Mike, along with his two partners, Steve Garnier and John Doran, owns Epilog Laser, a company taking firm aim at the woodworking market. Although large shops and specialized manufacturers have been using lasers to cut wood for some time, Epilog is working to put that technology within our grasp.
The Zing, a model which came out earlier this year, is a compact, relatively inexpensive but fully featured unit aimed at first-time laser owners, making it perfect for small businesses and high-end hobby woodworkers. "We sell to a lot of hobby woodworkers," Mike told me. "We'd like to see them in more shops, and for that reason, we go to most of the woodworking shows. You've probably seen us there.
The company was incorporated in 1988 by Mike's partners, Steve and John, both electrical engineers from Georgia Tech. John built a laser in his basement while in his 20s, just to see if he could do it. Steve worked at Melco Industries doing motion control, so they decided to pool their talents to make a laser that moved around. When Steve found himself downsized while they were working on their second generation laser, they decided to create their own company. They felt that as two engineers, they needed a business partner, so Mike Dean became the third owner. They came up with the name Epilog, and the company was born.
"Today, Epilog has some 70 employees," Mike told me, "as well as independent distributors throughout the world in about 50 countries. Situated in the foothills of the Rocky Mountains in Golden, Colorado, we occupy a 35,000 square foot facility designed specifically for what we do. All our lasers are made right here in the U.S.
"We manufacture two types of laser systems. Our fiber laser, so-called because the laser is developed in an optical fiber, is used almost exclusively for metal and plastic marking. All the rest of our products are CO2 lasers, and they encompass about 94 percent of our product output. These are ideal for wood. They range in price from $8,000 to $50,000 with prices based primarily on work area and laser wattage.
"At the bottom end, the Zing has a 16- by 12-inch table and a 25-watt laser. At the upper end is a 36- by 24-inch table with 120-watt laser. Laser wattage, as far as wood is concerned, translates only into speed. The higher the wattage, the faster the cut, but any machine will do any job. The smaller ones simply take longer.
"The laser beam is invisible, so watching it cut is fascinating. You can see where it contacts the material, but not the beam itself. Because the beam can both burn you and damage your eyes, we always keep it in an enclosed cabinet for safety reasons.
"Each machine works in two distinctly different modes, both similar to two primary types of computer printers. The plotter mode follows vector lines, and is best for cutting all the way through wood. The raster mode produces one line at a time, like most desktop inkjet printers, and is best for thicker, shallower lines, like engraving text or surface graphics. You set all the laser parameters the same way you set up paper orientation and print quality. Instead of a printer depositing ink on paper, the laser burns away a spot of wood. You can run raster, vector or a combination of the two in one job.
When I asked about the wide price disparity in the field of lasers, Mike had some interesting insights to offer. "There are several companies that manufacture similar systems here in the U.S, in Europe and in Asia. One of the technologies imported from China is a glass tube laser. While they are similar, their capabilities are limited, and the tubes don't hold up nearly as long as the metal tubes we use. Glass tubes are throwaway and only last for a few months, while our metal tubes last for five years or more, at which point they merely need to be recharged to keep working. The image quality is also significantly poorer with glass tubes.
You know, I think I could make room in my shop for a laser before Father's Day rolls around. Perhaps it's time to start dropping hints.


High Frazil is a Skill in Dragon's Dogma.
"An advanced form of Frazil that creates an expanded field of cold around the user that deals ice damage to those it touches."
While held, it is an AOE attack that does not deal any damage, but has a chance of Freezing enemies.
The AOE zone is bigger than Frazil.
You may move around while holding the zone of "cold". However this uses stamina and the skill will cancel if you run out of stamina.
When released, enemies targetted are frozen and the attack also deals moderate Frost damage (magickal) to any enemies caught in the frontal cone area.
The released "wave" does twice as much damage as Frazil.
While frozen, the enemies are quasi-staggered, in that they are vulnerable to physical attacks from other party members and their attacks may be interrupted by the Freezing.
Most effectively used as a "cast and blast" attack to stunlock enemies while having your party members swoop in for the bigger hits.


