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Thursday, November 6, 2003
7:30 – 9:30 a.m.
The Westin La Poloma
Tucson, Arizona
Philip T. Temple, Esq.
McCarthy, Fingar, Donovan, Drazen & Smith, LLP
White Plains, New York
I. Gifts of Closely Held Corporate Stock
1. Background on Corporate Income Taxation.
A. Generally, corporate income is subject to double taxation. First, the corporation pays corporate income tax on its net income. Then, the corporate shareholders pay income tax on receipt of dividends or on distributions of corporate assets when the corporation terminates. There is some relief from double taxation for S corporations, as discussed below.
B. Example: Jane Donor created a corporation some years ago and made a capital contribution of $10,000.00. The closely held corporation has assets worth $200,000 with a tax basis of only $40,000. Jane believes that her stock is worth $200,000 - - the value of the corporate assets. However, if the corporation sold those assets and liquidated, the IRS would collect approximately $81,520 of income tax and Jane would be left approximately $108,500.
Corporation: Sells assets worth $200,000
Tax basis 40,000
Taxable gain $160,000
Corporate tax (assuming 34%
tax bracket) 54,400
Proceeds left for shareholder
(Sales proceeds of $200,000 less
$54,400 tax) = $145,600
Shareholder: Liquidating distribution of net
proceeds $145,600
Less: Jane's cost basis 10,000
Long-term capital gain $135,600
Capital gains tax (20%) 27,120
Net proceeds to Jane $108,480
C. The result would be the same if the corporation merely distributed its assets to the shareholder because the law requires the corporation to pay income tax as if it had sold its assets and the shareholder is treated as if she had sold her stock.
The tax burden would be even worse if the distribution of assets were treated as a dividend to the shareholder because then the corporation still pays income tax as if it had sold the assets but the shareholder pays ordinary income tax on the value of the assets received rather than the more beneficial long-term capital gain rate.
D. Clear Conclusion: Keep appreciated assets, such as real estate, out of a C corporation. The problem is that the gift planner must deal with that fact because the shareholder/donor has already placed assets inside the corporation.
E. The corporation itself can contribute assets to a charity or a charitable remainder trust and avoid the tax on the assets' growth if sold by the charity or the trust but, if a trust is established, the income stream would be paid to the corporation, taxed to the corporation at its rates and then, when distributed to the shareholders, would generate regular income tax as a dividend.
2. Gifts of Closely Held Stock.
A. Gift of appreciated publicly traded stock to charity - - whether a public charity or a private foundation - - will still generate a double tax benefit: A charitable contribution deduction based on the fair market value of the stock with no realization of capital gain income.
B. However, the benefits obtained on a gift of closely held corporate stock will depend upon the charitable donee:
(1) If the gift is to a public charity, the deduction is still at fair market value with no realization of capital gain income;
(2) If the gift is to a private foundation, the deduction is for cost basis only;
(3) There are also higher ceiling limitations for gifts to a public charity than to a private foundation, as follows:
Cash or Long Term
Kind of Charity Ord. Inc. Prop. Cap. Gain Prop.
Public Charity 50% of AGI 30% of AGI
Private Non-Operating
Foundation 30% of AGI 20% of AGI
Private Operating Foundation 50% of AGI 30% of AGI
A five year carryover for any "excess" contribution is allowed in each case.
C. Qualified appraisal required. See below for discussion of valuation and substantiation rules.
3. Life Income Arrangements.
A. If publicly traded securities are transferred to, for example, a charitable remainder trust, the results are clear and there are ordinarily no problems with a deduction for the remainder value calculated on the full fair market with no imputing of the gain to the donor and generating an income stream which will generally increase the donor's income.
B. Using closely held C corporation stock. Example: John and Jane Donor, both age 65, are about to sell their corporate business for $10,000,000 that they started many years ago and which has basically a zero cost basis. Before the sale is a binding obligation, they transfer $1,000,000 of that stock to a charitable remainder unitrust at 7% retaining the income stream jointly and for the survivor of them. The below chart shows that, by avoiding capital gains tax, they receive an income stream of $70,000 rather than $56,000, an increase of 25%. And, they have generated an income tax charitable contribution deduction of approximately 25% of the value of their gift or $250,000 which is money in their pockets and which can be used for themselves or their heirs.
Sell the Stock Transfer Stock to
Personally CRUT Which Sells
Sales Price $1,000,000 $1,000,000
Cost Basis 0 0
Capital Gain $1,000,000 $1,000,000
Tax (20%) 200,000 0
Net Proceeds $ 800,000 $1,000,000
Invest at 7%
Annual Income $ 56,000 $ 70,000
A wealth replacement life insurance policy coupled, where appropriate, with an irrevocable life insurance trust will even more significantly increase the ultimate benefit to their heirs.
C. Often, a gift followed by a redemption by the corporation will achieve the same results. And, in corporations that have concern regarding the accumulated earnings tax, a charitable gift of stock in that corporation followed by a redemption can result in the corporation having less undistributed cash; therefore, it is less likely subject to the accumulated earnings tax and, of course, there are the other tax benefits already discussed.
D. Be careful in arranging the corporate redemption.
(1) Avoid imposition of the self-dealing rules; generally, it would appear that the corporation is itself a disqualified person that would not be able to purchase the stock from the trust. However, Code Section 4941(d)(2)(f) provides an exception to the self-dealing rules where the corporation makes an offer on the same terms to all shareholders of the same class and the terms of the offer provide for receipt of no less than fair market value. Must be all cash deal.
E. Beware of the pre-arranged sale.
(1) The threshold case: Palmer v. Commissioner, 62 T.C.684(1974), Aff'd on another issue, 523 F.2d 1308(8 Cir. 1975).
(a) Donor had voting control of both a closely held corporation and a tax-exempt private foundation. Pursuant to what appeared to be a single plan, donor contributed shares of corporation's stock to foundation and then caused the corporation to redeem the stock from the foundation.
(b) IRS wanted to impute gain to Palmer.
(c) Tax Court, affirmed by the Appeals Court, held that transfer of stock to foundation was valid gift and gain not taxed to Palmer on the following grounds:
(i) Foundation was not bound to go through with redemption at the time it received title to the shares, and
(ii) Corporation's right to redeem is based upon a purchase at fair market value.
(d) IRS has acquiesced in Palmer. Rev. Rul., 78-197, 1978-1 CB 83. Redemption proceeds of stock under facts similar to those of Palmer will impute gain to the donor only if the donee is legally bound or can be compelled by the corporation to surrender the shares for redemption.
(2) However, see Blake v. Commissioner, 697, F2d. 473 (2d Cir. 1982). A "chutzpah" case.
II. S Corporation Stock
1. Background: Generally, S corporation does not pay income tax. It is a pass through entity (like a partnership) and corporation's income is taxed directly to shareholders. This avoids double taxation of income that often occurs with C corporations.
2. Charity can now be eligible S corporation shareholder. Code Section 1361(c)(6),
effective January 1, 1998.
A. Charitable deduction is often less than full fair market value of stock because of reduction rule of Code Section 170(e), which requires that the income tax
deduction for a gift of appreciated long-term capital gain property is generally reduced by the amount of "ordinary income" that the donor would have realized had he sold the property. With an S corporation, often Code Section 751 rules regarding certain assets such as (1) "unrealized receivables," (2) "inventory," (3) "depreciation recapture," may have impact on deductible amount.
B. Watch out for phantom income.
C. Charity will be subject to unrelated business income tax (UBIT) on its portion of S corporation's accounting income. Also, unlike almost every other capital gain asset, the gain from the sale of S corporation stock by the charity will also be subject to UBIT. Code Section 512(e)(1)(B)(ii).
3. But, the above rule does not apply to a transfer that is not an outright transfer to charity, such as a transfer to a charitable remainder trust. Such a transfer will still automatically terminate the S corporation election. Often, that can have adverse tax implications to the donor who contributes such stock.
4. A way out: S corporation creates the charitable remainder trust.
A. S corporation transfers appreciated assets to the CRT; corporation gets
the income tax charitable deduction; passes deduction through to its shareholders; problem - - deduction that can be claimed by the shareholder is limited to his or her basis in the S corporation stock which is generally minimal.
B. But the charitable remainder trust can sell and invest the appreciated assets without capital gains tax and reinvest the full sales proceeds to generate the income stream.
C. Trust term can only be for term of years - - not to exceed 20.
D. Potential problems where there are multiple shareholders of the S corporation with different agendas.
III. Family Limited Partnerships - - The Charitable FLP
1. Background: Family limited partnership generally used in estate planning to manage the family wealth and create discounts for marketable securities and
other assets where discounts are not generally allowable.
A. Husband and wife, for example, create limited partnership; retain general partnership interests so that they maintain control, as well as limited partnership interests.
B. Make gifts to, say, children of limited partnership interest; take deep discounts for lack of marketability and minority interest.
C. Internal Revenue Service getting more aggressive in fighting deep discounts of, say, 50%; but the planning still works if taxpayer is not too greedy.
D. Discounts can also apply for estate tax purposes reducing the value of the estate. But, be aware, IRS using Code Section 2036 to keep value of stock in
2. Charitable FLP: too good to be true? IRS has taken hard look. See Wall Street Journal article of July 13, 1999; Chronicle of Philanthropy article of July 15, 1999.
A. The mechanics.
(1) John Donor creates family limited partnership comprised of general partnership interest and one or more levels of limited partnership interests.
(2) He puts business and other appreciated assets and cash into FLP.
(3) As general partner, donor retains a management fee for operating the partnership. The fee generally ranges from 3% to 10% of partnership income. This enables donor to keep all or almost all of the firm's cash flow or, perhaps, trickle out token amount to limited partners at discretion of donor as general partner. General partner also retains the right to borrow partnership assets for personal needs at competitive interest rates.
(4) Donor makes gift of, say, 97% of limited partnership interest to charity. This generates large income tax charitable deduction.
(a) Even when majority of all the limited partnership interests are conveyed to charity, those interests carry limited, if any, control and, often, no marketability, and must, therefore, be discounted considerably for valuation of the charitable deduction.
(b) Charitable gift is made, but subject to a "put" enabling the charity to force a buyback of the limited partnership interests - - typically, at significant discount from their value when received by charity.
(5) Donor makes a simultaneous gift of remaining 3% of limited partnership units to children and/or grandchildren. Gift tax valuation of those interests also takes into account lack of control and marketability and so a relatively large valuation discount for gift tax purposes is also taken.
(6) As part of transaction, partnership purchases life insurance on donor's life to fund the later buyout. The partnership itself splits the premium dollars with an irrevocable trust representing the interests of its beneficiaries, the limited partners of the 3% interest. Therefore, indirectly, since charity holds 97% of the limited partnership interests, charity is paying most of the insurance premiums. In one variation on this theme, charity, through its "put," can sell its interest to the irrevocable life insurance trust. Thus, charity's dollars have been helping to fund life insurance that will be used to buyout its interest - - at a substantial discount - - and the trust then receives the partnership interests with a stepped up basis benefiting the family members.
