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Take us for a moment to the tax law of 1986. What was important about that tax law in terms of shelters? ...
Probably the biggest thing it did was reduce the individual marginal rate. But prior to the 1986 act, the sheltering problem -- to the extent there was a problem -- was by individuals. What individuals attracted to tax shelters, even when they were bad economic investments, was the fact that the marginal tax rate was so high. It was up at 50 percent for earned income, and even a little higher for unearned income. ...
But what the 1986 act did was bring the top margin rate down to 28 percent. That was a huge change. So the incentive that people had to go out and invest in bad economic deals -- like coal deals and movie deals and gold mines that they sometimes found out didn't even exist, so they got defrauded -- the incentive to do that kind of stuff went away. ...
So if we move forward about a decade, mid- to late-1990s, what's the situation at this point in terms of the tax field, in terms of accounting, in terms of shelters? What's happened now?
A big change that occurred maybe from the early 1990s on was that the focus of the accounting firms was much more on, "How do we sell products other than our traditional products of auditing and traditional tax services?" Clearly the big accounting firms all moved into tax sheltering activities, and that kind of sheltering activity is very different from what existed pre-1986 act. ...
The sheltering developed in post-1990 and into the middle-1990s was sophisticated financial transactions targeted more at very higher-end wealthy investors, to the extent that they were in the individual side and targeted at corporations -- and they involved much more sophisticated tax planning.
Now part of the problem here is a problem that's existed in the Internal Revenue Code before today and will into the future -- it is complicated. So there will always be areas in which the ability to interpret what the code does to a particular transaction is subject to dispute. One of the reasons we have an IRS who audits big corporations is to examine whether or not the positions taken by corporations are correct.
So the sheltering that occurred in the 1990s, some of it was perfectly legitimate; some of it was more susceptible to challenge. In some cases, the courts have ruled those transactions didn't work.
By "didn't work," you mean weren't legal, were not justified, and therefore the tax benefit was ruled out?
Well, "justified" is kind of a subjective term. What the court said was, under the Internal Revenue Code and the tax laws, this transaction does not produce the result that the taxpayer claimed on the return.
As managing director of Federal Policy Group Clark/Bardes Holdings, Inc., Ken Kies lobbies for the leasing industry. He previously served as the chief of staff of the Senate's Joint Committee on Taxation from 1995 to 1998. In this interview, he explains the intricacies of cross-border leasing deals and why it they are legitimate transaction for companies to engage in outside of the tax benefits. Kies admits some companies will continue to "push the envelope" in finding innovative ways to show significant losses from leasing on their tax returns. However, he maintains that in the aftermath of post-Enron reforms, including the Sarbanes-Oxley bill, the problem of abusive tax shelters is unlikely to return. "I believe there truly is a fundamental change in the attitude of taxpayers about willingness to enter into these kind of transactions," Kies says. This transcript is composed of excerpts from two interviews conducted on Oct. 14 and Nov. 18, 2003.
No tax benefit.
Or the tax benefit wasn't as generous as what was claimed. In other cases, courts looked at situations that the IRS brought to them and said, "No, that is perfectly legitimate, and if policy makers don't like that, then they should go to the Congress and get the law changed. "
On many occasions, the Congress has stepped in and said, "We don't like that answer. We may not have intended it, but it may obviously work, so we're going to change the law and eliminate that tax benefit."
When I was at the Joint Committee on Taxation from 1995 to 1998, the Finance Committee and the Ways and Means Committee agreed to actually change a number of provisions that they considered were inappropriate and to close loopholes that may have existed in the code.
So Congress could take action. But what you have in the climate of the 1990s, when everybody's making a hell of a lot of money -- whether it's corporations or individuals or entrepreneurs or whatever -- the climate is one of aggressive marketing of shelters. Is that what you're saying?
... What the accounting firms did was say, "Well, OK, we're going to play that game. But we're going to try and make it up somewhere else, because we've got to function as an economic unit." So where a lot of them tried to make up the difference, if you will, is by being very aggressive in selling tax sheltering activities.
Now in today's world, that is completely changed, because [of] this passage of Sarbanes-Oxley and the scrutiny by boards of directors and the scrutiny of the SEC. The instances in which corporations are buying tax services from the same firm that audits them is very significantly on the decline, because of a concern about independence. That is, if I'm auditing you, and I'm also selling you tax services, and part of what I'm auditing is the tax provision that you've put on your financial statements, to some extent, I'm auditing what I sold you.
A little bit of a conflict of interest?
It's not a conflict of interest. It's a lack of independence. It's called a concern about independence. Is the auditor exercising independence in assessing whether your financial statements accurately present your financial picture to your investors and to the investing public generally? There it's a concern that there is not independence, if part of what I am auditing is something that I also sold you.
In today's world -- post-Sarbanes-Oxley, post-Enron -- boards of directors are very, very reluctant to even go down that road of taking the risk of buying tax services from the same entity that provides them with their audit. That's one of the reasons that I think we're seeing a decline in the level of tax sheltering activity -- because people are more cautious.
Take me back still to the late 1990s period you were describing. What's your take on the IRS at that point? Are they up to speed? Have they got modern computers, have they got the team, have they got the moxie to keep up with this market that is just exploding in the late 1990s? ...
In the case of dealing with corporate tax sheltering, having the computers is not what really it's about. You're asking a good question, which is, did they have the talent inside the IRS that can go head to head against the talent that the private sector has? [There are] a lot of very smart people in the Internal Revenue Service. Fortunately, there is a pattern of private-sector people going into the IRS at a high levels, and spending three or four years there, and then going back to private practice.
So they are not dependent on just the career people. The career people are some very good people. But it is a tough job every day for the IRS to stay up with what's happening.
Now that's only one part of this picture. The other part of the picture, though, is corporate America generally is not real good at keeping a secret. If corporations have a new fad -- and my own view is today those fads are for the most part gone -- but in the 1990s when you're talking about, there were transactions. One of them was called step-down preferred. It was a transaction that surfaced in the fall of 1996, when I was still at the Joint Committee on Taxation. Within months, we knew about that transaction and had passed and the IRS actually issued a notice. I think it was in March 1997 that shut the deal down cold.
So it had a half-life of about three to six months before the government was well aware of it and was able to take action that essentially stopped the transaction dead in its tracks. Part of the reason goes back to what I said earlier, and that is corporate America is not real good at hiding the ball. ...
[Charles Rossotti] describes a corporate return as big enough to fill half this room. I mean, our individual returns are nothing like that. Finding something in one of these corporate returns, even if you had 15 auditors working steadily, if you don't know what to look for, it's not that easy.
That's true. But that has nothing to do with the computer problems that the IRS had. ... The fact that a tax return is very large really kind of overstates the problem, because the places that the IRS auditors know to look are pretty obvious.
There's a thing called Schedule M that tells you every book-tax difference. Many of the shelters that the IRS ended up pursuing were transactions where there was a difference between the book-tax treatment, that is, how did you report it for financial reporting purposes, and how did it show up on your tax return? There is a schedule where the taxpayer has to list all of those, and that is a beginning point for an audit.
For Fortune 100 companies, the standard practice is that the IRS has a team of auditors at their headquarters pretty much 12 months out of the year, so a continual process of auditing that takes place. So for those taxpayers, the computer problems that the IRS had really were not relevant to their compliance situations or the problems the IRS was dealing with. For those taxpayers, the problem was more the sophistication of the transactions and their ability to understand them and to identify where there might be technical problems with positions take on tax returns.
You mean just not being sharp enough, and not getting what was going on?
That's part of it, but this is where the complexity of the code really is relevant. For U.S. multinationals that are invested in places all over the world, the complexities of our tax system of just how do they calculate their income. Assume for a moment you have a tax director whose only objective is to get it right, which, by the way, is the objective of most of them. Just getting it right is a very difficult thing when you realize all of the complexities that are in our tax system, about how do they calculate the liability associated with investments in a hundred countries around the world and transactions where they're bringing dividends back. We have a complicated tax system in that regard.
The complexity then feeds both confusion and differing interpretations about what is permissible and what's not.
There is no doubt that there are areas in the code where it's gray as to what the law is. The job of a good tax director is to be able to plan his company's transactions to try to minimize their tax liability legally, and if it's in an area where there is gray -- that presents potentially an opportunity for tax savings.
One of the things that was interesting is the difference in income reported by American corporations to Wall Street and the income reported to the IRS for tax purposes. What the Treasury Department says it noticed in the late 1990s was the gap between these two was widening; corporate profits reported to Wall Street were going through the roof, but corporate profits reported to the IRS for income tax purpose were staying flat and even going down, in some cases. Larry Summers, as Treasury secretary, found that alarming, and thought that the integrity of the tax system was at stake. What's your take on what Summers had to say about the problems of the tax system in the late 1990s?
I testified about this issue in front of the Senate Finance Committee. [I] pointed out that there were three very obvious explanations for the divergence between financial statement income, i.e., income reported to Wall Street, versus what was showing up on tax returns, which demonstrated that this was not the least bit surprising.
One was that the growth of markets and the growth in business in the late 1990s for many U.S. corporations was outside the U.S. That's where there were new markets and investment opportunities that created income for them. When they report to Wall Street, they report their worldwide income. For their tax return, they don't have to report the income from their foreign operations until they bring it back to the United States in the form of dividends. That's referred to as deferral. So if they make money in France, if they don't bring it back to the U.S., they can reinvest it in France. They don't have to report that to the Internal Revenue Service until they bring that revenue back.