We have been masterplanners at Thorpe Park since its acquisition by Merlin and have been involved with the design of all the major projects since then. The park is surrounded by lakes, the result of gravel working in the past. They are important for wildlife and the lakes to the south-west are part of a Site of Special Scientific Interest.
The last masterplan sought to create more land and to increase wildlife habitats by making islands in one of the lakes which has given increased shelter to the whole site. At the same time the area of floodplain has been increased to help alleviate flooding in the area. The masterplans run over five and ten year time frames and include a variety of attractions which will allow the park to evolve and satisfy its public.
We have been involved in all the major projects at the park since 1990 which have included six rollercasters, a dark ride and a hotel.


text:
/*
 * To change this license header, choose License Headers in Project Properties.
 * To change this template file, choose Tools | Templates
 * and open the template in the editor.
 */
package views;

import crud.UsuarioCRUD;
import database.DatabaseFactory;
import domain.Usuario;
import java.sql.Connection;
import java.util.Arrays;
import java.util.logging.Level;
import java.util.logging.Logger;
import javax.swing.JOptionPane;

/**
 *
 * @author victor alves abreu
 */
public class FrmUsuario extends javax.swing.JFrame {

    /**
     * Creates new form FrmUsuarioFrame
     */
    boolean edit;

    public FrmUsuario() {
        initComponents();
        edit = false;
    }

    public FrmUsuario(int id){
        initComponents();
        UsuarioCRUD usuarioCRUD = new UsuarioCRUD();
        Connection conn = DatabaseFactory.getDatabase("postgres").connect();
        try {
            Usuario user = usuarioCRUD.read(conn, id);
            tfId.setText(Integer.toString(user.getId()));
            tfNome.setText(user.getNome());
            tfCargo.setText(user.getCargo());
            tfEmail.setText(user.getEmail());
            tfCpf.setText(user.getCpf());
            cbAcesso.setSelectedItem(user.getAcesso());
            pfSenha.setText(user.getSenha());
            edit = true;
        } catch (Exception ex) {
            Logger.getLogger(FrmUsuario.class.getName()).log(Level.SEVERE, null, ex);
        }finally{
            DatabaseFactory.getDatabase("postgres").disconnect(conn);
        }

    }

    /**
     * This method is called from within the constructor to initialize the form.
     * WARNING: Do NOT modify this code. The content of this method is always
     * regenerated by the Form Editor.
     */
    @SuppressWarnings("unchecked")
    // <editor-fold defaultstate="collapsed" desc="Generated Code">//GEN-BEGIN:initComponents
    private void initComponents() {

        btCadastrar = new javax.swing.JButton();
        btSair = new javax.swing.JButton();
        pnPrincInfo = new javax.swing.JPanel();
        lbEmail = new javax.swing.JLabel();
        lbSenha = new javax.swing.JLabel();
        tfNome = new javax.swing.JTextField();
        tfEmail = new javax.swing.JTextField();
        cbAcesso = new javax.swing.JComboBox<>();
        tfId = new javax.swing.JTextField();
        lbId = new javax.swing.JLabel();
        lbNome = new javax.swing.JLabel();
        pfSenha = new javax.swing.JPasswordField();
        lbCpf = new javax.swing.JLabel();
        tfCpf = new javax.swing.JTextField();
        lbCargo = new javax.swing.JLabel();
        tfCargo = new javax.swing.JTextField();

        setDefaultCloseOperation(javax.swing.WindowConstants.DISPOSE_ON_CLOSE);
        setTitle("Cadastrar Usuario");
        setResizable(false);

        btCadastrar.setText("Cadastrar");
        btCadastrar.addActionListener(new java.awt.event.ActionListener() {
            public void actionPerformed(java.awt.event.ActionEvent evt) {
                btCadastrarActionPerformed(evt);
            }
        });

        btSair.setText("Sair");
        btSair.addActionListener(new java.awt.event.ActionListener() {
            public void actionPerformed(java.awt.event.ActionEvent evt) {
                btSairActionPerformed(evt);
            }
        });

        pnPrincInfo.setBorder(javax.swing.BorderFactory.createEtchedBorder());

        lbEmail.setText("Email");

        lbSenha.setText("Senha");

        cbAcesso.setModel(new javax.swing.DefaultComboBoxModel<>(new String[] { "user", "admin" }));

        tfId.setEnabled(false);

        lbId.setText("Id");

        lbNome.setText("Nome");