Further, if there is sale of partnership assets during donor's life and before charity exercises its right to demand a purchase of its interest, approximately 97% of the gain on sale is attributable to the charitable partner. Thus, donor's family pays tax on only the 3% balance, a small fraction of the gain.
(7) At the specified "put" date, charity exercises its option to force the purchase - - at pennies on the dollar - - of the limited partnership interest charity holds. It receives cash in return for the interest, which has been sold back, either to the partnership itself or to the 3% owners or to the irrevocable life insurance trust. Thus, the family business and other holdings of the limited partnership (together with any appreciation on the relatively untaxed capital gains sheltered by the charity's exempt status) comes back into the family's control.
B. So, where's the gift? Donor and his advisors try to convince charity that it will make some money on the transaction in return for allowing the donor and his family to receive tremendous benefits from the transaction. They receive a disproportionate benefit and facilitate their personal estate planning objectives. Remember Blake? This may be another classic example of using charity to serve a private rather than public purpose.
C. The IRS' likely position.
(1) The agreement of the parties from the beginning was based on an unwritten - - but very real - - understanding between the donor and charity that, after a relatively short period of time, charity will sell its interest back to the partnership or the other partners and receive only a small portion of what the underlying assets and, therefore, the charity's limited partnership interest, is worth.
(a) IRS could argue that what charity received at the time of contribution was only the sum of the future right to receive the "put" price and the present value of minimal income distributions for, say, five years.
(b) More likely, IRS will argue that there is no allowable income or gift tax deduction because the reality is that what the donor gave was a possible but uncertain stream of dollars over a period of years.
(2) The donor and his advisors would likely argue that the "put" is merely an option and that there was never a legal obligation on the charity to sell. Therefore, the contribution of the 97% interest in the limited partnership must be respected. However, in the more egregious and aggressive cases, would the transaction ever have been entered into had the parties not "known" from the beginning that the charity would have no practical choice but to exercise its "put."
D. Does it ever work? Yes, if there is donative intent, the family limited partnership is entered into to achieve other family planning objectives and there is not the overreaching present in the type of "charitable" family partnership described above.
IV. Stock Options; Restricted Stock
1. Stock Options - - Definition: A contractual right given by a corporation to an employee (and sometimes, to an independent contractor) to purchase stock in the corporation at a stated price per share for a stated period of time. There are two basic types of options.
A. Nonstatutory ("Nonqualified") Options (IRC §83).
(1) Generally, this type of option is not taxable to an employee when granted, unless the option has a readily ascertainable value (i.e., it is actually
traded on an established securities market), at the time of grant.
(2) Compensation is realized when the option is exercised or "otherwise disposed of." Compensation is equal to the difference between the fair market value of the stock at the time of exercise and the exercise price.
(3) An employee may choose to recognize compensation income on grant by making an IRC ?83(b) election. Seldom done because of difficulty in ascertaining value of options. No income will then be realized on subsequent exercise.
B. Statutory Options
(1) Includes incentive stock options ("ISOs"), employee stock purchase plans, qualified stock options and restricted stock options.
(2) General Tax Treatment:
(a) The employee does not recognize taxable compensation income at the time the option is granted or at the time the option is e for AMT purposes, the difference between the fair market value and the exercise price will be considered part of AMT income. exercised (unless exercised more than three months after leaving employment). The price for such avoidance is that the employee must not dispose of the stock until two years from the date the option was granted and one year from the date the employee received the shares upon exercise. Code Section 422(a)(1). A disposition includes a sale, exchange or gift.
(b) If the employee disposes of the stock before the holding period is up, he must recognize as compensation income the difference between the option exercise price and the fair market value of the stock at the time of the option exercise. In addition, he will recognize income equal to the difference between his basis in the stock (the exercise price increased by the amount included in gross income as compensation) and the amount he receives in the disposition.
(c) If the employee waits to dispose of the stock until after the holding period, there will be no compensation income, but there will be capital gain, if any (short or long-term, depending on how long the stock is held). The capital gain would be the difference between the amount received in the disposition over the basis in the stock (i.e., the amount the employee paid when exercising the option).
(3) Alternative Minimum Tax ("AMT") for ISOs: While the exercise of an ISO does not result in current taxable income, there are implications with regard to the AMT. When calculating income for AMT purposes, the difference between the fair market value and the exercise price will be considered part of AMT income.
(4) Where does cash for exercise come from?
(a) Other assets;
(b) Brokerage loan and sale;
(c) Sale in same year.
C. Disposition of Option Stock
(1) Definition: Generally, a disposition is any sale, exchange, gift or transfer of legal title of the stock. IRC §424(c) provides certain exceptions.
(a) Transfer from a decedent who held ISO stock to an estate, or a transfer by bequest or inheritance.
(b) Exchange of ISO stock in certain nonrecognition transactions (e.g., reorganization).
(c) Pledge or hypothecation is not a disposition, but transfer pursuant to pledge or hypothecation is a disposition.
(d) Between spouses incident to a divorce.
(e) Acquisition in joint ownership with right of survivorship. Change in joint ownership is disposition.
(f) Taxpayer in bankruptcy.
(2) IRS rulings:
(a) Purchase of a put on option stock is not a disposition (Rev. Rul. 59-242, 1959-2 C. B. 125).
(b) Short sale on option stock is a disposition (Rev. Rul. 73-92, 1973-1 C.B. 208).
D. Charitable Alternatives
(1) Outright Gift of Stock to Charity
(2) Charitable Remainder Trust
(3) Charitable Lead Trust: Employee establishes charitable lead trust with cash proceeds of sale or with other assets to offset gain in connection with exercise of option.
(4) Charitable Gift Annuity: Employee "sells" stock to charity in exchange for an annuity.
2. Rule 144 Stock
A. Regardless of whether they are publicly traded or not, securities are subject to certain Securities and Exchange Commission rules regarding their sale if they are acquired, directly or indirectly, in a transaction or chain of transactions not involving a public offering (in which case they are "restricted securities") from (1) the company issuing them or (2) an individual or company affiliated with the issuing company (generally including officers and directors of the company, in which case they are "control securities"). SEC Rule 144 provides a safe harbor for the sale of these securities if all the conditions of the rule are met.
B. Generally, Rule 144 requires that a charity and its donor together must hold restricted securities for a minimum of one year before their sale in accordance with the rule. It also imposes a value limitation on the amount of securities that can be sold by affiliates of the company during any three-month period and may require aggregation of the charity's sales with the donor's. Adequate current information on the issuing corporation must be on file with the SEC. The SEC, as well as the principal national exchange on which the securities are listed, must be notified of the sale.
C. Securities laws do not generally prohibit gift, but donor's restrictions on sale apply to donee (including charity).
D. Rule 144 stock not considered "qualified appreciated stock."
3. ESOPS and CHESOPS
A. ESOP is tax qualified, defined contribution employee benefit plan whereby, in return for meeting certain rules which protect the interests of plan participants, the ESOP sponsors receive various tax benefits.
B. Ordinarily, to set up an ESOP, the company creates a trust fund for employees and funds it by one, or a combination of, the following tax deductible methods:
(1) Contributing shares of the company.
(2) Contributing cash to buy company shares; or
(3) Having the plan borrow money to buy shares with the company then making payments to an ESOP trust to repay the loan.
C. Tax Advantages:
(1) Employer can deduct (within limits) contributions to an ESOP, including both principal and interest on loan proceeds the ESOP uses to buy company stock.
(2) Employer can generally deduct reasonable cash dividends, if paid to an ESOP and used to repay the ESOP loan or passed through to participants on ESOP held stock.
(3) The shareholders of a close corporation can defer taxation on the gain resulting from their sale of company stock to an ESOP, provided the ESOP owns 30% or more of a company's shares after the sale, by reinvesting sale proceeds in qualified replacement property ("QRP") consisting of stock or bonds in operating companies in the United States.
D. A CHESOP is a combination of an ESOP with a gift to charity.
(1) The simplest way is to have the shareholder donate his privately-held stock to a nonprofit institution, which then sells the stock back to an ESOP established by the company. Donor gets charitable deduction for full fair market value and avoids capital gain on the appreciation; or
(2) The owner of the shares can use the proceeds of the sale to an ESOP to purchase QRP and then gift the QRP to a qualified charity. Individual owns QRP with same holding period and basis as the stock sold to the ESOP, but avoids capital gain and gets full fair market value deduction by giving QRP to charity or, perhaps, to a qualified charitable remainder trust retaining an income stream.
V. Gifts of Real Estate
1. Real estate represents approximately 50% of total individual wealth; important that charities tap potential of real estate gifts.
2. Many kinds of real estate interests; know the names and rules, for example: whole fee interests; partial interests (undivided interests, life estate and remainder; joint tenancy; tenancy in common).
3. Income tax charitable contribution deduction.
A. Limit on charitable deduction for appreciated real estate gifts is 30% of adjusted gross income with five year carryover for any "excess" contribution - - up to 30% of adjusted gross income in each carryover year until exhausted.
B. If you can't use entire gift, consider contributing partial or undivided interest over a period of years or making the election to reduce the amount of the gift by the appreciation so that the ceiling increases to 50% of adjusted gross income.
4. Transfer of Encumbered Property to Remainder Trusts and as Outright Gift.
A. Mere transfer of mortgaged property is deemed bargain sale. Reg. Section 1.1011-2(a)(3).
(1) IRS has said Reg. Section 1.1011-2(a)(3) applies to CRT. Rev. Rul. 81-163, 1981-1 C.B. 433.
(2) Gain is for difference between amount of debt and allocated adjusted basis; not limited by property's fair market value.
B. LTR 9015049. CRT disqualified if funded with mortgaged property.
(1) Facts. D planned to fund charitable remainder unitrust with income-producing real estate. Trustee would make regularly scheduled payments on mortgage, but D would remain personally liable for the debt.
(2) IRS rules. Trust won't qualify. Charitable remainder trust must function exclusively as one from its creation. It isn't charitable remainder trust - indeed, it isn't even deemed "created" - as long as donor treated as owner of entire trust under the grantor-trust rules. Reg. Section 1.677(a)-1(d) provides that donor is treated as owner of trust whose income is or may be applied in discharge of donor's legal obligation. Because D would be treated as owner of entire trust, it wouldn't be deemed "created," and thus wouldn't qualify as charitable remainder unitrust.
(3) Earlier rulings (i.e. LTR 8931023).
C. Possible ways to avoid issue:
(1) If outstanding mortgage is small, donor may be willing to satisfy it before transferring property to trust.
(2) Sometimes lender may be willing to release mortgage if donor can substitute other security for indebtedness.