A second reason for this difference was that there was a significant uptick in capital investment. The economy was doing well, and corporations were making new investments in plant and equipment. The depreciation rules for tax purposes are faster than they are for financial accounting, because financial accounting is conservative. So the taxable income would show up as smaller in the early years. It would show up as larger in the later years, because depreciation is a timing issue. So if I get to take depreciation on the investment I made this year, I get more of it this year. I get less of it later on, and my financial statement, my taxable income, will go up.
The third phenomenon that contributed to this difference was the treatment of stock options. During the 1990s, a lot of stock option income was realized by individuals. That meant that they had to pay a lot of tax on that. But on the corporate side, it gave rise to a deduction for tax purposes. So it will reduce their tax liability, but it was not deductible for financial statement income. There's been a big fight back and forth as to whether that's the right answer or the wrong answer.
But from the standpoint of the Treasury Department, how much money is the Treasury collecting? Having individuals exercise stock options is pretty much a wash, because it results in taxable income to the individual. In some cases, the individual's marginal tax rate was higher than the deduction taken at the corporate level.
The Treasury Department also said that tax sheltering was a major factor in this. Do you disagree with that? Do you think that's exaggerated?
Larry Summers, who I have a lot of respect for, made that assertion. He was never able to substantiate it with real numbers, real analysis. He made some speeches claiming it. He and I actually had some very interesting exchanges over it, but were never able to quantify it. We did actually quantify the three factors that I talked about: foreign investment, depreciation, and stock option exercise. When you looked at those three numbers, they explain a significant amount of the difference between the income being reported for financial statement purposes versus the income being reported for tax purposes.
At the same time, he was talking about that corporate revenues were actually hitting all-time highs in the history of the Internal Revenue Code. So this unsubstantiated assertion that this deviation between financial statement income and taxable income was really offset, if you will, by looking at how much revenue was coming in to the federal government in the form of corporate tax revenues. ...
I think Charles Rossotti's figure on losses to abusive tax shelters was $85 billion, the figure that he quotes over a five- or six- year period here. I think the IRS study by an outsider said it was something like $11 billion to $18 billion a year lost to abusive tax shelters. Do you accept those as rough ballpark figures, or do you think the IRS and Charles Rossotti are exaggerating the problem?
You know, it's kind of a hard question to answer. First off, I have no idea what he was looking at when he said $85 billion. I would point out that many of the transactions he probably was referring to are transactions where the IRS has successfully challenged the treatment and won and taxpayers have had to pay the tax back. So unless you really can like identify what are the transactions that are being referred to and what are the dollars associated with them, it's very hard to make a judgment about that.
Having said that, my view has always been about this issue very simple. There will always be people that will push the envelope, given the complexity of the tax system we have and the benefits of doing that. The real question has always been in my judgment whether the IRS has the tools that it needs to effectively deal with the bad apples -- of which there will always be some in any tax system which has the kind of complexity that ours does.
So the amount of the problem is an interesting thing to throw around. But it's not really terribly relevant to the more important question, that is, does the IRS have the resources that it needs to effectively administer our tax system?
I want to give you a chance to respond to Summers. Summers singled out cross-border leasing or LILOs -- lease-in, lease-out arrangements -- as one of the poster children of the abusive tax shelters.
I'm not sure when Larry singled it out he even knew what the transaction was, and that was back in 1999. I was in a meeting with Larry where he mentioned the transaction. I'd have to say it didn't appear to me that he really even understood what he was describing. ...
They were very complicated transactions. They are heavily negotiated. In each case, they have legal opinions from very reputable law firms. Those transactions very comfortably fit within 30 years of leasing law, tax law that has been developed both through IRS guidance and through the courts. I can assure you Secretary Summers did not understand any of what I just told you -- that these transactions were actually conservatively fit within the leasing tax law that had been around for 30 years. ...
... What is a LILO?
... Let's say you're the German rail system and you own your rail cars. A U.S. party would enter into a transaction in which they leased the rail cars from you, and then turned around and leased them back to you. Now in order for that transaction to work, the initial lease term has to be sufficiently long that the lease back has got to be sufficiently small so that the transaction is recognized as a lease for U.S. tax purposes.
What makes that work? What makes that worthwhile? What does the U.S. investor get out of a transaction like that? ...
What they're what they get is a return on their investment. This is a financing transaction. It's a form of financing. Their leasing is a way to lend money to people.
How do they get money back?
Because they get paid rent.
But the rent they get paid is equivalent to the rent they pay.
That's one of the mistakes the IRS made in 1999 when they issued their first ruling on LILOs. They didn't think there was economic profit in these transactions.
We represent a number of taxpayers who did LILO transactions. We demonstrated in excruciating detail to the Internal Revenue Service that there was economic profit independent of the tax benefits. That's what caused them to withdraw the ruling that they had issued in 1999, which depended on an assertion that the economic profit in the transaction was small or insignificant relative to the tax benefits. In the leasing role, these transactions are actually conservative, compared to your typical leveraged lease. ...
We have talked to a number of German officials. We have been to German cities, whether you're talking Frankfurt, Cologne, Dortmund, Bochum, on up and down the line. Without exception, every single German official or member of the city council we talked to said that they were told by the arrangers and by the American investors that they only way that transaction was financed was by the tax benefit that the American investor got out of it.
The tax benefit is an important part of the transaction. I'm not trying to minimize that. But what I'm telling you is in every single one of the transactions you're describing there is pre-tax profits. That's the way the transactions all work.
How does it work? The American firm is paying. What they're saying is the American firm plunks down 99 years' worth of rent for the lease or whatever the term is. Then most of that money gets put in a bank, which then pays the rent back on behalf of the German party to the American to lease it back. The money is going around, as the IRS says, in a circular flow.
What you're referring to is called defeasance, which is that money is set aside to insure that the rent that's due under the agreement does get paid. That's called minimizing risk, and there's nothing wrong with minimizing risk in a leasing transaction. One of the ways the IRS has tried to attack these transactions [is to] say, "There's no risk in the transaction."
Let me just present a very simple hypothetical. If I lease property to the federal government -- and it happens every single day -- what is the risk of my not being paid? About zero. Does that mean it's not a leasing transaction?
My point about the money as they described it was the American money was going to the German [city] and then was coming back from the German city to the American investor. So how does the American investor make any money?
They make money because they pay for the lease up front. They are getting rental payments that pay them for the use of their equity. In every single one of these transactions, the net return on their investment is significant prior to the tax benefits involved. ...
But [former IRS Chief Counsel] B. John Williams said to us that these are circular money flows; that the money flows out and it flows back. As he puts it, nothing happens.
That's just plain wrong. The U.S. investors have significant equity investments. They are significantly at risk as to the value of the property at the end of the lease term. These are very sophisticated, complicated transactions, where there are appraisals that are done. There are opinions provided by local counsel, but very sophisticated law firms that have practiced in the leasing role for years. We are highly confident if this ever goes to court, that these transactions will stand up, because they fit very comfortably within the rules that have been developed over 30 years as to how leasing tax law applies. ...
Talk for a moment about that leasing industry. [What] is a leasing industry, and how important is it to the American economy?
The leasing industry is huge. In the United States today, there are probably 2,000 companies engaged in the leasing industry. In 2001, $280 billion worth of equipment was placed in service through leasing transactions.
Just to put in context how important that is, for every $1 billion worth of new equipment placed in service, it probably translates into 30,000 new jobs. In the United States, 80 percent of all corporations acquire some or all of their property through leasing transactions. That's how they actually obtain it. Thirty percent of all new equipment that's put in service annually is probably done through a leasing transaction.
So leasing is a huge part of the U.S. economy. That's true of not only the domestic side of that, but also the cross-border part of the leasing industry. In fact, the U.S. companies are the leaders in the world in the leasing industry, and there's a simple reason for that. We have a substantial amount of the world's capital. What leasing transactions really are about is providing capital to users of capital, whether it's Lufthansa Airlines or whether it's the city of Munich or whether it's the company down the street here that needs to get a bunch of new cars because they need to provide them to their delivery people.
If you walked out on the street today and walked up to a user of equipment, whether it's a backhoe or it's an automobile or it's a front-end loader, probably 30 percent of that would be a transaction in which there is a lease involved.
When people use the term "big-ticket leasing," who are they referring to? What are they referring to?
What they're referring to is large transactions. So they're referring to leasing transactions involving power plants, rail cars, airplanes -- large pieces of equipment. That's what big-ticket leasing is about.
Who can afford to do that? Are we talking about big banks? ...
We're talking about entities that have significant supplies of capital that they're looking to deploy, so major financial institutions would all be in this category. I mean, a major bank has a lot of depositors who put money in their bank. The job of the bank is to figure out, "How do we take that capital and invest it in a way that maximizes the return to our shareholders?"
So we're talking about principally large suppliers of capital. Those are the people that have both the sophistication to enter into these transactions, and the capital available to do it. So almost every major financial institution in the United States has a leasing function. A number of major corporations who have a diversified investment profile ... would be in that situation. Another example would be companies that are major manufacturers of equipment, like a Caterpillar, or a Boeing, or GE, or people like that, because they use leasing as one of the techniques by which they are able to export their property to users. ...
