedish office and educational buildings built since 2000. The first method involves using the ventilation system of the building and the second one to use a number of blower doors.
In this study, an attempt is made to define building design variables for a medium-sized office building with individual office cells in order to provide sufficient summer comfort without active cooling in a moderate climate.
Firstly, an approach to take realistic window-opening behavior into account is proposed based on observational data in literature. A stochastic model is defined for an active and a passive user, representing the variability between individuals.
The scope of the research described in this paper is to develop, evaluate and propose a new empirical index, the so-called Index of Workplace Comfort (IWC), which quantifies the overall comfort sensation of a user in an office building. The proposed Index of Workplace Comfort is calculated on the basis of both environmental and psychological properly weighted sensation votes of workplace occupants.


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Dpto amoblado centro historico
Dpto amoblado centro historico
Le logement
The apartment is located in a privileged area of Santiago, close to the historic center, just steps from the Metropolitan Park (Cerro San Cristobal), steps from Bellavista (where you find theaters, bars, restaurants and a house - museum of Pablo Neruda) and subway.
INCREDIBLE VIEWS! Building with barbecue, pool, gym, 24 hour concierge. Modern Department. The building has a BBQ area and a rooftop pool with panoramic views of Santiago.
And with BICYCLES for tourists!
The apartment has all the necessary amenities to make your stay pleasant to the city of Santiago. The furnished kitchen (refrigerator, microwave, bar for a drink or eat, cooking utensils, kettle, gas stove), living room with sofa bed. These are the common areas.
The double bed room with TV, en suite bathroom, terrace with table and chairs to enjoy the view of the city.
I can advise you to visit:
Santiago is the capital, is a modern city, nightlife, restaurants, parks, and like any metropolis be careful with with your belongings, but not more crime than in other countries. Other MUST GO places: Easter Island, Torres del Paine (south of the world, is an amazing park where you can see ancient glaciers, forests, rivers and lakes), Viña del Mar / Valparaiso, San Pedro de Atacama (village located in the driest desert in the world).
Salle de sport
Indisponible : Détecteur de fumée
Indisponible : Détecteur de monoxyde de carbone


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- Leading elephant conservationist shot dead in Tanzania
- The State Of Tanzania's Forests
- Tanzania's President Renews Call To Conserve Elephants
- UN Recommends Kilimanjaro Reforestation
- Tanzania's Ecosystems Under Assault
- China Widens Ban On Ivory
- Climate Change Could Impoverish Tanzania
- Most Wanted Ivory Trafficker In Tanzania Arrested
- Tanzanian Students Lead International Group Up Kilimanjaro
- Mellowswan A Finalist In MIT Climate Challenge
Tag Archives: climate change and forest conservation Tanzania Africa
Deforestation Threatens Tanzania's Future
Mellowswan Proposes National Reforestation Project For Tanzania Deforestation is a widespread problem around the world and across Eastern Africa. Rising demand for charcoal results in a loss of some 575,000 hectares annually for fuel wood just in Tanzania. Fires, illegal harvesting … Continue reading