(3) Donor could sell undivided interest in property to charity (reporting capital gain on any appreciation attributable to that interest). Then donor could use sale proceeds to satisfy mortgage, and transfer unencumbered property to charitable remainder trust. Charity would have to take care not to pay more than fair market value for undivided interest - and fractional interests in property may have to be discounted to reflect the unwieldiness of a co-tenancy arrangement. Naturally, charity would first have to be sure charitable remainder is large enough to make it all worthwhile.
5. Consider the following types of trusts or other split interest arrangements:
A. Unitrust agreements.
(1) Standard Unitrust -- pays stated percentage (at least 5%) of net fair market value of trust assets, revalued at least annually, out of income and, if income is insufficient, out of principal. Excess income is retained in trust.
(2) Net Income With Makeup Unitrust -- pays lesser of (i) stated percentage of annual net fair market value and (ii) actual trust income. Deficiencies in distributions from an earlier year are made up in any later year in which trust income exceeds stated percentage. Then excess income retained in trust.
(3) Net Income, No Makeup Unitrust -- pays lesser of (i) stated percentage of annual net fair market value and (ii) actual trust income. Deficiencies in distributions from an earlier year are not made up. Excess income is retained in trust.
(4) Hybrid agreement (the "Flip" unitrust). Net income unitrust becomes standard unitrust on sale of , i.e., closely held corporate stock. First, unpublished PLR said O.K. Then, IRS said it doesn't work. PLRs 9506015 and 9516040. Now Final §664 Regs again says O.K.
(5) Some Specific Items Regarding Nimcruts.
(a) Excess income in earlier year cannot be used to make up deficiency in later year.
(b) Provision for treating post contribution realized gain as income in net income unitrust.
(c) What is income? Generally state law governs. Be careful of special situations; i.e., assets such as timber; assets that have periodic large amounts of income.
(d) Net income provision does not change calculation of charitable deduction for income, gift or estate tax purposes.
B. Annuity trusts.
(1) Trust where annuity amount couched in terms of stated dollars; trustee directed to pay X dollars a year out of income and, if income is insufficient, out of principal. Any excess income is retained in trust.
(2) Trust where annuity amount couched in terms of a percentage of initial fair market value of assets transferred to trust. Once amount determined, stays constant for trust term.
(3) Unlike unitrust, cannot make additional contributions to annuity trust.
C. Pooled income fund.
Donor irrevocably transfers money, long-term marketable securities or both to qualified charity's separately maintained pooled income fund, where it is invested together with transfers of others who make similar life income gifts. Donor (or other designated beneficiary) receives his share of pooled income fund earnings each year. On donor's death (or death of other designated beneficiary) payments terminate and charity removes donor's gift from pooled fund and uses it for charitable purposes.
D. Charitable gift annuities.
(1) Immediate payment. Donor transfers money or property to charity in exchange for promise to pay fixed amount annually to donor (and survivor, if desired) for life. Transfer is part gift and part purchase of annuity. Annual income (rate of return) paid by charity depends upon beneficiary's (annuitant's) age at time of gift. Annual rate of return remains constant for life.
(2) Deferred payment. Donor makes gift to charitable institution in exchange for charity's promise to pay him guaranteed life income starting at retirement (or any other date specified).
(3) Gift annuity for irrevocable remainder interest.
E. Charitable lead trusts.
(1) Donor can avoid tax on income paid to charity, but the trust must not provide reversion for donor or spouse. Trust should be lead unitrust or lead annuity trust. Otherwise, value of charity's income interest will be subject to Federal gift tax. And, if there is a reversion and donor dies before property reverts to him, there will be no estate tax charitable deduction.
(2) Main drawback of law is that donor cannot get income tax charitable deduction unless trust so drawn that he is taxed on income paid to charity. Thus, except for very wealthy individuals, short-term charitable income trust created during lifetime is generally not advantageous. Some create trust with tax-exempt bonds so that income, while reportable, is not taxable.
(3) Lead trusts paying an income stream to charity are advantageous when created by donor's will. Estate tax charitable deduction allowed for value of income paid to charity under lead trust created by donor's will. To get estate tax deduction, income interest must be guaranteed annuity (lead annuity trust) or fixed percent distributed yearly of net fair market value of trust assets, determined yearly (lead unitrust).
F. Gifts of personal residence with retained life estate.
(1) Charitable deduction (for income, gift and estate tax purposes) allowed for gift of remainder interest in real property (not made by transfer to charitable remainder unitrust, annuity trust or pooled income fund trust) only if remainder interest is in personal residence or farm.
(2) Life tenant (often donor) must maintain property --- pay real estate taxes, insurance premiums and for ordinary repairs.
6. Bargain Sale.
A. Real estate is sold to charity for below fair market value; difference between fair market value and sales price is charitable contribution deduction.
B. Donor's cost basis is allocated on a pro rata basis between sale and gift portion. The gain attributable to the sale portion is realized by the donor; the appreciation attributable to the gift portion is not taxed.
C. Intention to make a gift should be well documented.
7. Gift of Land for Conservation Use.
A. Gift of lease, option to purchase or easement as to real estate that is granted in perpetuity qualifies for the charitable deduction as long as the gift is made exclusively for conservation purposes. See Code Section 170(f)(3)(B)(ii).
B. Value of easement is its fair market value on date of gift. If there is no meaningful record of market place sales, then the value of the easement and, thus, the deduction equals the difference between the pregift fair market value and the post gift fair market value of the entire property.
C. No deduction allowed if the grant of the easement may have no material effect on property's value or may enhance, rather than reduce, property's value. Regulation Section 1.170A-14(h)(3)(ii).
D. The amount of basis that is allocable to the qualified conservation interest is in the same ratio to total basis as to the fair market value of the contributed interest bears to the fair market value of the property before the gift.
VI. Gifts of Tangible Personal Property
1. Deductibility of gift of tangible personal property (for example, art or other collectibles) deductible at fair market value only if gift is deemed as being made for a related use. If gift is being deemed for an unrelated use, gift is limited to cost basis.
2. See special rule of Code Section 170(a)(3) below.
3. Transfer of Tangible Personal Property to Remainder Trusts. Is A Puzzlement!
A. Code Section 170 (a) (3):
Future Interests in Tangible Personal Property -- For purposes of this section, payment of a charitable contribution which consists of a future interest in tangible personal property shall be treated as made only when all intervening interests in, and rights to the actual possession of enjoyment of, the property have expired or are held by persons other than the taxpayer or those standing in a relationship to the taxpayer described in section 267(b) or 707(b). For purposes of the preceding sentence, a fixture which is intended to be severed from the real property shall be treated as tangible personal property."
B. The Krugerrand Rulings:
(1) LTR 9225036 held that appreciated in value Krugerrands are more like money than collector's coins (tangible personal property), thus the deduction for a transfer to a CRT would be based on full fair market value -- not cost. The Service also said that funding an otherwise qualified CRT with Krugerrands would not disqualify the trust. And, since the coins were not tangible personal property, the rules of IRC Section 170 (a)(3) won't apply.
(2) A second Kruggerand ruling submitted some nine months later, which was withdrawn because of the tax payer's death, appeared to indicate that IRS had changed its mind.
C. LTR 9452026 held that funding a CRT with an appreciated musical instrument is OK.
(1) IRS did not rule on the qualification of the trust referring to its Revenue Procedures containing specimen CRT documents.
(2) Since the instrument is tangible personal property, no income tax
deduction is allowed under IRC Section 170 (a) (3). A deduction is allowed only when it is sold.
(3) It's an unrelated use gift and, therefore, the income tax contribution deduction is based on cost, not fair market value.
D. A dilemma, what to do?
VII Valuation and Substantiation Rules
1. Valuation -- General Rules.
A. Basics. If a charitable contribution is made in property other than money, the amount of the contribution is the fair market value of the property at the time of the contribution... fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
B. Comparable sales.
(1) Comparable sales technique (also known as "market data method") most useful when donated property similar to other property available on open market.
(2) Appraiser locates several similar items -- called "comparables" -- that were sold or available for purchase near time of donation.
(3) That gives ballpark figure. Then value increased or decreased, depending on how donated property stacks up against comparables.
C. Capitalization of income.
(1) If asset generates income, value can sometimes be appraised by estimating how much income it can be anticipated to earn.
(2) Then match to market rates.
D. Replacement cost.
(1) This method most often used when property to be valued is unique and isn't expected to generate income.
(2) Because replacement cost represents value of brand-new asset, adjustments may be made to reflect depreciation on property before its donation.
E. Subsequent sales.
(1) Often, charities that have no immediate use for donated property sell property and use sales proceeds for charitable endeavors. Although sale price of donated asset is not conclusive evidence of fair market value, IRS and the courts generally find it very persuasive.
(2) Indeed, new reporting requirements for certain contributed property sold within two years of gift show how probative Congress finds that information.
2. Form 8283: Appraisal summary.
3. Form 8282: The "tattle tale" form.
4. Appraisals.
A. What must be appraised?
(1) Property gifts (other than money and publicly traded securities) if claimed or reported value of property exceeds $5,000. To determine whether $5,000 threshold crossed, only part of gift claimed as charitable deduction counts. Thus, if land worth $25,000 is placed in charitable remainder unitrust, appraisal requirements apply only if charity's remainder interest more than $5,000 and donor claims income tax charitable deduction.
(2) What is "qualified appraisal"?
(a) Qualified appraisal can be done any time from 60 days before donation up until due date (including extensions) for return on which donor reports or claims gift; post-donation appraisals are okay.
(b) Regulations require qualified appraisal to give following information:
(i) Description of property in sufficient detail for person who is not generally familiar with type of property to ascertain that appraised item is property contributed.
(ii) In case of tangible property, its physical condition.
(iii) Date (or expected date) of contribution to donee-charity.
(iv) Terms of any agreement or understanding entered into (or expected to be entered into) by or on behalf of donor (or donee) that relates to use, sale or other disposition of contributed property; includes, for example, terms of any agreement or understanding that –
(A) Restricts (temporarily or permanently) donee-charity's right to use or dispose of donated property;
(B) Reserves to, or confers upon, anyone (other than charity or organization participating with charity in cooperative fund-raising) any right to income from donated property or possession of property - including right to vote donated securities, to acquire property by purchase or otherwise, or to designate person having income, possession, or right to acquire; or
(C) Earmarks donated property for particular use.
(v) Name, address and TIN of qualified appraiser (or appraisers) and - if qualified appraiser is a partner in partnership, employee of any person (whether individual, corporation, or partnership or independent contractor engaged by person other than donor - name, address and TIN of partnership or person who employs or engages qualified appraiser.
(vi) Qualifications of appraiser who signs appraisal, including appraiser's background, experience, education, and membership, if any, in professional appraisal associations.
(vii) Statement that appraisal was prepared for income tax purposes.
If you think you may require the assistance of Lisa Newfield in any matter, email (firstname.lastname@example.com) or phone her (914-385-1032) with any question you may have.