        javax.swing.GroupLayout pnPrincInfoLayout = new javax.swing.GroupLayout(pnPrincInfo);
        pnPrincInfo.setLayout(pnPrincInfoLayout);
        pnPrincInfoLayout.setHorizontalGroup(
            pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
            .addGroup(pnPrincInfoLayout.createSequentialGroup()
                .addContainerGap()
                .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
                    .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
                        .addGroup(pnPrincInfoLayout.createSequentialGroup()
                            .addComponent(lbEmail)
                            .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.RELATED, javax.swing.GroupLayout.DEFAULT_SIZE, Short.MAX_VALUE)
                            .addComponent(tfEmail, javax.swing.GroupLayout.PREFERRED_SIZE, 202, javax.swing.GroupLayout.PREFERRED_SIZE))
                        .addGroup(pnPrincInfoLayout.createSequentialGroup()
                            .addComponent(lbNome)
                            .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.RELATED, javax.swing.GroupLayout.DEFAULT_SIZE, Short.MAX_VALUE)
                            .addComponent(tfNome, javax.swing.GroupLayout.PREFERRED_SIZE, 202, javax.swing.GroupLayout.PREFERRED_SIZE)))
                    .addGroup(pnPrincInfoLayout.createSequentialGroup()
                        .addComponent(lbSenha)
                        .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.UNRELATED)
                        .addComponent(pfSenha, javax.swing.GroupLayout.PREFERRED_SIZE, 202, javax.swing.GroupLayout.PREFERRED_SIZE)))
                .addGap(47, 47, 47)
                .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
                    .addGroup(pnPrincInfoLayout.createSequentialGroup()
                        .addComponent(lbId)
                        .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.RELATED)
                        .addComponent(tfId, javax.swing.GroupLayout.PREFERRED_SIZE, 53, javax.swing.GroupLayout.PREFERRED_SIZE))
                    .addComponent(cbAcesso, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE))
                .addGap(12, 12, 12))
        );
        pnPrincInfoLayout.setVerticalGroup(
            pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
            .addGroup(pnPrincInfoLayout.createSequentialGroup()
                .addContainerGap()
                .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
                    .addGroup(pnPrincInfoLayout.createSequentialGroup()
                        .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.BASELINE)
                            .addComponent(tfId, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE)
                            .addComponent(lbId))
                        .addGap(31, 31, 31)
                        .addComponent(cbAcesso, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE))
                    .addGroup(pnPrincInfoLayout.createSequentialGroup()
                        .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.BASELINE)
                            .addComponent(lbNome)
                            .addComponent(tfNome, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE))
                        .addGap(14, 14, 14)
                        .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.BASELINE)
                            .addComponent(lbEmail)
                            .addComponent(tfEmail, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE))
                        .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.UNRELATED)
                        .addGroup(pnPrincInfoLayout.createParallelGroup(javax.swing.GroupLayout.Alignment.BASELINE)
                            .addComponent(lbSenha)
                            .addComponent(pfSenha, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE))))
                .addContainerGap(30, Short.MAX_VALUE))
        );

        lbCpf.setText("Cpf:");

        lbCargo.setText("Cargo:");