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NIMES, France -- At least one person was killed and four injured in a blast at a nuclear site in the south of France on Monday as the government sought to play down fears of a radioactive leak.
France's state nuclear regulator had said earlier that there was a risk of a leak after the blast at Codolet in the Rhone Valley near the southern city of Nimes.
Despite killing one person and wounding at least four more, the blast "did not cause any radioactive leak", a spokesman at the energy ministry said.
National electricity provider EDF confirmed the initial death toll following the explosion in an oven at the site.
One of the injured is in a serious condition, France's Nuclear Safety Authority (ASN) said, officially declaring the incident "over".
"This accident has no radiological risk or need for population protection," the ASN said, adding that it had suspended its crisis cell dealing with the incident.
The blast hit the Centraco nuclear waste treatment center belonging to EDF subsidiary Socodei, said a spokesman for the Atomic Energy Commissariat (CEA).
"Initial reports suggest there was an explosion in an oven used to melt metallic low- and very low-level radioactive waste," the ASN said.
An EDF spokesman said: "This is an industrial accident, not a nuclear accident."
"In this kind of oven, there are two sorts of waste: metallic waste such as valves, pumps and tools and combustible waste such as technicians' work outfits or gloves," the spokesman said.
An expert at the Institute for Radioprotection and Nuclear Safety in Paris, Olivier Isnard, said radioactive levels in the oven were only around 17 becquerels per kilo -- "very, very low" -- at the time of the blast.
"We don't expect there to be an impact on the environment," Isnard said, adding that samples would be taken from grass, soil and dust on cars to confirm this.
The interior ministry said that no one was evacuated from near the site nor were any workers confined following the blast.
Those injured "have not been contaminated" and the fatality was caused by the explosion, the ministry said.
Environment Minister Nathalie Kosciuscko-Morizet was due to arrive at the site on Monday afternoon, her ministry said, "to help carry out a precise evaluation of the possible radiological impact of this accident".
"For the time being, no exterior impact has been detected," a source at the ministry said.
"There are several detectors on the outside and none of them detected anything, the building is sound," an adviser at the ministry told AFP, adding that "we do not yet know what caused the blast".
The site is around 20 kilometers (12 miles) north of the historic city of Avignon which is thronged with tourists at this time of the year.
EDF's share price dropped over six percent on the news of the blast.
France said in June it would invest one billion euros ($1.4 billion at the time) in future nuclear power development while boosting research into security.
France produces most of its energy from nuclear power. Some countries, notably its EU neighbor Germany, have rejected nuclear power after the Fukushima reactor disaster in Japan.
Environmental lobby group Greenpeace demanded total and immediate transparency from the authorities.
"It's essential for local populations to be informed in real time about the situation and possible radioactive discharge," said campaigner Yannick Rousselet.
He pointed out that the site was not covered by the audit of French nuclear sites ordered after the Fukushima disaster nor had it been part of the ASN's latest round of inspections.


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May 19, 2015
The Crow and the Wolf
It's been a long journey since Wither Studios began conceiving the shadows that would become Crowman & Wolfboy (C&W) and we've had many highs and lows during the development of our first game as an independent game company. More recently, people have begun to ask when new content would be coming as the game currently ends with a cliff hanger. Even though we would love to see all of our plans for C&W come to life, please understand that our situation may prevent this from happening.
The Wither team works part time although it is our goal to eventually become full time! We began working on C&W towards the end of 2011. Shortly after development started, we created a Kickstarter to help us pay for things we couldn't cover out of pocket. The Kickstarter was successful (the goal was for $4,000 and we got $6,000) and, after fees/reward fulfillment, we were left with less than $5K.
After years of hard work, C&W was released on iTunes in October, 2013. Upon release on iOS, the game made about $7K with sales quickly dying down and flat lining after 3 months. At this time, we started a new promotion obtaining us almost 250,000 downloads (nearly all were free due to the promotion). Within a week of the promotion ending, sales spiked making us around $6,000 and the next three months pulled in about $300 per month followed by once again drastically declining sales. Although our user/professional reviews were good (averaging 4 1/2 stars and currently a 78 on meta critic), we just didn't have the marketing funds to get the attention the game needed. Furthermore, Apple never featured us which is very important in the mobile industry for attaining sales. In 2014, C&W was selected to be a part of the Indie Showcase at PAX East bringing us the belief that this was exactly what we needed. However, we ended up spending way more money simply participating in PAX compared to the relatively few sales we gained in return. Surprisingly, PAX did not garner us much media attention despite being part of the Showcase.
With sales floundering, we decided to restructure C&W for Android as a free to play game. After months of re-configuring the game to fit a free to play model (a necessity on Android), we released it on the Google Play Store and have made under $700 total to date (over 8 months). Up to this date, C&W has netted roughly 470,000 downloads and seen a profit of roughly $18,000 across all platforms. That may sound like a lot, but know that we still haven't even been able to pay ourselves back for the amount of money each team member has contributed. Currently some of us have been working towards making C&W work on desktop for a Steam Early Access release on which the fate of C&W now rests. If it does well enough to support further development, then we can finish the expansions we want to create. However, if the sales are low then we cannot proceed with any further development for C&W without dumping our own personal money into something we will not see a return in.
On a more positive note, the porting process to Steam doesn't require the full team. As such, over the past few months we've been conjuring up our next game concept. We won't say much besides that it will be something totally different from C&W and we are super pumped about it! We'll share more details when things are further along!