I've got to admit to you my own personal confusion. When you talk about leasing the way you just were, the ability of Caterpillar or Boeing or GE to move big expensive equipment, to make big deals whether they make them with the city of Chicago or with Lufthansa, it makes sense. But I have a very hard time understanding why a Wachovia bank would get into a half-a-billion dollar deal to lease the 30-year-old sewer system in the city of Bochum; I mean, absent the tax benefit.
Yes, well, the tax benefits are part of the transaction. There's no doubt about it.
Without the tax benefit, would they get into it?
They might not. ...
So in May 1999, IRS issues regulations against LILOs. What is the leasing industry's response?
Well, they didn't do any more LILO transactions. They moved on and restructured their transactions to recognize that the tax law had changed.
You got to understand every leasing transaction is just a function of four or five key factors: what is the value of the property, what's the cost of money, what's the interest rate, what are the tax rules, and how much risk is involved. Essentially, those factors control what the nature of an leasing transaction would be, and they control what the rent is that will be paid. They control what people are willing to pay for property and so on.
So if you change the tax rules -- because leasing is fundamentally is a real economic activity -- the parties to the transaction will adjust their relationships accordingly. So if Congress wanted to come in and say, "Nobody gets any depreciation on any property," property would still get leased. It would just have a higher cost to the user.
So the leasing industry, because it's a real business and provides lots of capital, will always exist. It's just a question of what rules will they operate under. ...
So the industry moves on, and now you hear people talking about service contracts. ... We begin to hear people talk about service contracts replacing lease-in, lease-out contracts. What is a service contract?
... A service contract is a contract in which I own the property. I provide you with service. If in the case of an airplane, I may provide air transportation services to you.
What the law does is, it looks at that transaction and says, "Is the nature of the contract I have with you one in which I have actually leased you the property," in which case it's treated as a leasing transaction, or, "Is it a transaction which I am providing a service," in which case the leasing rules don't apply. So rules actually developed even before the 1984 act. But the service contract depends on what is the nature of the contractual relationship between the two parties. ...
... The position of people at the IRS is that the service contract is simply a circumvention of the 1999 rules. It replaces the old lease-in, lease-out contract. As somebody said to us, it's the same old wine in new bottles, or it's new window dressing, but the same structure underlying the deal is there.
The first point is people don't put old wine in new bottles, and this transaction doesn't represent that, either. These are different transactions. They have different terms, the economics are different and a different set of rules apply.
So I think what they're really saying to you is when the leasing industry realized that LILO transactions couldn't be done any longer because the regulations were finalized in May, the industry looked at what other ways [they can] structure transactions that make sense for both parties, the investors and the users of the property, whether it's equipment or buildings or whatever. The industry moved in the direction of long-term leases, which are essentially under U.S. tax law treated as purchases followed by a lease and a service contract. Those transactions work because of provisions enacted all the way back in 1984.
The industry moved to something.
The industry evolved, is a way to put it. They aren't doing the same economic transaction and calling it something else. They are doing a different economic transaction, which is governed by a different set of tax rules.
And still picking up a big tax benefit to drive the process?
It's part of the economics, but the economics [in] leasing transactions are essentially simple. There are suppliers of capital, and there are parties that want to use equipment or property. They will frequently structure their arrangements as leases, because that's the way to supply capital. The tax rules will be a factor in determining what is the rental payment and what are the other economics of the transaction.
It almost seems like a cat-and-mouse game. The industry comes up with one scheme and the IRS takes a while to track it down and says "No," and the industry moves on to another one.
It's a weird way, I think, of describing it. But I think a more objective way of describing it would be to say this is an industry with real economics and real suppliers of capital. If you change the tax rules, they will adapt, because there is a big demand for capital out there among parties that don't have it but who have a need to use equipment and capital. If the rules change, then the parties will adapt to that. ...
One of the things that's happened in the Senate Finance Committee last year, a couple of times, was the passage of legislation that sought to make a general rule that business transactions needed to have what was called economic substance, a business purpose -- they couldn't be done for purely tax reasons. Do you think that legislation is a good idea or not?
Where I am on that legislation is where the U.S. Treasury Department is and where a number of tax experts are. That is the consensus view of many -- that this is not good legislation, that the economic substance doctrine, which that legislation purports to codify or put into a statute, is much better off left in the hands of the courts, who have used it appropriately to disqualify transactions where the transaction was heavily motivated, if not exclusively, by tax considerations.
Any attempt to codify that statute would have unintended consequences that far outweigh the benefits of attempting to codify it. The courts have demonstrated that they're very capable of applying the doctrine in ways that are sensible. It's better off left there than any attempt by Congress to try and reduce it to statutory language.
You've said several times in our conversation, if Congress doesn't like the way some of these transactions work out, then what they should do is change the law. Yet now here is an effort by some people in Congress to change the law, and not just case by case, but to try to set a general set of rules so that taxpayers can know. ... The argument is we need to pass a more general rule that will deal with more of these problems across the board instead of dealing with it case by case.
I think the answer to that is simple, and that is that there is far more harm that can be done by passing a generic statute like that than the good that can come from it. The Internal Revenue Code is a set of specific rules that people are supposed to operate within. If you put on top of that some generic statement of the economic substance doctrine, it's going to create a lot of confusion. ...
We really have to have a tax code that's a set of statutes. My view is that there are plenty of ways for the Internal Revenue Service to deal with overly aggressive transactions, and that sometimes Congress does need to come in and legislate specific rule changes. That's the way this situation should be handled, rather than some sort of omnibus broad statute that really would create more confusion than it would do good in terms of the administration of the tax law.
If Congress tries to deal with individual tax shelter problems one by one, how do you avoid adding to the complexity of a tax code, when the complexity itself invites still further efforts to get around the tax code?
You're never going to eliminate the tax code, and there have been a number of instances where the solution to a tax shelter was a very simple legislative change. In the case of the leveraged corporate and life insurance [COLI] problem which we dealt with in 1995 and 1996, the Congress enacted a very simple tax change that shut down those transactions. So it's wrong to assume that solutions to aggressive transactions or loopholes have to be complicated. They don't necessarily have to be. It really depends on the nature.
What is your take on the other provisions of some of the efforts to deal with tax shelters -- increasing penalties on promoters of shelters, requiring disclosure and registration of shelters by law -- and not just by regulation?
Some of those proposals are probably OK, although I would point out to you that those proposals have been around now for three or four years, and they haven't been enacted. But during that same time period, the IRS has very effectively gone out and addressed a lot of the significant corporate tax shelter problems that are out there. The mood of the country, in terms of the willingness to enter into corporate tax shelters that are aggressive, has completely changed as a result of the post-Enron environment, the post-Sarbanes-Oxley.
So I would suggest to you that most of the problems that we saw in the late 1990s with respect to aggressive corporate tax planning is behind us. The [IRS] was actually pretty effective at using the tools they had available to it to go out and address the problem areas that arose, and corporate America is not that good at keeping a secret. As a consequence, the IRS discovers most of these transactions, and actually has been able to deploy its resources pretty well to address them.
I asked Larry Summers and some of the people who work with [him] why some of the proposals that they've put forward three or four years [haven't moved forward]. The response was the effective lobbying of the financial services industry -- very powerful influence with Capitol Hill key committees -- House Ways and Means, Senate Finance.
Everybody always looks for an excuse as to why you didn't accomplish something that you set out to do. I think it really overstates it to suggest that it was just because of effective lobbying. I think a number of thoughtful members of Congress said, "Lets go slow on this." Does the IRS really need more than they already have? The evidence to date is that the answer is probably, for the most part, that the IRS has very effectively under B. John Williams, when he was chief counsel, shut down a lot of corporate tax shelters that probably were inappropriate.
They did it with the powers they had, without the proposals that Secretary Summers had proposed. For the most part, I think, they really brought most of the corporate tax shelter problem under control.
But I want to reemphasize that, in a complicated tax system, there will always be people that are pushing the envelope. That's why we have an Internal Revenue Service, and we don't have a wholly voluntary system with nobody in charge of making sure taxpayers comply. We are always going to have some people out on the edge.
I think today there are less people out on the edge than there probably have been in 20 years. The publicity associated with the aggressive effort by the Internal Revenue Service to go after the offenders, the hearings in the Congress, the concerns about Sarbanes-Oxley, and the attitude within boards of directors of [having] to be much more cautious is better today than it's been in at least 20 years.
A number of people have cited the post-Enron effect in corporate America and the more vigorous efforts by the Treasury and IRS. But I will say Rossotti and a couple of others have said that they expect a new wave of tax sheltering in the corporate world when the economy recovers. Their answer to the decline in corporate interest in tax shelters is really much more economically tied. ...
I just have to say Charles Rossotti is a very bright guy. I think he's just wrong on this point. I would point to the hearings that the Senate held in November 2003, where representatives of at least a couple of the major accounting firms said, "We're out of that business. We're not going back to it. We know the world has changed, and that's not the way in which we're going to about our business." That's point number one.
Point number two, the attitude within boards of directors across America today has changed -- I think changed forever -- because of the concern about the focus that the Sarbanes-Oxley process puts on companies year in and year out. That is not going away, even if profits go back up. So the world has changed, and the problems in the future I think you're going to see are far less than what we witnessed over the past ten years.
So if people like Summers and Rossotti and others say they're worried about the integrity of the American tax system being undermined by a period of aggressive marketing of shelters, you disagree?