        javax.swing.GroupLayout layout = new javax.swing.GroupLayout(getContentPane());
        getContentPane().setLayout(layout);
        layout.setHorizontalGroup(
            layout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
            .addGroup(layout.createSequentialGroup()
                .addContainerGap()
                .addGroup(layout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
                    .addGroup(layout.createSequentialGroup()
                        .addComponent(lbCpf)
                        .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.RELATED)
                        .addComponent(tfCpf, javax.swing.GroupLayout.PREFERRED_SIZE, 145, javax.swing.GroupLayout.PREFERRED_SIZE)
                        .addGap(36, 36, 36)
                        .addComponent(lbCargo)
                        .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.UNRELATED)
                        .addComponent(tfCargo, javax.swing.GroupLayout.PREFERRED_SIZE, 136, javax.swing.GroupLayout.PREFERRED_SIZE)
                        .addContainerGap(javax.swing.GroupLayout.DEFAULT_SIZE, Short.MAX_VALUE))
                    .addGroup(javax.swing.GroupLayout.Alignment.TRAILING, layout.createSequentialGroup()
                        .addGap(0, 0, Short.MAX_VALUE)
                        .addComponent(pnPrincInfo, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE)
                        .addContainerGap())))
            .addGroup(layout.createSequentialGroup()
                .addGap(118, 118, 118)
                .addComponent(btCadastrar)
                .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.RELATED)
                .addComponent(btSair, javax.swing.GroupLayout.PREFERRED_SIZE, 91, javax.swing.GroupLayout.PREFERRED_SIZE)
                .addGap(0, 0, Short.MAX_VALUE))
        );
        layout.setVerticalGroup(
            layout.createParallelGroup(javax.swing.GroupLayout.Alignment.LEADING)
            .addGroup(javax.swing.GroupLayout.Alignment.TRAILING, layout.createSequentialGroup()
                .addContainerGap(javax.swing.GroupLayout.DEFAULT_SIZE, Short.MAX_VALUE)
                .addGroup(layout.createParallelGroup(javax.swing.GroupLayout.Alignment.BASELINE)
                    .addComponent(lbCpf)
                    .addComponent(tfCpf, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE)
                    .addComponent(lbCargo)
                    .addComponent(tfCargo, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE))
                .addPreferredGap(javax.swing.LayoutStyle.ComponentPlacement.UNRELATED)
                .addComponent(pnPrincInfo, javax.swing.GroupLayout.PREFERRED_SIZE, javax.swing.GroupLayout.DEFAULT_SIZE, javax.swing.GroupLayout.PREFERRED_SIZE)
                .addGap(18, 18, 18)
                .addGroup(layout.createParallelGroup(javax.swing.GroupLayout.Alignment.BASELINE)
                    .addComponent(btCadastrar)
                    .addComponent(btSair))
                .addContainerGap())
        );

        pack();
    }// </editor-fold>//GEN-END:initComponents

    private void btCadastrarActionPerformed(java.awt.event.ActionEvent evt) {//GEN-FIRST:event_btCadastrarActionPerformed
        UsuarioCRUD usu = new UsuarioCRUD();
        Connection conn = DatabaseFactory.getDatabase("postgres").connect();
        try {
            Usuario usuario = new Usuario();

            usuario.setAcesso(cbAcesso.getSelectedItem().toString());

            if (edit) {
                usuario.setId(Integer.parseInt(tfId.getText()));
            }

            usuario.setNome(tfNome.getText());
            usuario.setEmail(tfEmail.getText());
            usuario.setSenha(pfSenha.getText());
            usuario.setCpf(tfCpf.getText());
            usuario.setCargo(tfCargo.getText());
            if (edit) {
                usu.update(conn, usuario);
            } else {
                usu.create(conn, usuario);
            }

            DatabaseFactory.getDatabase("postgres").disconnect(conn);
            this.dispose();
        } catch (Exception ex) {
            JOptionPane.showMessageDialog(this, ex);
        }
    }//GEN-LAST:event_btCadastrarActionPerformed

    private void btSairActionPerformed(java.awt.event.ActionEvent evt) {//GEN-FIRST:event_btSairActionPerformed
        this.dispose();
    }//GEN-LAST:event_btSairActionPerformed

    /**
     * @param args the command line arguments
     */
    public static void main(String args[]) {
        /* Set the Nimbus look and feel */
        //<editor-fold defaultstate="collapsed" desc=" Look and feel setting code (optional) ">
        /* If Nimbus (introduced in Java SE 6) is not available, stay with the default look and feel.
         * For details see http://download.oracle.com/javase/tutorial/uiswing/lookandfeel/plaf.html
         */
        try {
            for (javax.swing.UIManager.LookAndFeelInfo info : javax.swing.UIManager.getInstalledLookAndFeels()) {
                if ("Nimbus".equals(info.getName())) {
                    javax.swing.UIManager.setLookAndFeel(info.getClassName());
                    break;
                }
            }
        } catch (ClassNotFoundException ex) {
            java.util.logging.Logger.getLogger(FrmUsuario.class.getName()).log(java.util.logging.Level.SEVERE, null, ex);
        } catch (InstantiationException ex) {
            java.util.logging.Logger.getLogger(FrmUsuario.class.getName()).log(java.util.logging.Level.SEVERE, null, ex);
        } catch (IllegalAccessException ex) {
            java.util.logging.Logger.getLogger(FrmUsuario.class.getName()).log(java.util.logging.Level.SEVERE, null, ex);
        } catch (javax.swing.UnsupportedLookAndFeelException ex) {
            java.util.logging.Logger.getLogger(FrmUsuario.class.getName()).log(java.util.logging.Level.SEVERE, null, ex);
        }
        //</editor-fold>
        //</editor-fold>