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Jassam, left, a freelancer who worked for Reuters, was arrested on
September 2, 2008, by U.S and Iraqi forces during a raid on his home in
Mahmoodiya, south of
"We welcome the release of Ibrahim Jassam but we remain
deeply concerned by the lack of due process exercised in this and similar, previous
cases," said
Pentagon spokeswoman Patricia Johnson told CPJ today that Jassam "was detained as a security threat in September 2008 as the result of activity with an insurgent organization." She said that while he was never charged, the military found that "there was intelligence evidence against him," without specifying what the evidence was.
"I am very pleased his long incarceration without charge is finally over," said Reuters Editor-in-Chief David Schlesinger. "I wish the process to release a man who had no specific accusations against him had been swifter."
In November 2008,
the Iraqi Central Criminal Court ruled there was no evidence to hold Jassam and
ordered the
CPJ has repeatedly denounced the U.S military's practice of detaining journalists without charging them with a crime or providing them with due process. On several occasions, CPJ has raised the matter with officials at the White House and the Department of Defense, including in a letter sent to President Barack Obama and in a meeting in December 2009 with National Security Advisor Gen. James L. Jones. In each case, CPJ lobbied for Jassam's immediate release.
CPJ has
documented 14 cases in which journalists have been held by
EDITOR'S NOTE: The original alert was modified in the fourth paragraph to update with the Pentagon's response.