I categorically disagree. I would point to the fact that tax administrators from around the world come to the United States every year, because the United States has the highest compliance rate of any tax system in the world. That's true today, it will be true tomorrow, and it will be true 20 years from now. We have a compliance rate that is the envy of the rest of the world.
Do you think any changes are needed by law?
Oh, I think maybe some of the additional penalty provisions, most of the information reporting the IRS is already getting. The one caution I'll just offer you on penalties. If you get penalties too high, you will find that audit agents will not impose them, because they will have a visceral reaction that somehow it's overkill. So some people have a knee-jerk reaction if we just make penalties higher and higher and people will stop doing this stuff.
The penalties now for a promoter that promotes an abusive tax shelter is, like, $1,000, and they're making several hundred thousand dollars per deal.
What's really stopping the promoters from promoting inappropriate transactions is that reporting obligations require them [to] disclose the taxpayers that they're marketing these transactions to. That's what really stops it, because taxpayers who know their name is going to appear on the list of having bought an inappropriate tax shelter, they're not going to enter into the transaction. So my advice is don't get caught up on how high the penalty should be on the promoter. Make sure your reporting system is right and, if it is, you won't have anybody buying the transaction from the promoter.
But you've got e-mails from within accounting firms in which you have high executives saying to each other, "There is no point in our meeting the reporting requirements of the IRS, because even if we get penalized, we're making 100 times as much as we're going to get penalized." The economics say don't report it.
First off, I can assure you the accounting firms that testified in front of the Senate last November are not sending those kind of e-mails and they are not doing that anymore. They are well aware that that kind of behavior was wrong. I am confident that you're going to see people complying with these rules.
But you've got at least one of those accounting firms and two major law firms fighting the IRS, tooth and nail, to resist the court summonses of the IRS to submit them documentation.
You know what? The courts will deal with that. ...
You said that, [in] the testimony last November, accounting firms came forward and showed they had effectively had a change of heart and they were no longer saying [they] were not going to report. I'm saying in response to that one of those major accounting firms which testified last November is fighting the IRS tooth and nail not to turn over records. A couple of major law firms are doing the same thing. Does that look like a change of heart to you?
There may not be, in their particular case. There clearly is a change of heart generally across the industry. There may be a few outliers that are still not with it, but my bet is they're going to get there. But remember, my more fundamental point is on the buyer side. On the taxpayer side, in boardrooms today, there is nobody looking favorably on these kind of aggressive tax shelter transactions.
So my only point was, don't get hung up focusing on the promoter side. The more important side to look at is the buyer side of these transactions. The attitude there is truly changed -- and I believe forever -- because of the scrutiny that Sarbanes-Oxley imposes on the decision making process, and the pressure it puts on boards in terms of their role in approving these kind of transactions.
But prior to that, finding the position taken by the corporations that adopted those shelters was, "We have a legal opinion. This fits comfortably within existing law." It then was declared abusive by the IRS. It was audited and it went to court. So aren't people going to continue to do that?
I think the answer is no, and if you look at what actually happened back then, the world is different today. The legal opinions that they got, if you read them carefully, weren't worth much. The legal opinions were dependent on stipulated or assumed facts that may or may not have actually been part of the real transaction.
What I'm telling you is, in today's world, the boards of these publicly traded companies and the management just have a far different appetite for risk than existed five or 10 years ago. I don't believe the appetite for risk is going to change. But I also said that the reporting and disclosure rules that the IRS imposed, if they need additional penalties to make sure people are complying with them -- my own view is that's fine. But the more important part of this equation is on a taxpayer side, where I believe there truly is a fundamental change in the attitude of taxpayers about willingness to enter into these kind of transactions.
Several people have said to us that many of these shelters are technical tax transactions which arguably follow the letter of the tax rules. But the position taken by some of the people enforcing the tax rules is that these corporations are twisting the tax rules. They're not really following.
In some cases, that may be true. If that's true, then the IRS should challenge them, and they should force taxpayers to defend their positions. It may be up to the courts to make a decision. Once the courts have made a decision, it may be up to Congress to change the law if they don't like the decision of the courts.
But taxpayers have to operate under an Internal Revenue Code that has rules in it, and sometimes people are going to have disagreements about that. There are a lot of areas of the code where the rules are not crystal clear as to which way a transaction gets treated. So that's going to happen.
People say that in the lease-in, lease-out transactions, while you are a leasing industry, your industry was twisting the tax rules of the IRS.
I think the answer to that is clearly wrong. These transactions, by the admission of the IRS had real pretext, economic profit. Indeed, when the IRS gave up on their 1999 ruling and withdrew it, the IRS made that concession so people can make those assertions. But what the IRS did in withdrawing the 1999 rulings is really inconsistent with that. Now the IRS is still challenging the transaction. We may well end up in court. We are highly confident if we go to court, the taxpayers will prevail, because we have 30 years of leasing tax law on our side with respect to these transactions. ...
Some people are saying that protection of some of these tax benefits and their application, either by the industry or by friends and supporters in Congress, is a subtle way of gradually winnowing away the corporate tax; that protection of certain tax transactions is a method of gradually reducing the corporate tax share until it finally disappears.
The only thing I can say to that is Washington is full of people who have Machiavellian theories about why things happen. This is just another example of one that is wrong. If you look at the numbers that just came out of the Congressional Budget Office in January of this year, you'll see the corporate tax revenues are projected to climb over the next five years back over $200 billion.
But as a percentage of the total, they don't begin to compare with what they were say 20, 30 years ago.
Actually, if you look at the level of corporate revenues in the late 1990s as a percentage of GDP, it was the highest that they'd been since 1980 and 1981. Corporate revenues are again climbing. So if the theory is that this was all a carefully well-orchestrated effort to make the corporate revenue so small that everybody would give up and say, "Lets get rid of the corporate tax system," all I can say is that person has a very significant imagination. We're not getting rid of the corporate income tax. It's going to be a significant revenue generator. Given our current deficit situation, the likelihood that we will ever get rid of the corporate income tax under any scenario is about zero.
Editor's note: This portion of the transcript is excerpted from a FRONTLINE interview with Ken Kies at a conference on cross-border leasing in Paris on Oct. 14, 2003.
So it looks like leasing is doing well in Europe right now. ...
It's in the many billion of dollars, I would guess $20 billion, $30 billion, maybe bigger, because the European Community has an economy that is roughly the same size as the U.S. The U.S. economy is about $11 trillion of GDP. The EU, particularly with the new states that are being added or will have been added recently, probably has an economy roughly equivalent to that $11 trillion.
The United States and the EU both have the same problem. People need the equipment, but they don't have the ability to produce it outright. So frequently the way they get it is through the leasing transaction. ...
Who do we get here [at the conference in Paris on cross-border leasing]? Are these the big-ticket leasers? Are these the European cities? Who is represented?
The people represented here are the people who help structure the transactions. They are from all over the world. There are people here from Australia, the United States, Europe. I think that there are people from the Far East. So this is a pretty big conference, and you attract a number of players from all around the world. ...
Money represented here will be the leasing business.
In the U.S., the leasing business [brought in approximately] $216 billion in 2002. It will be probably about the same size, because it is the tool by which all the U.S. manufacturers export property. [With] major manufacturers like Caterpillar, General Electric, the users of their equipment cannot afford to buy. So the way in which they are able to export it is through a leasing transaction where a third party is providing financing. That's why it makes it so important to the U.S. economy, both domestically and internationally. ...
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Medicinal Sweets or I Wish I Had a Sore Throat
Awhile back I shared a post about Candied Tangerines and how delicious they are in the bottom of a cup of tea. But I wanted to make something a bit more medicinal that still had that 'yummy' quality to it. I've been fascinated by herbal anything my whole life. Imagine! The created things on this planet combat disease and infection, promote healing and life and can manage to do it in a gentle, easily accessible way. It's such a perfect system!
Everyone knows that when you have a sore throat, you are supposed to have hot water, lemon and honey. Why? Well the hot water soothes and reduces swelling, while breaking up any lingering congestion in your throat. The lemon will cut through mucus (because of the acidity), kill bacteria, and also help numb tender, sore spots. The honey coats your throat and sweetens up all that acid that's working in the lemon. Honey has been recognized by every culture as having a multitude of healing properties and modern medicine is even starting to research this natural wonder for its curative powers. It is important that you use RAW HONEY, pasteurized honey cannot claim the same health benefits. Come to find out, the Koreans make a medicinal "marmalade" with just fresh lemon and honey. I just had to try this.
I cut up 2 lemons, dropped them in a small mason jar and poured honey over them until it filled up about 1/3 of the jar. You can immediately see the juice from the lemon being drawn out by the honey and the two swirling together. I just made mine, but if I let it sit in the fridge, over the next couple of months the lemon will darken and the mixture will thicken. The peels and pulp will break down as well and leave behind a golden, lumpy marmalade that I can scoop into a cup and poor piping hot water over. Oh, it almost makes me want a sore throat! (To speed up the process, you can also store this in a cool cupboard rather than the fridge.)
Because I enjoy getting the most out of what I make, and I know that there are other medicinal jujus that can help me with a sore throat, I'm going to add a heaping Tablespoon of fresh chopped ginger and let that candy along with the lemon. When the hot water hits that, I can breathe in the steam and get some benefit in my sinuses as the ginger stimulates circulation and will allow me to breathe easier, while at the same time, be soothing to my stomach, which will also be a bit stressed if I'm sick.
I'm excited to try this and I'll be taking some finished product pictures as well to share with you.
After I published this article, I ran across this article on the medicinal powers of honey.