        /* Create and display the form */
        java.awt.EventQueue.invokeLater(new Runnable() {
            public void run() {
                new FrmUsuario().setVisible(true);
            }
        });
    }

    // Variables declaration - do not modify//GEN-BEGIN:variables
    private javax.swing.JButton btCadastrar;
    private javax.swing.JButton btSair;
    private javax.swing.JComboBox<String> cbAcesso;
    private javax.swing.JLabel lbCargo;
    private javax.swing.JLabel lbCpf;
    private javax.swing.JLabel lbEmail;
    private javax.swing.JLabel lbId;
    private javax.swing.JLabel lbNome;
    private javax.swing.JLabel lbSenha;
    private javax.swing.JPasswordField pfSenha;
    private javax.swing.JPanel pnPrincInfo;
    private javax.swing.JTextField tfCargo;
    private javax.swing.JTextField tfCpf;
    private javax.swing.JTextField tfEmail;
    private javax.swing.JTextField tfId;
    private javax.swing.JTextField tfNome;
    // End of variables declaration//GEN-END:variables
}

redpajama_set_name: RedPajamaGithub


-WOW! .54 Acre lot available in the "Summit" subd. just off Buffalo Lake rd. in Harnett county! Very convenient to desired Highland Elem. and Western Harnett High Schools and just a walk across the street to Groceries, shopping, dining & more! Fantastic corner lot to have your new home built on! Neighbors on one side only! Great location to Ft. Bragg, Sanford,Lillington, Raleigh or Southern Pines.
-WOW! .54 Acre lot available in the "Summit" subd. just off Buffalo Lake rd. in Harnett county! Very convenient to desired Highland Elem. and Western Harnett High Schools and just a walk across the street to Groceries, shopping, dining & more! Fantastic corner lot to have your new home built on! Neighbors on one side only! Great location to Ft. Bragg, Sanford, Raleigh or Southern Pines.
-Gated, Golfing,Lake, Pool & Tennis Community! Nice Residential lot that is waiting for you. In a community with pool, tennis, golfing, gated and lake.


text:
ALERT: Massive New Migrant Group On It's Way To America That Contains The "World's Poor"
Posted By: Dino Porrazzo July 9, 2019
Posted by Dean James at Right Wing Tribune
Immigration group says next massive 'influx of migrants' to U.S. already coming from 'entire world's poor'
By JonDougherty
Just as the Trump administration, with Mexico's help, appears to be getting a handle on the influx of mostly poor migrants from Central America, a new wave is set to besiege U.S. borders — poor from around the world.
According to an analysis by Todd Bensman of the Center for Immigration Studies (CIS), tens of thousands of "exotics" and "extra-continentals" are currently moving towards the United States through Panama.
"Like the proverbial 'bulge in the belly of the snake,' unusually high numbers of non-Latino migrants, obviously not from Central America, are now reportedly passing from Colombia through Panama on their way to the U.S. southern border," Bensman, the center's national security fellow, writes.
"Their numbers range to the tens of thousands, whose vanguards we have already seen at the U.S. Southwest Border in recent months: Cameroonians, Ghanaians, Congolese, Haitians, Cubans, and some from the Middle East," he added.
Bensman, who gleaned his information from sources who returned recently from the region, said that word has reached around the globe that getting into the United States has become administratively easier given the current loopholes in asylum laws that Democrats refuse to help the Trump administration fix.
Those witnesses — Panama-based author and freelance journalist Chuck Holton and Diane Edrington, a Mississippi-based nurse practitioner who has worked for years as a Panama Missions volunteer — report "that a surge is underway the likes of which neither has ever seen and which obviously surpasses what I witnessed in December."
He added that Holton and Edrington both "saw massive numbers of Africans overwhelming government camps and smuggling infrastructure as they push through to repeat the successes at the U.S. border of those who have gone before them."
Meanwhile, officials in Colombia and Panama are reporting that "many thousands have gone through" in recent weeks and are "already in the pipeline" heading for the U.S.:
"'Trump wants to keep us out, but he can't do it,'" Holton said he was repeatedly told in Turbo, Colombia as African migrants were preparing to board boats to the jungle trails for 10-day, smuggler-led wilderness treks into Panama. "They were very clear about that. 'If I can get in now, I'm going to get while the getting's good.'"
Holton said everyone knew to go to American "sanctuary cities," where local authorities won't cooperate with Immigration and Customs Enforcement.
"They have some level of understanding of what a sanctuary city is. 'If we can get to one of those they won't mess with us; They won't get us out.'"
"A lot of these guys obviously do not qualify for asylum," Holton told me. "When they talk to me, they don't have a problem telling me it's for economic benefits, to get a better job, to have a better life."
No matter, Holton said. By claiming asylum, "They know they'll have to let them into the U.S. and that they can stay for at least three years" before any ruling on their claims comes back. "They're very clear on that."
Officials in the region estimate that as many as 35,000 people are already enroute, with more coming. Many are stricken with ailments and diseases, according to the CIS report.
This article originally appeared at The National Sentinel and was republished with permission.
BREAKING News Out Of MEXICO
Biden Gets "Smacked Down" After Straight Up Lying And Then Gets Rocked By The Truth
Alert: Smugglers From Mexico Are Using Technology To Monitor Border Patrol And It's Time We Take Action On Them NOW
BREAKING: Mexico Deports Over 300 Indians Illegally In Country