subset: commoncrawl


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Check out the new RVW Level Builder Video!
We've just produced an exciting video that shows off the new RVW Level Builder! Check it out to see how easy it is to get started with the powerful new software.
Download the initial version of the software, here. For more information on the Level Builder, visit this page.


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Papoose In Studio Recording "Real Niggas Always Finish Last" Pt. 1 [Official Video Coming Soon][Street Heat Exclusive]
Street Heat TV Reports "PAPOOSE- Song being recorded before Video". Official world premiere video coming soon on worldstarhiphop.com
Please click the "Report" button below if the video on this page is not working properly.
Comments will only be displayed by verified emails. No Spamming or Racism.


text:
Tea Ware
Tea for me, tea for you, tea for two! If you are a solo sipper or the host of a tea party for dozens, get just the right tea ware here. From very traditional to very modern tea ware, express your tea brewing style with teacups, teapots, and tea infusers that look as good as the hot, cold or iced infusions they help create.
Learn More about Tea Ware
Bodum Assam Tea Press with Handle
Regular Price: $34.95


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It looks like your browser is out of date.
To use all features of KLM.com safely, we recommend that you update your browser, or that you choose a different one. Continuing with this version may result in parts of the website not being displayed properly, if at all. Also, the security of your personal information is better safeguarded with an updated browser.
A trip to Milan consists of more than just shopping, enjoying the culture and admiring the Duomo – sampling a plate of risotto is a must! The Milanese love their risotto. While in the vast majority of Italy pasta rules supreme, Northern Italy is best known for its rice dishes such as risotto. There are several restaurants that specialise entirely in this dish.
Risotto is the diminutive of 'riso', the Italian word for rice. In Milan they prepare the rice, the world's most popular grain, in a very special way. Risotto alla Milanese is cooked with saffron, lending the dish its rich yellow colour. There are many stories about the origin of the tradition, but one of them tells the story of a young servant who worked on the Duomo di Milano in 1574. He got into an argument with his boss and intended to ruin his boss' upcoming wedding by colouring the rice with saffron. However, it became an unexpected (and lasting) success.
The Trattoria da Abele is well known for its risotto in Milan. This simple and traditional eatery serves a variety of risottos and other dishes every day. Choices range from the classic Risotto alla Milanese to more unique variations such as the risotto cuneese (with bacon and potatoes) and risotto con spinaci e scamorza (spinach and smoked cheese). In summer, the cooks play around with lighter ingredients, such as tiny wild strawberries. Desserts are another specialty, so be sure to leave some room!
Via Temperanza, 5, Milan
Trattoria Casa Fontana is a must for risotto lovers; this small restaurant uses top quality rice to prepare 23 different risotto dishes – these can be with meat or strictly vegetarian. This restaurant is usually pretty packed so reservations are recommended. Located in the suburbs of Milan, the restaurant requires some effort to get there.
Piazza Carbonari 5, Milan
Restaurant El Brellin serves outstanding traditional dishes such as risotto with zucchini flower, raw shrimp and purple potato slices, or a classic Milanese risotto with saffron and beef shank sauce. The restaurant has 2 floors and its walls are adorned with many small paintings; find a cosy spot by one of the fireplaces and enjoy your meal. If you wish to extend your evening after dinner, spend some time with a drink in the adjacent café that is part of El Brellin.
Alzaia Naviglio Grande 14, Milan