subset: commoncrawl


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If this latest report from Primate Labs is accurate, then customers who snag a fourth-generation iPad on Friday will be pleased with the device's performance. According to a Geekbench result that appeared on Sunday, Apple's latest tablet outperforms all other recent iOS devices, including the iPhone 5.
The iPad (fourth generation) scored a 1,757, which is 10 percent higher than the iPhone 5's 1,571 score and more than twice as fast as the third-generation iPad, which scored 791. The results also show that the iPad 4 has a dual-core Apple A6 processor clocked at 1.4GHz, which is slightly higher than the 1.3GHz of the iPhone 5.
Customers can buy an iPad (fourth generation) starting November 2 at Apple retail stores. The base 16 GB WiFi model with Retina display will cost US$499. Customers can still pre-order an iPad, but the tablet won't ship for another week.


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June 28, 2011 - 7:00pm
After more than a month of flooding in some areas, high water on the Missouri River is not expected to abate anytime soon. With more river crossings being shut down and levees bracing against record levels, emergency officials remain on high alert. Grant Gerlock of NET News spoke with Al Berndt of the Nebraska Emergency Management Agency for an update on flooding across the state.


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When Derek Fisher looks back at the footage of the Lakers' championship parade, he'll see himself and think the same thing he already thought upon first seeing replays of himself the night the championship was won.
"I can see it in my own face," Fisher said. "I'm just really happy."
It's really an interesting way to put it. Our joy comes from within, but the expression of it is far more telling than the feeling itself.
That's what parade day Wednesday was about: the expression of joy.
Yes, Phil Jackson is absolutely right when he says it's about the journey. Each moment exists as its own slice of life.
Nevertheless, rarely does any moment reach as elevated a natural high as this one.
It's similar to the sensation Fisher felt upon watching that footage of his own real smile. He and all the Lakers looked out from atop their bus moving down Figueroa Street and the floor inside the Los Angeles Memorial Coliseum and didn't just see more people in one day than they ever do, they saw all those people smiling because of what they'd done.
The season's long run isn't about those kinds of smiles along the way, even though the Lakers' team-wide camaraderie was entirely healthy except for Vladimir Radmanovic being a little too hard on Sun Yue in the rookie hazing. (Radmanovic's trade to Charlotte fixed that anyway.)
And obviously everyone got peeved with Sasha Vujacic at one point or another.
But eight and a half months ago, Jackson handed out season-planning books to his players, and on the front of each was a big "D," with the message: "DEFENSE = discipline/desire/determination/dedication."
None of those "D" words is meant to start thinking happy thoughts. It's about work and teamwork and then maybe one day sharing off-the-charts joy with your teammates that leaves Fisher unwilling to remove his game uniform, reeking of sweat and champagne both, even back at the Lakers' Orlando hotel for their postgame meal and party.
The common statement is that these Lakers will always share a bond as champions, which isn't entirely true.
It only took two years after the Miami Heat's first championship in franchise history for Shaquille O'Neal to be traded and for him to e-mail to friends a Photoshop-created image of Dwyane Wade's face on a woman's body.
But it does last in many cases. It's why Robert Horry stops by the Lakers' locker room after a game this season in Houston, and Kobe Bryant says to Horry's son: "You know your dad was one of the most clutch players of all time, right?"
Fisher is the latest in that line because of those two 3-pointers in Game 4 in Orlando, even though the record shows that Fisher's 28.4 percent success rate on 3-point shots in the postseason was the worst on the entire team.
For all the respect he always had from his teammates, Fisher told them during his slump: "I can't just be a leader of the choir; I have to be a member also."
His teammates held him up at times, and he wound up lifting them all the way to that upper bowl of the Coliseum on Wednesday afternoon, descending to the field like royalty joining the commoners.
It was a day for everyone to wish/beg/demand that free agents Trevor Ariza and Lamar Odom get re-signed, and for Bryant to laugh at Stu Lantz's query about being able to opt out of his contract and say: "This is my home. Where am I gonna go?"
It was a day for many other Lakers to grab the mic and try way, way too hard to rev the crowd up rather than speak some substance, but in the end that mattered little.
It was not a day of complex emotion. It was joy, even for those distanced from the festivities and watching on TV.
Some day, Fisher will re-watch the parade on TV. When it's over, he'll turn the set off, and he'll see himself in that blank reflection of the screen.
There it will be again: the smile on his face that reminds him just how happy he was.
He'll again see that real smile on his own face.


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IT WAS AFTER THE SHAMPOO and scissors
that she asked me.
After the mousse and blow-drying,
after the chair was lowered
after I paid,
just when I thought I was free and clear.
That's when she asks.
"How's the writing going?"
And I was doing such a good job
keeping the conversation on her,
arriving prepared
with an endless stream of questions
about things in her life,
things I AM interested in
almost as much
as I am interested in NOT talking about me.
But she hands me a mirror
and spins me around
and I say I'm delighted
and she says she's delighted, too,
and I thank her
and pay
and thank her again
and am almost out the door
when she says the words.
"How's the writing going?"
Almost made it.
And now there it is, hanging out there.
* * *
a dozen possible responses –
LIES all,
but she won't know –
"going great'
"comin' right along"
or even
"hardly any time right now,
what with estate matters to tend to" –
I fall back on my propensity for the truth,
a leaning for which I have been faulted
(but not in the last two months)
and think of the stack of pages
I take almost everywhere with me,
the white binder
I take out in the morning
and put away again in the evening,
the pages I keep fumbling back-and-forth through,
making little notes,
nothing more.
How is the writing going? she wants to know.
"It's not."
I add
something about
being in a period of mourning
and transition
and dust-not-yet-settling and all….
"you know how it is"
as if showing a hall pass to the vice-principal.
She nods.
I flee
just as slowly and as quickly as I can.
* * *
IN THE SAFETY of MY CAR
I check my hair in the mirror
and catch a glimpse
of the white binder
on the passenger's seat,
NOT seat-belted in –
it's very life in jeopardy.
I find a theme list waiting for me,
the annual chance
to say
yes I have something to say
and will write for you.
I can't believe they have kept me on the mailing list.
Maybe they know about writers,
how silences punctuate the landscape
and never to rule out any writer
like cicadas
they return
to make a big noise again
…just about the time you'd forgotten they existed.
How's the writing going?
It's not.
Not today.
But maybe tomorrow.


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I gotta admit that the Stepbrothers trailer made me chuckle even though you can see the jokes coming from a mile away. Maybe it's because I can imagine Beatty and I playing the lead roles. And Big John knows which of the brothers that I'd be.
Before you watch, please know this is the mature audiences trailer. If you're offended by profanity or stupidity, then don't click it.