redpajama_set_name: RedPajamaCommonCrawl


How to Cut Porcelain Tile Using a Wet Saw - So That's How You Do That!
Joe, I need to know how to cut porcelain tile, should I use a wet saw? This is a question I am asked all the time. A wet saw is probably the most expensive tool that you can buy, at least one of the most expensive! The only other alternative is a tile cutter. These are also expensive and the price can add up quick!
I'm really not talking about a tile cutter that you can buy at a home improvement store. I'm talking about a good, high quality tile cutter. Although, Home Depot has finally stepped up their game and got rid of most of their junk cutters.
They now have Rubi tile cutters. These are a really good Brand of cutters. That's the Brand I use. The price tag they have on them, well they are really good too. I would say they have done a good thing for the DIY'er looking to buy a tile cutter.
I love my tile cutter and it is what I use the most. But if you ask me how to cut porcelain tile I'm going to say use a wet saw.
If you are installing ceramic tile, porcelain, glass or stone, you can use a wet saw without ever changing the blade. A tile cutter has many different types of cutting wheels. I have them all, because you never know which one is going to work. Sometimes none of them work!
That's when I pull out my wet saw. The cutting wheels can be expensive. If you rent a tile cutter, it probably has a cutting wheel that should have been thrown away last year.
I believe that I need to point you in the right direction on how to cut porcelain tile or any tile. I would say a wet saw is the best tool for you to use. I do like my tile cutter because it's faster, I can use it anywhere and it's just more convenient.
But we are talking about the most user friendly cutting tool, so I choose a wet saw! I do want to say though, that not all wet saws are created equal. I have used some junk wet saws and it would be hard for me to tell you if the wet saw you are renting is worth renting or not.
I just want to say that if you have a big project that you are working on, you might want to consider buying a wet saw. The money you spend on renting might be close to what you would pay for one. Here is a link to a saw I think would be a great saw.
I know it's expensive! I'm really not telling you to buy it, if it doesn't make sense. If you have a custom shower to install, chances are that it would be a minimum of $2000.00 just for installation. Let me be clear, I do not make any money from this link I am sharing. I have a Dewalt tile saw that costed me over a $1000.00. I really wanted to be able to recommend a saw that was more reasonable in price.
So I went to Home Depot and bought the saw that you see in the link above. I wanted to test it before I recommended it to you. I have used it for over a year now and it's really a good saw!
What if you did buy it? You could sell it when you are done with it on Craigslist or Ebay. I'm sure you could get your money back. Okay enough on that let me show you why I like this saw.
When you are wondering how to cut porcelain tile or any tile, what type of cuts are you thinking of?
You can cut all of these types of cuts on a wet saw. It has to be able to plunge cut though. Take a look at this video and I'll show you what I mean.
The wet saw is really the key when asking how to cut porcelain tile. I really do think a wet saw will save you a lot of frustration when installing ceramic tile, porcelain, glass and natural stones.
I hope this helps you with your installation. Any comments below would really help me out, so please leave one.
I also have another post that I wrote about how to cut porcelain tile. I show three more cutting methods. Here is a link to it (Click Here).
Thanks for getting back to me so quick. Sorry to bother you with this again, but would you rather use a 7″ 9amp saw from the link on your page or a 8″ 12amp saw that Ridgid also offers for $200 more.
I appreciate all your info. I just want to make sure which saw your using. The link showed model 4030 for $297, you mentioned you payed $500. Are you using model 4040? Do you think it's worth $200 more for the 4040?