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Arctic Cat Prices, Values and Specs
Select any Arctic Cat model
Arctic Cat Note
SNOWMOBILES - Manufacturer will not release missing weight information. Contact manufacturer for weight specifications.
(Model years 2019 - 1985)
Founded in 1960, Arctic Cat is a North American manufacturer of recreational vehicles. Although the company produces ATVs and Prowlers, they are primarily known for their high performance snowmobiles.


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Master's in Basic Science
- Bioscience & Biotechnology, PhD
- Chemistry, MS/PhD
- Computer Science, MS/PhD
- Information Technology, MS
- Mathematics, MS/PhD
- Physics, MS/PhD
Click on your area of interest for more information!
The applicant should have a solid foundation within their chosen area of scientific study, as evidenced by academic grades and scores on the Graduate Record Examination (GRE). International applicants must also submit a TOEFL score. All general application requirements for the School of Arts & Sciences will apply as well - please visit the Arts & Sciences graduate website for details.
Research Advisor
In order to be considered for admission into the Basic Science Master's degree program, an applicant must identify a research advisor with whom they would be able to complete their graduate work. Together with the potential advisor, the student must present a projected plan of study which will be reviewed by the admission committee as part of the application. This allows both the student and the advisor to carefully consider the desired outcomes of this program. Please note: this requirement does not apply to applicants of the Biology or Data Analytics specializations.
Degree Requirements
Completion of an MS degree in Basic Science requires that the student meet the minimum university requirements for the Master's degree, as found in the current Clarkson Catalog:
- A minimum of 30 credit hours of graduate coursework, as follows:
- At least 20 credit hours of course and seminar work. The balance of coursework must be consistent with the research or professional experience component.
- Only courses numbered 500 and above are accepted for graduate credit.
- 10 credit hours of transfer credit (B grade or better) may be accepted.
- Satisfactory completion of a research or comparable professional experience, as follows:
- A written thesis based on independent research;
- A comprehensive examination; or,
- An appropriate, professionally oriented special project.
- At least one academic year of study beyond the B.S.
- A cumulative GPA of 3.0 in courses used to meet graduation requirements
- All work must be completed in five calendar years
A thesis submitted in partial fulfillment of the requirements for the Master of Science degree will be examined by a committee of at least three Clarkson faculty appointed by the student's department. After approval by the examining committee, the thesis requires signature approval by the dean of the Graduate School, and two copies of the thesis will be deposited in the University library.
To be eligible to receive a degree during Commencement exercises at the end of the spring semester, a student who has submitted a thesis acceptable to the advisor and committee must file the completed final copies with the appropriate School office no later than 10 working days before the Faculty vote to award degrees.
Student failing to perform satisfactorily will be separated from the University upon the request of the department chair and with the concurrence of the dean of the respective School.
Any changes in the student's degree program must be approved by the dean of the School.
Additional graduation requirements may be set by the research advisor or primary department.
Contact Us
For additional information, please contact:
Carmen Camp
Graduate Coordinator, School of Arts & Sciences


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DALLAS — Omar the Barber missed out on a big night of tips. The Dallas Mavericks' beards will keep growing, and perhaps if they're fortunate enough to play for .500 again in the final 10 games of the season, they won't broadcast plans to hold a locker-room shaving party afterward.
Not that the Indiana Pacers needed additional motivation beyond the East's No. 2 seed being up for grabs to get up for Thursday's 103-78 smacking of the Mavs, but they pounced on it anyway.
"That was the message coach [Frank Vogel] said to us coming in," Pacers forward David West said. "Another day for them to do it. It wasn't going to be tonight."
It was 41-41 at halftime and the Mavs' sweaty, scraggly beards that should have had time-elapsed cameras trained on them since their late January inception, were 24 minutes from finally getting out from under them.
"Personally, whatever gimmick they have to do to rally themselves is fine," center Roy Hibbert said in one breath after delivering 16 points 11 rebounds. In the next breath he said, "We wanted to shut that [expletive] down."
The Mavs' beard story has gained a lot of traction recently because of the team's hot streak, riding Dirk Nowitzki's improved play to the cusp of the eighth and final playoff spot. That goal seemed a long shot back when Nowitzki, Vince Carter, Chris Kaman and others took O.J. Mayo's unity idea to heart — no shaving until .500.
So close to breaking even after Tuesday's riveting overtime win against the Los Angeles Clippers, a giddy Mayo, who scored the improbable lefty scoop through a double-team to force OT, said innocently postgame that he's ready to shave. Mayo's barber, Omar — popular with other members of the team, too — would be at the American Airlines Center and ready to get to work.
Nowitzki, who dresses in the locker stall next to Mayo, had said the other night that he preferred not to talk about it for fear of jinxing it. After Thursday's whipping, his hobo-like beard creeping a good half-inch down his neck, Nowitzki was more perturbed at the Mavs' failure to move up the standings than missing out on a shave until at least Tuesday (when Dallas visits the Lakers).
"Knowing the Lakers lost now, we had an opportunity to cut into their lead," Nowitzki said. "And it sucks. It sucks."
Shave talk or not, Nowitzki said the Pacers — who held the Rockets and Mavs on back-to-back nights to 91 and 78 points, and both to under 40 percent shooting — simply beat Dallas every which way in the second half. Indiana's stubborn defense held Dallas to 37 second-half points as the Pacers outrebounded the Mavs 55-34.
"I said I didn't want to jinx it so I didn't really talk about it much. It is what it is," Nowitzki said. "They play well. They come in here and beat us. A team like that, obviously, blatantly brings out our weaknesses, that's why they won. I don't care if they didn't want us to shave or not, but they're a better team."
Dallas (35-37) isn't dead yet, not with the Lakers' walking wounded being just 1 1/2 games ahead in eighth and unpredictable Utah a game ahead in ninth with 10 games to go.
But realistically, Thursday might have been the Mavs' best shot at .500. The defensive fury of the Chicago Bulls arrives for a Saturday afternoon game before a four-game road trip starting with the Lakers. Then comes a back-to-back at Denver and Sacramento and finally, Portland.
The beards will grow even though Carter said the purpose of the pact, to define a clear goal and bring the team together, had served its purpose and is now becoming overblown in the media. He said Mayo's comments about bringing Omar the Barber to the game were taken out of context.
Mayo didn't stick around long enough to discuss it after scoring seven points on 3-for-10 shooting in the loss.
"We only have 10 games left. I'm not going to shave now," Nowitzki said. "We were like six or seven games under .500, had a common goal; just keep pushing see what happens. We have a tough game Saturday against a very good team that just beat Miami. Then we have a tough road trip against some good teams. We've just got to ride it out and see what happens."
West has had his share of physical battles with Nowitzki over the years going back to the 2008 playoffs when West played for New Orleans. After Nowitzki tagged him with an elbow, the two went toe-to-toe and West gave Nowitzki's clean-shaven face a little tap.
They had a brief flare-up as well Thursday night jostling for position. West said he couldn't really describe Nowitzki's matted mass of facial and neck hair.
"I don't know," West said. "It was hairy, I know that."
West then offered his support to Nowitzki and the Mavs in their quest to reach .500. The Pacers have twice done their part to prevent such success with two blowout wins in the season series.
"Hopefully they can get going and get rid of it," West said. "None of them look good."
Omar the Barber is on call.