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Model Type
21 Combined MPG (18 city / 27 hwy)
EPA estimated
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Controlled, compliant ride; quiet as a tomb; high-class interior even in base form.
Less trunk space than rivals; some iPod functionality issues.
Leather, wood and chrome do not make a luxury car. Neither does a surly musician from Michigan talking about luxury in a Super Bowl commercial. No, it's the way a car's suspension absorbs the blows from gnarled pavement and its engine's ability to push you into the back of your seat. It's the interior hush that lets you appreciate the premium sound system. It's the sheer presence that makes a car stand out in a crowded parking lot.
The 2011 Chrysler 300 is not a luxury car just because the marketing department says so; it rightly deserves the title. Even in its base trim with cloth seats and a V6 engine, the newly revised 300 sedan delivers the sort of premium driving experience that its predecessor never did and that other full-size sedans do not achieve. While the new car shares its platform and general look with the 300 that came before, the 2011 Chrysler 300 has been overhauled to such a degree that the term "new" is certainly warranted.
The structure has been stiffened and the suspension retuned to provide the sort of buttoned-down, compliant ride one could compare to a Mercedes-Benz. The old pair of inefficient and insufficient V6s has been replaced by a single 3.6-liter V6 that bests them both in power and fuel economy. Inside the cabin, an abundance of acoustic insulation and soft-touch materials dramatically improve the cabin's look and ambiance, while ice-blue lighting and silver-accented gauges add a dash of cool. Add in a generous features list and it's easy to forget that you're driving the cheapest 2011 Chrysler 300 available. Just imagine what it would be like with leather and extra chrome.
"Hey, that thing got a Hemi?" was the question posed by an old Chrysler marketing campaign. With the old Chrysler 300, buying a V6 model meant you'd have to sheepishly answer "No, a V6" and slowly walk away in shame. While we still wholeheartedly endorse the purchase of the 363-horsepower, Hemi V8-powered 300C, buying the 300 V6 is no longer something to hide from the neighbors.
This new 3.6-liter Pentastar V6 sends 292 hp and 260 pound-feet of torque to the rear wheels through a five-speed automatic transmission. That's good enough for a run to 60 mph from a standstill in 7.1 seconds, more than sufficient for spirited highway passing. The 300 will even smoke the rear tires if you get creative, though you're more likely to note its EPA rating of 21 mpg combined. Even more important might be the smooth new V6's refinement, enhanced by the way the 300's ample sound insulation further quells engine noise to a distant thrum.
Regardless of which engine you choose, it's the new 300 sedan's handling and ride that truly impress. There is ample body roll through turns, but like a big Mercedes sedan, the 300 remains controlled and predictable. The steering is perfectly weighted for this type of car, perhaps because Chrysler has resisted the temptation to make the level of electrically controlled assist overly variable with speed, so the effort level doesn't unnaturally progress from loosey-goosey to firm as speeds rise. The new 300 steers like a real car rather than a video game.
The ride is similarly well sorted. The pavement on Wilshire Boulevard in L.A. looks like a bombing range, and yet the new 300 seems to bulldoze it smooth, gracefully delivering a sophisticated, perfectly damped ride with the aplomb of the best German luxury sedans. There is, however, quite a caveat here. Our base-model 2011 Chrysler 300 came equipped with the standard 17-inch wheels and the generous, pliable 65-series tire sidewalls that go with them. The 18-inch wheels and 60-series tires of the next trim level probably won't adversely affect the ride, but we can't say the same thing about the 19s, 20s or even larger dubs that will no doubt befall 300s everywhere. (DUB subscribers, you have been warned.)
With a car the size of the 300, it shouldn't come as a surprise that there's ample room in every dimension aboard for occupants big and small. The adjustability of the driver seat and tilt-and-telescoping steering wheel is particularly impressive. If there is a flaw, it's the tall center tunnel needed for the driveshaft required in this rear-wheel-drive car; if rear-seat space is a priority, a front-wheel-drive car might be a better choice.
Once you've sunk into the soft confines of the supportive seats, you're likely to notice the distinct sound of...absolutely nothing. According to our sound meters, the cabin of the 2011 Chrysler 300 is just as quiet as that of a Bentley Mulsanne, which is only slightly less hushed than the surface of the moon. The 300 is definitely one of those cars where keeping a close eye on the speedometer is important, since you don't have the usual telltale wind and road noise.
Every 2011 Chrysler 300 comes standard with a large, central touchscreen interface regardless of whether you spring for the Garmin-sourced integrated navigation system. Largely devoted to the control of the surprisingly strong standard audio system, the touchscreen's graphics look crisp and modern, clutter has been kept to a minimum and icon buttons are large enough to find at a glance. It's almost the exact opposite of the new MyFord Touch system.
Curiously, however, "Playlist" is not one of the menu items within the optional iPod interface. Chrysler says it will be added in the future, but this is irritating and puzzling given that previous Chrysler iPod interfaces had this common menu item. (UPDATE: Chrysler is now offering a software update for those whose 300 lacks this particular functionality.)
Another area of minor concern is the trunk. Its opening and rearmost portion is plenty wide to swallow golf clubs, but the wheelwells intrude as you move forward. The resulting 16.3 cubic feet is still pretty large, but pales in comparison to the enormous trunk of the Ford Taurus. Really, though, if these are our principal areas of concern, the 300 is in pretty good shape.
The 2011 Chrysler 300 looks awfully similar to the car it replaces, but its designers have smoothed out its edges, added some panache to its light clusters and replaced the old egg-crate grille with bold, contoured chrome bars. It's a classy look that comes through even on the base car. More practically, the designers also added 3 inches of rake to the windshield, which not only streamlines the appearance but also seems to improve forward visibility as well. The new 300 has less of the feel of a gun emplacement to it when you're behind the wheel. Rear three-quarter visibility is still hampered by the large C-pillars, but this is increasingly common among large sedans and it's hard to sternly criticize the 300 for it.
The interior has undergone a more radical transformation. The old car's center stack looked like a desktop computer tower. And the cheesy gauges lit up like a Timex Indiglo wristwatch, the various switchgear felt brittle to the touch and the many interior surfaces were either hard or had a low-grade sheen. No matter your trim level, it didn't feel like a luxury car. In contrast, the new 300 looks good and is made well, too. Soft-touch surfaces nicely extend all the way to where the driver's leg contacts the center stack, while even the diamond-quilted cloth upholstery feels nice (we wonder if its light color will easily stain, however). We also appreciate Chrysler's decision to use brushed aluminum trim rather than chrome, which negates the nasty reflections you get in other luxury sedans.
So the 2011 Chrysler 300 possesses all the ingredients of a proper luxury car regardless of price or trim level. It's no longer a car you buy just for the Hemi or because it looks fly with 22-inch wheels. Of course, luxury cars in this price range are typically compact sport sedans that obviously provide an entirely different sort of driving experience. In this way, we can draw parallels between the Chrysler 300 and the Hyundai Genesis, a similarly priced rear-drive large sedan with ample features, a high-class cabin and a pair of stout engines. They also have badges that people don't associate with luxury (Hyundai not yet; Chrysler not any more).
There are also sedans like the Buick LaCrosse, Ford Taurus and Nissan Maxima, while the 2011 Dodge Charger is closely related to the 300, but sportier. Yet for those looking for a classic American luxury sedan with ample power, a superb ride, a spacious cabin and strong value, the 2011 Chrysler 300 is almost the definitive choice.
Others To Consider Buick LaCrosse, Ford Taurus, Hyundai Genesis, Nissan Maxima.
The manufacturer provided Edmunds this vehicle for the purposes of evaluation.
Used 2011 Chrysler 300 listings and inventory: Shop Edmunds' used car, SUV, and truck listings of over 6 million pre-owned vehicles to find a cheap used and certified pre-owned (CPO) 2011 Chrysler 300s for sale near Ashburn VA. There are currently 674 used and CPO 2011 300s listed for sale in your area, with list prices as low as 11,977 and mileage as low as 26,643. Simply research the type of used car, SUV, or truck you're interested in and then select a vehicle from our massive database to find cheap pre-owned vehicles for sale near you. Once you have identified a used vehicle you're interested in, check the Carfax and Autocheck vehicle history reports, read dealer reviews, and find out what other owners paid for the used 2011 Chrysler 300. Then select Edmunds' special offers, perks, deals, and incentives to contact the dealer of your choice and save up to 300 on a used or CPO 2011 300 available from one of 2,641 dealerships in your area.
What's a good price on a used 2011 Chrysler 300 ?
Save up to $300 on one of 11 used 2011 Chrysler 300s for sale at dealerships within 25 miles of Ashburn, Virginia with prices as low as $11977 as of Mar 24, 2018, based on data from 10 dealers and 1 consumer-driven dealer ratings ranging from 1 to 1 out of 5 stars.
Price comparisons for used 2011 Chrysler 300 trim styles:
The used 2011 Chrysler 300 Base is priced around $22625 with average odometer reading of 63837 miles.
The used 2011 Chrysler 300 C is priced around $15993 with average odometer reading of 82678 miles.
The used 2011 Chrysler 300 Limited is priced around $14230 with average odometer reading of 78448 miles.
Shop with Edmunds for perks and special offers on used cars, trucks, and SUVs near Ashburn, Virginia. Doing so could save you hundreds or thousands of dollars. Edmunds also provides consumer-driven dealership sales and service reviews to help you make informed decisions about what cars to buy and where to buy them.
What options are available on the 2011 Chrysler 300?
Available Chrysler 300 2011 Submodel Types: Sedan, SRT-8, SRT8
Available Chrysler 300 2011 Trims: Touring, S, Touring L, C Platinum, C HEMI, LX, C John Varvatos, Limited, S V6, C Luxury Series, Alloy, S V8, SRT-8, SRT8, C, Anniversary Package, C John Varvatos Luxury, Base, Limited Fleet
Exterior Colors: Gloss Black, Bright White Clear Coat, Granite Crystal Metallic Clear Coat, Billet Silver Metallic Clear Coat, Velvet Red Pearl Coat, Maximum Steel Metallic Clear Coat, Ceramic Grey Clear Coat, Jazz Blue Pearl Coat, Cool Vanilla Clearcoat, Phantom Black Tri-Coat Pearl, Inferno Red Crystal Pearlcoat, Deep Cherry Red Crystal Pearl Coat, Bright White Clearcoat, Linen Gold Metallic Pearlcoat, Green Metallic Clear Coat, Midnight Blue Pearlcoat, Satin Jade Pearlcoat, Magnesium Pearlcoat, Ocean Blue Metallic Clear Coat, Silver Steel Metallic Clearcoat, Ceramic Blue Clear Coat, Dark Titanium Metallic Clearcoat, Redline 3 Coat Pearl, Tungsten Metallic Clearcoat, Brilliant Black Crystal Pearlcoat, Clearwater Blue Pearlcoat, Ivory Tri-Coat Pearl, Light Sandstone Metallic Clearcoat, Luxury Brown Pearlcoat, Pewter Grey Pearl Coat, Stone White Clearcoat (Fleet), Billet Metallic Clearcoat, Blackberry Pearlcoat, Bright Silver Metallic Clearcoat, Butane Blue Pearlcoat, Deep Cherry Red Crystal Pearlcoat, Deep Lava Red Pearlcoat, Deep Water Blue Pearlcoat, Glacier Blue Pearl Coat, Luxury Brown Pearl Coat, Marine Blue Pearlcoat, Mineral Gray Metallic Clearcoat, Steel Blue Metallic Clearcoat, Stone White Clearcoat
Interior Colors: Black leather, Black cloth, Black/Linen leather, Dark Slate Gray/Light Graystone premium cloth, Dark Slate Gray premium cloth, Dark Slate Gray/Light Slate Gray premium cloth, Black/Light Frost Beige leather, Dark Frost Beige/Light Frost Beige premium leather, Dark Khaki/Light Graystone premium cloth, Dark Slate Gray/Medium Slate Gray, Dark Slate Gray/Light Graystone, Black premium leather, Black/Pewter premium leather, Deep Mocha leather, Black/Caramel leather, Black/Linen cloth, Dark Frost Beige/Light Frost Beige leather, Black/Ambassador Blue leather, Black/Pearl Premium Leather premium leather, Black/Red leather, Deep Jade/Light Graystone, Deep Jade/Light Graystone leather, Indigo/Linen premium leather, Mochachino premium leather, Black leather/suede, Black leather/sueded microfiber, Black premium leather/alcantara, Dark Khaki/Light Graystone leather, Dark Slate Gray/Light Graystone leather, Black premium cloth, Black/Light Frost Beige premium cloth, Black/Light Frost Beige premium leather, Black/Pearl leather, Black/Radar Red leather, Black/Smoke leather
Popular Features: Mobile Internet, Keyless Entry/Start, Apple Carplay/Android Auto, AWD/4WD, Upgraded Stereo, Lane Departure Warning, Pre-collision safety system, Audio and cruise controls on steering wheel, Auto Climate Control, Automatic Emergency Braking, Aux Audio Inputs, Fold Flat Rear Seats, Multi-Zone Climate Control, Post-collision safety system, Power Driver Seat, Rear Bench Seats, Stability Control, Tire Pressure Warning, Trip Computer, USB Inputs, Upgraded Engine, Alarm, Back-up camera, Bluetooth, Heated seats, Leather Seats, Remote Start, Navigation, Adaptive Cruise Control, Blind Spot Monitoring, Electronic Folding Mirrors, Parking sensors, Upgraded Headlights, Cooled Seats, Rear Entertainment System, Sunroof/Moonroof
Engine/Mechanics: 8, 6 cylinders
Transmission: AUTOMATIC
Fuel Types: premium unleaded (recommended), premium unleaded (required), regular unleaded, flex-fuel (unleaded/E85)
Drivetrains: all wheel drive, rear wheel drive
used 2011 Chrysler 300 Overview
The used 2011 Chrysler 300 is offered in the following submodels: Sedan. Available styles include Limited 4dr Sedan (3.6L 6cyl 5A), 4dr Sedan (3.6L 6cyl 5A), and C 4dr Sedan (5.7L 8cyl 5A). Pre-owned 300 models are available with a 0-liter flex-fuel (FFV) engine or a 0-liter gas engine, with output up to 0 hp, depending on engine type. The used 2011 300 comes with rear wheel drive. Available transmissions include: 5-speed shiftable automatic.
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tag:blogger.com,1999:blog-953397841255562532.post4383075944076233492..comments2013-05-31T12:51:36.589+01:00Comments on G4ILO's Blog: Useful RFIJulian Mosshttps://email@example.com:blogger.com,1999:blog-953397841255562532.post-52982652142850808432010-12-23T22:33:52.893+00:002010-12-23T22:33:52.893+00:00I have been there before. Fortunately now I live f...I have been there before. Fortunately now I live far out in the country. My nearest neighbors are more than 100 yards away. The noise on the road is rarely audible inside and never lasts long. But previous times had me wishing for a 5 inch deck gun (like the submarines of old had) with an impressive tracking/targeting system. Just lights on is not enough to truly get their attention.
73 and Merry Christmas.Chiphttps://email@example.com:blogger.com,1999:blog-953397841255562532.post-78774910531535189092010-12-19T18:33:50.727+00:002010-12-19T18:33:50.727+00:00Huh - Kids today ! we;ve all been there done it go...Huh - Kids today ! we;ve all been there done it got the T-shirt - hopefully they'll grow up...!? At my previous QTH a key-up set off two adjoining alarms Grrrr no Dx ing.G4NKXhttps://email@example.com:blogger.com,1999:blog-953397841255562532.post-13724682044945631922010-12-19T14:07:24.486+00:002010-12-19T14:07:24.486+00:00Great story! Especially if the tide came in and th...Great story! Especially if the tide came in and they could not start the car to drive it to dry land!!Julianhttps://email@example.com:blogger.com,1999:blog-953397841255562532.post-27745824093289181882010-12-19T13:58:17.217+00:002010-12-19T13:58:17.217+00:00Last Summer we were spending a nice and calm eveni...Last Summer we were spending a nice and calm evening at the lake shore. Then suddenly car full of young boys appeared and they decided to test their car audio. I can't find the right words how f#^#g loud music they were playing. We could barely stand maybe 10 minutes or so and were going to leave and then music suddenly stopped and then some of them screamed: BATTERY!!!! I told you that it won't last long you Idiot!
Oh man that was FUN!!!!!zLY2SShttps://email@example.com:blogger.com,1999:blog-953397841255562532.post-21006326132147224852010-12-19T13:23:28.310+00:002010-12-19T13:23:28.310+00:00Good one Julian, better get to bed early this even...Good one Julian, better get to bed early this evening and get some sleep (or take a nap today of course). The neighbours can be gratefull to you if any of them knew there's a HAM radio op between them ;-)
73, BasPE4BAS, Bashttps://firstname.lastname@example.com:blogger.com,1999:blog-953397841255562532.post-51606511777087046222010-12-19T10:40:32.714+00:002010-12-19T10:40:32.714+00:00Hello Julian, but you didn't? I mean WSPR? My ...Hello Julian, but you didn't? I mean WSPR? My latest experiences on 80 with WSPR is that best DX is around midnight. After 1.00 UTC the DX dropped down. I like the story of your remote neighbors security lights. Hi. In a situation like this it can be very handy. I wish you and Olga a Merry Christmas and Happy New Year. (We are off for holidays just after X-mas and we'll be back January 3) 73 PaulPaul - PC4Thttps://email@example.com