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November 17, 2007
November 17, 2007
The Beatles isn't–Okay maybe they have been a tad degraded
I'm told "Yesterday" has more than 3000 recorded versions, 2500 of which are likely elevator music quality.
One Paul's, 499 ring tones, and 2500 elevator music quality. There's a shadow hanging over tune. Oh, yesterday came suddenly.
Makes sense to me.
I wouldn't consider Dylan or The Rolling Stones elevator music.
Or Led Zeppelin. They are stairway music.
Stairway To Heaven or Elevator To Heaven


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|These were made by Sandy Wilt and Angelina Paese
|Made by Stacy Miller and Kristy Kelly
|Made by Stacey Epler and Brenda Kiehl
Stampin' Up Supplies:
Cardstock: Whisper White, Sycamore Street Designer Series Paper
Accessories: Sycamore Street Ribbon & Button Pack, Basic Pearls, Flower Trim.
Framelits - Apothecary Accents, Dress Up, Delicate Designs Embossing Folder
So buy these Dress Up Framelits! You know you want them.


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FOREIGN AFFAIRS – STRATEGIC BASE IN AFGHANISTAN – 30 October 2012
Dr Julian Lewis: Did the Minister see the important article in The Sunday Times this weekend, which made it clear that after 2014 the Taliban will be targeting all the progressive steps that have been taken, and will he therefore seek to open the Government's mind a little more to the prospect of trying to preserve those gains by supporting the concept of a strategic base in the area after 2014 for international security assistance forces?
[The Parliamentary Under-Secretary of State for Foreign and Commonwealth Affairs (Alistair Burt): How the use of forces will be made after 2014 is still to be considered. My hon. Friend has made this plea before. I would say in response to the Taliban that one of the most significant events in recent weeks has been the public response to the Taliban in Pakistan, in support of the young girl Malala and her right to education. Bearing in mind the links between the Taliban in Pakistan and in Afghanistan, that assertion by the people of Pakistan of the importance of women's rights and women's education may be the best response we have yet seen to the demands of the Taliban, and a consideration that they may not be accepted by the people themselves, which would be the best guarantor of women's rights in the future.]


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More recently, the University library has been getting lots of researchers, especially foreigners who deem it fit to visit our library for the rich resources therein.. Some of these researchers come unannounced, while some write to the library first, to establish contact before visiting.
Today, these two researchers officially announced their presence at the Library by paying visit (courtesy call) to the University Librarian - Professor Chinwe N. Ezeani. See pictures after the cut...
|The Univ. Librarian (Prof. C. N. Ezeani) and the Deputy Univ. Librarian (Vin Ekwelem), posing with the foreign researchers
The University Librarian, having a chat with the researchers


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- This event has passed.
OFTeen Improv Troupe
Feb. 6, 2018 @ 4:00 pm - 6:00 pm
An event every week that begins at 4:00pm on Tuesday, repeating until Mar. 20, 2018
The OFTeen Improv Troupe* will have 10 weeks together to grow and develop as an ensemble. We will expand on the basic skills learned in OFT's week-long camp experiences as we explore both short and long form improv technique, games, theory, tricks and tools. To enrich our work, we will welcome professional local improvisers to join us as special guests.
The Troupe will meet Tuesdays, Jan 16th-March 20th from 4- 6pm, culminating in a public performance after our last class on March 20th at 6pm.
Ages: 13 & up
Schedule : Jan 16-Mar 20 2018, 4-6pm
Cost: $100
Director: Vanessa Postil
*Prerequisite: Student has taken at least one week of teen improv at OFT in the past 2 years