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Get the Flash Playerto see this player.
|Girls Boarding School
Short review: The members area held up the promises found on the tour pages and then some. These pages are loaded with severe punishment. Whether you enjoy dropping your pants for pain or you'd rather be on the administering side of it all, this website will give you some new material for meat beating. Whether you're a pro with welts and scars or maybe you're just curious about partaking, try the search area.
Content Amount: The amount of content on this website is as never ending as the pain tolerance held onto by these models. Their faces may contort and cringe, and their cries may be loud, but they never waiver from their strict stance of pulsating punishment.


text: Joe Landman wrote: > Peter St. John wrote: >> >> So maybe the ceiling will be (Deliverable FLOPS times Recoverable >> Bytes)/ml > I rather like the Strossian MIPS per kilogram ... :) I am partial to the Bremermann limit: Hans Bremermann's conjecture that "no data processing system, whether artificial or living, can process more than 2 × 10^47 bits per second per gram of its mass." How many Moore doublings until we reach it ... Robert ... ?? rbw -- Richard B. Walsh Project Manager Network Computing Services, Inc. Army High Performance Computing Research Center (AHPCRC) rbw at ahpcrc.org | 612.337.3467 > > "The world is given to me only once, not one existing and one > perceived. The subject and object are but one." > > Erwin Schroedinger ----------------------------------------------------------------------- This message (including any attachments) may contain proprietary or privileged information, the use and disclosure of which is legally restricted. If you have received this message in error please notify the sender by reply message, do not otherwise distribute it, and delete this message, with all of its contents, from your files. -----------------------------------------------------------------------


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Students are at your site to both learn and serve. This is the fundamental difference between Service Learning and volunteerism. It is a tricky balancing act to see both components as equal. But if you think of Service Learning as an academically-focused service program, it will help you to keep both the academic and service goals of the students in mind throughout your involvement with the Program.
Writing Resources for Non-Profit Organizations
Many resources are available here to assist you in creating annual reports, marketing campaigns, employee manuals, applying for grants, etc.
Helpful Hints for Success as Co-Educators
Here are several guidelines for working with Marquette students. We provide this list so that both our Community Partners and our students have the most fulfilling experience from the established partnership.
Important Service Learning Documents
Here you will find an explanation of the Service Learning documents which are most important to Community Partners.
Visit this page to find a list of upcoming important dates for Community Partners, including conferences and seminars.
Our Agency Manual will outline what the Program expects of you as a Community Partner, and what you can expect from us in return.


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Webster's defines romance as trying to influence someone with personal attention, gifts or flattery, but any guy I know would simply explain it as "doing stuff that feels good but isn't sex." Surprisingly, it's not the huge gesture but the one that's tailor-made for your man that will leave him swooning. For example, there was the ex who noticed that I was always reading copies of Sports Illustrated at newsstands, so she surprised me with a subscription. Another old girlfriend, in one of my favorite romantic moves ever, organized a game of Wiffle Ball on my birthday and got a Carvel ice-cream cake (Fudgie the Whale!); she knew I'd had one like it at every party growing up. What else might turn your guy into man mush? I've got a few suggestions.
Get him far, far away from his Wii, his buddies and his boss
For a man, traveling anywhere distant enough that he needs to book a hotel or change the hour on his watch has the same effect as putting on a tuxedo—we get to act like someone else…or at least like a more refined version of ourselves. I once had a good relationship that got an instant upgrade to great after a weeklong vacation in Dublin. And, no, it wasn't the Guinness. Something about the green hills, the castles and the misty air made me want to cuddle and see her in an Irish sweater, and nothing else. It was like falling in love all over again, and we managed to carry the giddiness back home with us.
Don't ask, just do
My brother had been cooped up in his apartment all weekend, working to meet a deadline, when he received a text from his girlfriend: "Look outside yr door." He did, and found a basket of snacks and energy drinks. She was long gone, and when he called to tell her to come back, she refused, saying, "Finish up so we can play later." People always use the "if you need anything let me know" line, but she (literally) delivered. He insists it's the most romantic thing a women has ever done for him.
Wake him up naked
Pretty much nothing in our day beats looking at you in the buff, so imagine the impact when it's the first thing we see. But this is a column about romance, not sex, you say? Believe me, you naked in the morning light is guy-romantic, making us feel all warm and fuzzy. (And then it's true: He will want to have sex.)
Make him feel like a stud
One thing that leaves us chest-thumping like the star of a bad football movie is the belief that we're keeping you happy in bed. So anything you do that affirms this—a compliment here, a trip down sexy memory lane there—is good by us, even if it involves grabbing our butt and using crude language. I told you we were different from you….
Support his little indulgences
I have a friend who lives for the World Cup. He adjusts his work schedule around matches and wears an Italia jersey round-the-clock. His fiancée couldn't care less about any of it. So when she called him to find out how his team had done, he thought she was being sarcastic. But no, turns out his girl had genuinely reached out simply because she knew how much it mattered to him. After some prying on my end, he admitted that her little gesture had struck a major chord: "I'd kind of hidden that part of my life from her; now I can be myself more." Hmm, knowing and accepting each other? Being completely comfortable with your partner? I'm going to say nothing tops that for romance—except doing it all naked.
Jake is a real, live single guy dating in New York City.


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Amazon hasn't yet announced which of the 14 pilots it released last month will be getting series orders, but there's already been one confirmed casualty: "Zombieland."
Co-creator and co-writer Rhett Reese, who also co-wrote the hit film the pilot was based on, took to his Twitter account to break the news to "Zombieland" fans. Though maybe that's not who he wants to speak to right now.
"Our Zombieland series will not be moving forward on Amazon," he wrote. "Sad for everyone involved."
RELATED: Amazon pilots: Part 1 | Part 2 | Part 3
But then he continued: "I'll never understand the vehement hate the pilot received from die-hard Zombieland fans. You guys successfully hated it out of existence."
Despite having a script by the film's original writers and the same producer, as well as some of the same make-up and visual effects people, fans never quite took to the pilot the way they did to the film, which benefited from the performances of Jesse Eisenberg, Woody Harrelson, Emma Stone and, of course, one sweet Bill Murray cameo.
"Zombieland" was one of the 14 pilots Amazon released online, looking for audience feedback as to which should be picked up for a full season. Amazon said it would be looking at the number of streams, how many people watched the entire episode and audience ratings and reviews.
The "Zombieland" pilot averaged 3.7 out of 5 stars based on over 5,000 reviews. The lowest-rated of the comedy pilots, "Browsers," averaged 3.1 stars, while the highest-rated, "Those Who Can't," grabbed 4.4 stars.
Coincidentally, one of the highest profile pilots, "Alpha House," was, like the "Zombieland" film, graced with a Bill Murray cameo.
All hail our smart TV masters, but not just yet
Jon Stewart slams Disney's makeover of 'Brave' heroine Merida
Frank Darabont buries 'Walking Dead,' digs into LAPD cops in TNT drama
Real places, fake characters: TV's bars and eateries
CRITICS' PICKS: What to watch, where to go, what to eat
PHOTOS: Violence in TV shows