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Showing Suppliers 1 - 4 of 4
Charles Ross and Son Company
Address: 710 Old Willets Path, Hauppauge, NY
Business Type: Manufacturer
Description: For over 168 years Ross Mixers and Blenders have been used in the process Industries to manufacture adhesives, chemicals, cosmetics, coatings, food products, pharmaceuticals, plastics and more. Their mixers, blenders, dryers and dispersers are recognized worldwide as the standard of excellence,... (more)
Chemicolloid Laboratories, Inc.
Address: PO Box 14094, Hauppauge, NY
Business Type: Manufacturer
E.T. Oakes Corporation
Address: 686 Old Willets Path, Hauppauge, NY
Business Type: Manufacturer
Keith Machinery Corporation
Address: 34 Gear Avenue, Lindenhurst, NY
Business Type: Manufacturer, Service


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Chesapeake - Residential Communications Technician
Residential Communications Technician| $50-$80k
- No Experience
- Highest Industry Pay
- Company Sponsored Certifications (Up to $5000 value)
We are Custom Communications Inc., the largest sub-contractor serving satellite TV and LTE for the Home operating across the southeast and into the northeast. We partner with industry leaders in subscriber based communications to perform residential installations, service and repairs for digital TV & Internet customers, and perform cell phone repairs for the largest insurer of mobile devices.
Through service agreements & equipment investments we deliver more work and inventory to our talented force of Residential Communications Technicians. Our Technicians are Owner Operated, Independent Contractors that rely on our ability to deliver consistent, high paying work.
**We out perform and out-pay every other contractor in the industry, period.
Top performers can break $100,000 annually performing:
- Satellite Video
- Satellite Internet
- Video/Audio Installations
- In Home Sales – yes technicians add sales to existing customers!
- 4G LTE to the Home
- Cell Phone Repair
What it takes to be successful:
Profitable technicians chase the work.
- 2-4 work orders per day
- 5-6 days per week in ALL weather conditions
- Regular weekends, share holidays
This is not for everybody…
While anyone can do this, it may not be for you. As a technician expect:
- Driving – driving, and more driving.
- Heights – must be able to climb ladders, rooftops, peaks...
- How about small attics in August? It can be stifling hot, and hard to breathe.
- What about in a crawl space mid-winter?
- You will work – At any point you may be digging, shoveling, carrying, climbing, drilling, kneeling; crawling…
We'll Help You:
- Find affordable contractors insurance
- Pair you with a Senior Contractor to Ride Along gain experience
- We'll order and pay for your required background investigations – each provider is different!
Must Haves:
- White Van or Truck
- Clean Criminal History, Clean Driving Record, Pass a Drug Screen
- Be 18 or over and able to legally sign a contract
**Should you google us, please verify you are viewing CCI of Garner, NC – there are others out there with similar names!
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2: Nope, they were just created with the universe, they are the caretakers of it, not the creators of everything. They remade worlds, but they did not make them in the first place.
3: No, imprisoned. And this was with all the titans and their minions working together in a massive war did they manage to finally bind them, and with great losses for the Titans. The Titans nearly lost too, but what turned the tide was they shattered the bonds between the mortal realm and the elemental plain, imprisoning the Elementals. And Sargeras is 1 titan, and a lesser one at that. The shattering of Gorshalach made Sargeras lose most of his power, now his main power is in the Legion which would still be crushed by the Old Gods alone, much less with their servants.


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SOMERS, N.Y. -- The Westchester County judge who sentenced Somers murderer Terry Losicco to 27 1/3 years to life in prison died Thursday, according to a recent report.
Judge Angelo Ingrassia, 89, died Thursday just days before his 90th birthday, according to reports from The Daily Freeman and The Journal News .The Middletown resident served as a judge for Orange, Dutchess, Putnam, Westchester and Rockland counties until 1999, according to the reports.
Ingrassia sentenced Losicco, who was 16 at the time of the crime, and fellow Lincoln Hall resident David Hollis in the 1980 murder of Somers resident Eleanor Prouty .
The two broke into the home of Eleanor and Norman Prouty, where they expected to find a large sum of money. Eleanor Prouty, 67, was beaten to death and sodomized. Norman Prouty, who used a wheelchair because of multiple sclerosis, was badly beaten and survived but lived the rest of his life in a nursing home.
Losicco reportedly was scheduled to go before the New York State Parole Board this week . The board has yet to announce its decision, which is expected within the next two days. Hollis was granted parole in 2010.
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26 March 2011 17:30
Systemschriften OS Xby 84GHz (via)
List of typefaces included with Mac OS X - Wikipedia, the free encyclopedia
1 (1 marks)
Founded in late 2003 and heartquartered in France, we are non-profit and independant.
We believe in the open web, think internet services should be sustainable, build for the long term.
While we are re-launching the service, we only accept new members through invitation.
last mark : 26/03/2011 17:36


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Airplanes of the Past Highlights
We've been fascinated with both military airplanes and commercial airliners for decades, and still are today.
This site is a tribute to the great aircraft of the past, and to those who designed, built, flew, and serviced them.
We also respect the efforts and sacrifices of the military officers and airmen in restoring peace through victory in World War II, and the job they performed in maintaining the peace during the Cold War.
Shown below is a quick YouTube video showing some highlights from the website ... turn up your volume, and enjoy!
Thanks for taking time to visit the website, and fly again with us soon!


text: So, it was an awards show. Ricky Gervais did a fine job, but these shows are what they are. It's been awhile since I've seen an awards show that rose above the format. I mean, we're talking stretching back to Billy Crystal's first go at the Oscars. This Golden Globes show had some really strange moments, almost more like interludes, where the Hollywood Foreign Press Association wanted to show its worldliness. As for some of the awards, I was very excited for Jessica Lange's well-deserved award for "American Horror Story," and Claire Danes and "Homeland" got well-deserved kudos. I also was happy to see wins for "Downton Abbey" and Peter Dinklage for "Game of Thrones." Kelsey Grammer ("Boss") beating out Damien Lewis and Bryan Cranston? Well, I guess the HFPA owed him one for all those "Frasier" nominations.