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Henley Royal Regatta Chauffeurs
Start your Royal Regatta experience early with London Chauffeur UK; stunning cars, sumptuous refreshments & sophisticated service as standard
It's not called the Royal Regatta for nothing so you need a chauffeur driven car that looks the part to whisk you away to an exciting day at Henley. London Chauffeur UK don't just stop at a handsome set of wheels, we provide exemplary service plus refreshments and a paper of your choice as standard so you can relax and arrive feeling fabulous.
Fancy a tipple?
Ice-cold champagne and other delicious drinks are easily arranged, as are some naughty but nice nibbles and anything else you might require to make your journey even more enjoyable.
Get ready to feel like a HRH as your chauffeur sweeps wide the door to mark your arrival at the Henley Royal Regatta, and then relax with a Pimms and give yourself up to the spirit of the day, sure in the knowledge that your driver will be there to collect you as soon as you are ready to leave at the end.
Why choose our Henley Chauffeur service?
- All our cars have been designed to the highest specifications, guaranteed to be spotlessly clean, flawless and equipped with the latest technology for your entertainment and comfort
- All our chauffeurs are as smartly turned out as our cars, approachable, courteous and possessing the highest levels of experience and professionalism to be found anywhere in the industry
- We always arrive early and have a convenient 30 minute waiting period included with every booking for those conversations that you just can't leave! We also make sure we are plugged in to traffic reports to ensure we avoid any delays
- We pride ourselves in having the highest standards of customer service standards of any chauffeur company in London, nothing is too much trouble, all you have to do is ask
Ready to reserve your Henley chauffeur service?


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The white bow tie is not just the namesake of the White Tie Dress Code but also one of the most defining element of a formal tailcoat evening full fig outfit.
This Fort Belvedere White Marcella Pique Bow Tie is the number one choice for elegant men who want to look particularly dapper no matter if it is an Opera premiere, a wedding or a noble prize dinner.
Normally, most bow ties have two identical ends, but during the heyday of men's elegance, some particularly dapper English Gentlemen, invented the single end bow tie, which creates a superbly neat and elegant look.
When you look at photographs of 1920's and 1930's dinner parties you will notice that many men preferred a small bow tie rather than a big one, and for that very reason we decided to offer a small Single End Bow Tie In Satin as well.
You will not find a sized white Marcella Piqué bow tie in this small shape and quality anywhere else. If you prefer a single end bow tie in a larger shape, click here. If you prefer a smaller bow, this is the right one for you.
1. Quality Cotton Marcella Pique from Italy- Fort Belvedere sources this luxurious and three-dimensional cotton pique from a very small family owned Italian mill. It will work with your white tie vest and bib front shirt.
2. Handmade - This bow tie is entirely made by hand, so it is as delicate as possible.
3. Self-Tie Bow tie - Self-tie bow ties separate the gentlemen from the boys. It is essential that you know how to tie your bow tie. We provide video instructions on how to tie them for beginners and advanced connoisseurs.
4. Fixed Size - It is very rare to find fixed sized bow ties today especially the ones that are made from a solid piece of fabric in the back, which is essential for (detachable) wing collars because you never want any clasps showing in public. Unlike black tie, the only correct collar for white tie is a wing collar, and so you need a sized bow tie. In short, this fixed size white bow tie is the way to go for gentlemen.
5. Sophisticated Shape - This Butterfly Bow Tie will have dimensions of approx. 3.65" by 1.75" or 9.25 cm by 4.5 cm.
6. Small Single End Self-Tie Bow Tie - Self-tie bow ties separate the gentlemen from the boys, and single end bow ties are even one step up. The smaller size of this bow tie makes it the perfect piece of neckwear for short or slim men as well as people who like smaller bow ties.
A bow tie should never be tied to look perfectly symmetrical because it would look too much like a pre-tied cheap version, and who wants to look cheap? Instead, you should tie your black bow tie with a bit of wit, nonchalance or sprezzatura, meaning intentionally off-kilter with one end a little longer than the other, one side higher than the other, or a tight or a loose knot to achieve bow tie perfection.
Most bow ties suffer from poor interlining and the same boring two shapes - not so Fort Belvedere bow ties. This single end bow tie will stand on its own, and looks particularly dapper with a wing collar, but a soft turndown collar works just as fine. It is slightly smaller than our sized bow tie but still large enough to work with any face. This black silk satin single ended bow tie works well with all kinds of tuxedos with a satin lapel, midnight blue or black tuxedo, white of off-white shirt, studs or no studs, vest or cummerbund.
Make sure to wear a boutonniere with your white bow tie and tailcoat. Traditionally men wear roses and carnations with evening ensembles but other flowers like a cornflower might work as well. The decision what to wear is up to you but you must wear a boutonniere with white tie.
Simply untie your bow tie just like you would untie your shoes. Store it hanging or laying flat, it is up to you.
This bow tie comes in heavy Fort Belvedere box, perfect unadorned for a gift box, storage or travel.
If you have questions or need style advice in choosing a bow tie for yourself or someone else, let us know, we are happy to help.