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Information for Philosophy Job Applicants
Information for Philosophy Job Applicants
Claremont McKenna College is a private liberal arts college located in Claremont, California, 35 miles east of downtown Los Angeles. For the past four years, we have been ranked eleventh overall among the nation's 266 liberal arts college as measured by U.S. News & World Report. The college has top-tier students and a serious commitment to scholarship.
Scholarly Community: One of the most attractive things about Claremont McKenna College is that it is part of a six-college consortium: five undergraduate liberal arts colleges (Pomona, Claremont McKenna, Scripps, Pitzer, and Harvey-Mudd) and Claremont Graduate University. These colleges are physically contiguous, so your colleagues at other colleges are at most a five-minute walk away. Effectively, then, each of us has about 20 colleagues in philosophy, so we combine the faculty size of a large research university and the intimacy of a small liberal-arts college. There is more information about the five-college resources here.
Scholarship: Both the College and the Department of philosophy are committed to serious scholarship. You can get an idea of our research interests and publication records by looking at the faculty page. Current faculty have published in such journals as Philosophy and Phenomenological Research, Ethics, The Australasian Journal of Philosophy, Philosophers' Imprint, Philosophical Studies, Mind, The Journal of the History of Philosophy, Philosophical Quarterly, Oxford Studies in Ancient Philosophy, and American Philosophical Quarterly; we have published books with Oxford University Press.
Teaching: At Claremont McKenna faculty are given the opportunity to for serious engagement with their students. The teaching load is 2-2, courses are almost always capped at 19, and many classes are even smaller. Our students are among the best in the nation. 85% are in the top 10% of their graduating class, and their median SAT scores are 1410.
Location: The town of Claremont is close to downtown Los Angeles but far enough east that it doesn't suffer from the problems (e.g., traffic problems) of a large city. Claremont itself is a pleasant college town. The thing people like least is the smog and accompanying heat, which for about a month each summer reaches the 100's. (Though without humidity.) The town has plenty of benefits that compensate for the heat. You enjoy the ability to travel to Los Angeles for major cultural sites such as the many Los Angeles art museums, the philharmonic, and the Los Angeles Opera. The town is also good for people who love the outdoors, since we are situated at the base of a 10,000 foot mountain with wonderful hiking. The best thing about the location may be the almost-constant California sunshine.


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Cameos are the jewelry I'd like to share. Even though my father was a jeweler, we females of the family didn't own or wear much jewelry. My mom and I both had lockets. I suppose my sister did, too, but I don't remember. My mother had several rings, including her engagement and wedding rings, a single strand of pearls, some earrings that she wore frequently, and these cameos. She had other jewelry but none that is memorable.
The large brooch is about an inch and a quarter long. I didn't measure the others but you can guess their size from the photo. The metal on the large cameo was repaired at some time in the past and it looks like it needs a repair again. It was interesting to photograph these then enlarge the photos to see so much detail. (You can enlarge the photo, too, by clicking on it. It will open in a new screen and be larger, then enlarge again if you click on it in the new screen.)
As I was researching cameos today I learned that I have not been as kind as I could have been to these. They have been together in a fabric holder but because they are susceptible to scratches and breakage they should be carefully stored either laying in their own places without touching other pieces or gently wrapped in fabric. I also learned that they can be cleaned with white toothpaste and a soft toothbrush. Because the shells dry out, they also need to be conditioned a few times a year with baby or mineral oil left on overnight and removed with a soft cloth.
I love these cameos but they've been hiding away and I rarely look at them. Maybe I should find a small shadow box so I could display and enjoy them.
This post is a contribution to Alona Tester's Family History Through the Alphabet challenge. You can read more about the challenge and find links to others' posts at her blog, Genealogy and History News. Thanks, Alona.
Thursday, April 4, 2013
J is for Jewerly - Family History Through the Alphabet
2 comments:
Nice Nancy. I gather you don't know where they came from or how old they are. You definitely displayed them nicely. Thanks.ReplyDelete
This is a great word for J. I'm doing the A-Z challenge and I think I may borrow this idea for day after tomorrow. whew! Enjoyable post. I had no idea that cameos needed to be stored so carefully, not that I have any.ReplyDelete
I appreciate your comments and look forward to reading what you have to say. Thanks for stopping by.
Subscribe to: Post Comments (Atom)


text: > > why do you think there's some OS specificity? afaikt, the results > > would be reflected in SMART, which is most definitely available under Linux. > > i may be misunderstanding... is there a way of logging this under linux > > (software package, kernel patch?) or is this simply a bios-type message > > that will go into syslog automatically? huh? smartsuite contains smartd which queries your smart-capable drives and logs changes in parameters to syslog. I don't know why you call this "bios-type" though, since bios and syslog never meet. the kernel is only ah, peripherally involved. > i've done a search for smart and linux and found very little. hmm, of the top 4 hits for "smart linux disk" on google, I get three relevant sites. here's the tar: http://www.linux-ide.org/smart/smartsuite-2.1.tar.gz as far as I know, smartctl's self-test controls give you the equivalent of IBM's DFT. regards, mark hahn.


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Norwestent needed a new logo design and created a contest on 99designs.
A winner was selected from 118 designs submitted by 22 freelance designers.
Sydney Acoustic Neuroma and Meningioma Institute (SANAMI)
A collaboration of 5 brain surgeons and 2 ear, nose the throat surgeons forming sydney's most comprehensive team for managing complex brain tumours and brain problems. We are team of clinicians, all super speciality trained surgeons, who are trained to manage complex brain tumours and problems using the latest minimally invasive techniques in Australia's premier private hospital. We are seeking to create a contemporary corporate identity that has clean lines and direct colours.
Informed Patients (who are searching the internet by diagnosis eg, acoustic tumour, meningioma, brain tumour), general practitioners (family physicians), other ear nose and throat surgeons, other neurosurgeons.
This audience likely is a patient, or has a patient with a specific brain condition. They are searching the internet to find information regarding their tumour or brain condition and we will be the premier website and location to have their treatment in Australia.
We are targeting sydney, then new south wales (state), then australia as well as asia pacific and middle east. We will be the premier location for contemporary, high quality care with excellent surgical outcomes.
Our corporate identity has to reflect clean precise lines, but also convey the fact that we are managing brain problems.
Our previous logos http://www.norwestent.com; http://www.northsidehearing.com.au illustrate the style we like. We are after clean precise lines (to reflect our clean and precise surgery). Please feel free to have artistic licence over corporate colours and font, but we would like a contemporary font family to reflect our modern unit and the number of colours should be kept to a minimum please.
The hospital in which we work is considered one of australia's largest and most premium locations (north shore private), it is where our heads of government, VIPs and movie stars, have their hospital stays.
We are positioning ourselves as Australia's premier team based approach to the management of brain tumours.
Thanks in advance for your efforts and good luck with the competition!
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