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363x500 Buttermere Composite 1.0 Bowl U/mount Super White
This product is available to buy in our showrooms as part of your kitchen package
kitchen showroom
Enter your town or post code below.
Or see all showrooms
The Buttermere undermount sink is an ideal option for those with large or small kitchens, a perfect compact solution or a handy secondary work station. Perfect for solid surface work tops and those looking for a sleek minimalist look in their kitchen
Finish: Super White
Pack specification:inc chrome basket strainer waste and overflow
Compatible with sink pop-up waste:Yes
Minimum cabinet size required:600mm
Main bowl size:436x295x178mm
Overall size:500x363mm
Cut-out size:500x363mm
Template Supplied - Yes
Inset/Undermount - Undermount
Manufacturer part no:AQU10WWWRENSK
Weight (kg):9.02
|Product Code


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Experience the afterlife in this lyrical, paranormal debut novel that will send your heart soaring.When Elliot finds herself dead for the third time, she knows she must have messed up, big-time. She doesn't remember how she landed in the afterlife again, but she knows this is her last chance to get things right. Elliot just wants to move on, but first she will be forced to face her past and delve into the painful memories she'd rather keep buried. Memories of people she's hurt, people she's betrayed…and people she's killed. As she pieces together the secrets and mistakes of her past, Elliot must find a way to earn the forgiveness of the person she's hurt most, and reveal the truth about herself to the two boys she loves...even if it means losing them both forever.
Going into this book I was a bit worry, because i didn't know how things would turn out. I had read a few afterlife books that left me confused and uninterested after a few pages BUT OH.MY.GOD!!! This is one of THE best afterlife books i have EVER READ SO FAR!!! [my reaction is below @ finding this great read!]
My Thought's (Lisseth):
Yeah this AMAZING book has no trailer T_T BUT i picked this one; BLUE JEANS by Lana Del Rey because it has a late/ water & the lyrics go so WELL with the book. PLUS one lyric, "I'll love you till the end of time" ;D
Book-Video Match UP:
What do you think? LEAVE A Comment & u could win the DIVINERS!-Comment Contest.


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Cubby's Chicago Beef
I learned a valuable lesson growing up in Omaha, Nebraska as a young adolescent. One of my fondest memories of Omaha was Austin's Steakhouse. There was a huge cow head right by the highway outside the restaurant. I remember thinking that if a place had a huge cow head sign by their restaurant, then that meant they probably knew how to prepare cow meat just right. That was also where I fell in love with BBQ ribs. Why am I telling you this? Check out the cow underneath the Cubby's sign! I made the instant connection to back when I was a kid. So now everyone knows how to lure me into a restaurant, just put a picture of a cow in front of your place.
Now before I get into my Cubby's review, which was spectacular by the way. We were turning right onto State St from University Parkway, which is where you need to go if you are going to Cubby's from I-15. Well we drove by this dancing Spiderman advertising Dickey's BBQ on the side of the road. This is for your enjoyment.
I loved the menu. It was huge and drawn in chalk. They even had little tidbits about what type of beef they use. Yes, there was yet another big picture of a cow on the inside. There were so many things that I would have ordered on the menu. I feel I could come here 7-8 times, order something different, and be happy with my order every time. Everything looked so good.
I went with the Rip City Tri-Tip Steak Sandwich. The steak in this sandwich is what really made the sandwich. You could tell it was cooked up just right. The meat was tender and juicy. The sauce choices that Cubby's offers were perfect. I ordered one and my co-worker ordered one. We both chose different sauces. Both were satisfying. There were even little chopped up pieces of bacon in there too.
Another item we went with were the fries. Right when we walked in there was a dude sitting down with this giant size bowl with wax paper lining the bottom of it. It was filled to the brim with fries doused in buffalo and blue cheese sauce. I like blue cheese to a certain degree, I don't like it when it overbearing, but these fries were seasoned just right. They were so good, even when it was time to go, and I was so full I was going to burst at the seams, it pained me to leave even one fry behind.
Of course no Food Radar meal would be complete without snagging some delights for the road!
Conclusion – Cubby's is some of the best food in Provo. It had that feel to it, that it was really becoming one of those classic hangouts that everyone knows about. They were even in the process of expanding their dining room which is a sign of a place on the up and up and not on the way out. Finally I would have to agree with the sign on the door on the way back from the restrooms.
3 CommentsLeave a Comment
Randall Bohn / Nov 2 2012 9:11 am
Looks great! Plus, they take WingCash.
Bobby Schenkel / Jan 9 2013 11:26 pm
i really love the taste of beef, it is so yummy that most of the time my dish have beef in it.;
Please do inspect this useful web blog
<a href=" http://www.foodsupplemendigest.com/bcaa-benefits/ "


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Managers comments (Cardiff v Wolves)
Cardiff City manager had apparently forgotten how to give post-win matchday comments after seeing his side end their 13 game winless streak by defeating Wolves 2-1.
Instead Jones decided to focus on the lack of amosphere in the Molineux ground as away fans were banned for the encounter, and the injury to Cardiff skipper Darrne Purse.
'We chose not to accept any hospitality at all, so our chairman Peter Ridsdale sat in the dug-out with us and he banged his head on the roof when we scored.'
'In all my time when I was manager of Wolves and bringing opposition teams to Molineux I have never felt an atmosphere like it, it was dead.'
'But we got our just rewards for our fans.'
Jones showed obvious concern for his influential skipper who was replaced by Roger Johnson before half time:
'Losing Darren is a big blow because he is an experienced player and the one who keeps what is a young defensive line together.'
'He has damaged discs in his back and it's too early to say how serious the problem is but we will get him off for tests as soon as we can.'
'Darren is a strong character and hopefully the discs can click straight back in.'
Wolves manager Mick McCarthy was gutted after losing having felt his side deserve to win, McCarthy also bemoaned the lack of atmosphere:
'We will never play any better than that but we just have to finish off those chances. Overall it was a terrific performance from us but the atmosphere was rubbish.'


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So remember that I'm a cookbook nerd? Sick and home in bed with a laptop one day this week, I saw this tweet from @eleg_sufficiency – simply brilliant idea for anyone with too many cookbooks and too little time to search through them > Cook & Eat
That's me suckered. I checked out the Cook & Eat project, which is called Gobbledybook, a search engine for cookbooks by Seattle photographer, stylist and food blogger Lara Ferroni .
It's a clever idea to use web searching mechanisms to render the (beautiful, expensive) books you already own more useful – for years Harold McGee has been using a sidebar link to a Google Books search of his On Food and Cooking at his site News for Curious Cooks as a super-charged index. I also use food blog search a lot, and have recently started using forage, the Australian food blog search engine (and you'll find both of those in the sidebar).
The difference with Gobbledybook is that it searches cookbooks, not blog posts. And I have a lot of cookbooks, although not as many as Pat does.
Gobbledybook seems to have a reasonable selection of Australian content, with titles by Luke Nguyen, Curtis Stone, Bill Granger and *cough* Donna Hay. Ottolenghi is in there, and a few baking and vegetarian books, 60 in all to date for a total of nearly 5000 recipes. It has started as Ferroni's own collection, and she will expand it with more of her titles and is encouraging others to start logging their own recipes.
It requires you to sign in with facebook, which I don't like. It's unclear about how the sites interact, and the sign-in box makes it clear they might publish to your wall. I'm worried that if I accidentally look up a Donna Hay recipe it could get posted to my Facebook profile and I will lose the respect of my loved ones. (Updated: more seriously, if you purchased a book via Gobbledybook while logged in through Facebook, Facebook might keep your financial data without asking first.)
As it so often happens, someone else has had the same great idea. Another recently launched service called Eat Your Books does pretty much the same thing. In both cases, ingredients lists but not method are entered, there being no copyright in an ingredients list. Eat Your Books is in beta, but is still considerably more developed with 16,521 Cookbooks and 240,795 recipes entered. It costs US$25 per year or (for a limited time only!) $50 for a lifetime membership. There's a 30 day free trial, which I'm doing at the moment. I can see myself handing over the $50 at the end of it.
Gobbledybook is a charming name the first time you encounter it, but gets pretty tedious to type. And "EYB" makes it a lot easier to stick to twitter's 140 characters. The problem is, I've found Gobbledybook to be pretty buggy and it's certainly not intuitive to use. Perhaps that comes from it being an individual's project expanded? EYB is much better designed and has a more developed search function. You can request that books be added and indexed.
Gobbledybook says their service is better than Eat Your Books because you can add your own books to Gobbledybook rather than waiting for the service to do it, and they will "match up" data behind the scenes so that a failure to use a sufficiently specific term won't bugger up your search results, a problem Ferroni says she's had at EYB with things like searching for "soup" not picking up a "bisque".
I haven't played sufficiently with Eat Your Books a great deal yet, but haven't found any problems. Adding just 24 of my books has given me 4800+ searchable recipes. Searching my books for "witlof" gives me 22 recipes, including chicory and witlof so it looks like someone's doing some "matching up" there too.
I emailed to ask some questions and was really impressed by the substance and tone of their answers. I asked if I could import the few hundred books I had in my Library Thing and was advised that a data import is on the way, and that they're linking with British suppliers and eventually Australian and New Zealand ones to expand the library. And already, somewhere in Canberra, is an indexer adding info from the most prominent Australian books (nah, not me, although I offered …) Their focus is on the last 15 years, but I hope eventually they'll index older titles like the Time Life Good Cook series which I have so painstakingly accumulated.
I'm not so interested in the "community" parts of the sites, as I already have a food blog and a twitter problem, but there's potential for it to really take off. Much as I love flipping through cookbooks, sometimes I'd rather just be able to find or remember what I'm looking for – so when there's something new at the farmers' market or a glut in the veggie garden, dinner need never be boring. Even if it's zucchini again.
Updated: disclosure! Eat Your Books has given me a free lifetime membership after reading this post. It didn't cross my mind before writing, and I was going to pay up anyway, but as I don't usually accept stuff I thought I should mention it.