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Welcome to Ultimate-Motorcycle!
Motorcycle handlebar clamp bolt mounting kit with water resistant Smartphone case from Ultimateaddons. This kit from Ultimateaddons will allow you to mount a wide range of Smartphones securely to your motorcycles handlebars.
Universal One Holder - (Included)
Are you looking for a holder you can mount in the car, transfer to your motorcycle when you go out a run at the weekends? This one holder by Ultimateaddons will support Smartphones with dimensions of Width 50-80mm, Height 120-170mm Depth 5-15mm. The holder also comes with a hand rain cover.
25mm to 3 Prong Adapter - (Included)
3 prong socket plate is designed to allow Ultimateaddons® 3 Prong holders and cases to be connected.
Handlebar Clamp Bolt Attachment - (Included)
The kit is available in 3 sizes M6, M8, M10 size screw and a 1" (25mm) Ball Mount, allowing various holders to be attached. This type of mount is ideal for those who do not want the handlebars of their Motorcycle to be cluttered. Please note that the supplied bolt lengths are approx: 55/60/65mm, once you attach the 1" ball attachment to the screw head the thread length that will go into the handlebars are approx: 27/32/37mm.
Extender - (Optional)
if you want more flexibility with the positioning of the Smartphone or if you want to add extra height ideal if you use a tank bag is select the 3" extender.
Sold Out


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Welcome to The Heather Glen Country House
Set in the heart of the Eden Valley in Cumbria, we are a family run wedding venue & restaurant along with offering private function and accommodation.
Located between Carlisle & Penrith and boasting our own 1/12 acres of English Country side gardens, the Heather Glen is the perfect place to celebrate those special occasions, wether it be a meal with friends or to have the exclusive use of our Country House for your big day the Heather Glen offers the complete package.
We are excited to announce we are extending the Heather Glen and we are currently adding a new function room and accommodation facilities to our Country House This is due to be completed by 1st June
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Heather Glen Country House
Ainstable Village
Carlisle, Cumbria
Tel: 01768 896219


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Design Within Reach
What better place to find cutting-edge works by up-and-coming artists than at the schools that they attend?
ShopSCAD Atlanta; Lacoste, France; Savannah When the Savannah College of Art and Design opened its store in 2003, no one expected it to be so successful that the school would introduce satellite shops at its campuses in Atlanta and Lacoste, France. It certainly keeps director Amy Zurcher busy. "I meet with artists five days a week," she says, "so we always have new things in stock." Some of her best sellers are made by alumni, including Gogo Borgerding's colorful cuff bracelets ($155) and the functional-yet-fun carpet bags that Claire Sanchez sews from vintage fabrics ($65). 340 Bull St., Savannah, 912/525-5180, shopscadonline.com.
GSA Shop Glasgow, Scotland Art nouveau master Charles Rennie Mackintosh, the Glasgow School of Art's most famous alum, would have been proud of the new shop housed in his 1896 building. The space looks like an intimate loft, with the same clean lines that were a benchmark of Mackintosh's work. "It really allows the products we sell to speak for themselves," says assistant manager Annie Murphy. Among her favorites: geometric necklaces crafted from leather and acrylic beads by textile-design graduate Caitlin Urquhart ($105) and fanciful cards embroidered with bright letters and hearts by alumni Betty Fraser Myerscough ($10). 11 Dalhousie St., Glasgow, 011-44/141-353-4526, gsa.ac.uk.
RISD/works Providence With graduates like glass artist Dale Chihuly and former faculty such as Cuisinart creator Marc Harrison, the Rhode Island School of Design has a reputation for innovation. And now, it's got an avant-garde store that does it equal justice: Pritzker Prize–winning architect José Rafael Moneo designed the new Chace Center building using an eclectic mix of acid-etched glass, aluminum, and red brick. "The ultramodern space is a perfect venue for our funky products," says shop director Matthew Johnson. The wares include toys and tees by Family Guy cartoonist Seth MacFarlane (from $32), a RISD grad, and fun kitchen gadgets such as a chopper that dices onions into tiny squares, by former student Sascha Kaposi ($18). 20 N. Main St., Providence, 401/277-4949, risdworks.com.