I also apppreciate and agree with your faith in God statement.
That is the saw! It has just come down in price since I shot that video. Thank you for your comments!
I much prefer using a wet saw for cutting tile than any other method. It is just so much easier, and that is all that really needs to be said. If you have a big project then rent a wet saw or get your own, you won't regret it. However, I am curious about the blade. You said you don't ever have to change it when cutting ceramic tile, porcelain, glass or stone. So, do most wet saws have diamond tipped blades?
I agree totally on the saw. Yes I do use a diamond blade. Honestly I usually toss the blade that would come with the saw. Dewalt has a blade that cuts most everything that I use and I highly recommend it.
Thanks Joe for the great info. Im still not sure though what is best way to 'rip' a 24×12 tile? can i do this with a basic table saw? my concern is there is not a lot of table surface in front of the blade and it seems difficult to get a straight cut trying to feed that 24″ tile thru. am i better off putting a diamond blade in my 71/2 circular saw?
also … if you have to taper the 24″ tile (for the last piece next to a wall)… ie take a long triangular 'sliver' off the 24″ side. not sure how to do that with a table saw?
You can rent a saw that will do all of those things. The saw I am using in the video will cut a 24″ tile and the head plunges and it can be tilted to cut a beveled edge. Home Depot probably rents a saw capable of that.
Great how to videos. I'm about to start a tile job (laundry room) and was worried about using a tile cutter on the porcelain tile. I have a lot of cross cuts.
I do have a wet saw (cheap one, but bought a good blade) and will use for the long cuts. tile is 6×24.
Great help from you. I like your explanations as it really ma keys it easy to understand for the diy'er.
Your instructions were very helpful. I watched your video on the angle grinder for the toilet flange. Not sure I'm ready for that! Do you have any advice for making a somewhat circle with the wet saw?
Just take your time. It would need to be a saw that can plunge cut.
Just what I needed to see. We have purchased porcelain tile after a disaster with marble that was free. I have many curved cuts around the flange and the bathtub as well and an angle grinder is what I will purchase. Good info and well presented.
Thank you so much for these detailed instructions and reviews. Would you be able to provide the name of the wet saw that you recommend? The link no longer works.
The link is once again live!


A two-day validation workshop on Market Assessment of Solar PV Small-Scale Distributed Generation (SSDG) under the Global Environment Facility project entitled "Removal of Barriers to Solar PV Power Generation" in Mauritius, Rodrigues and Outer Islands, opened yesterday at the Ravenala Attitude Hotel in Baie aux Tortues, Balaclava.
The Minister also pointed out that electricity consumption in Mauritius has been increasing with the advent of technology and rapid economic growth. It is fundamental for the country to increase its electricity production through sustainable methods so as to keep pace with the new economic challenges and sustainable development, he said. Mauritius needs to make use of efficient and low cost production energy and decrease the use of non renewable energy so as to increase the renewable energy proportion of the country's production mix to 35% by 2025, he indicated.
Furthermore, Minister Boissézon emphasised Government's commitment in seeking new ways to change the energy production and utilisation model, thus contributing to modern energy systems for the promotion of harmonious development of energy, the economy and sustainable environment.
For his part, CEB's Acting General Manager, Mr Mukoon, recalled that following the launch, in 2009, of the Long Term Energy Strategy 2009-2025, Government in 2010, with the support of United Nations Development Programme, initiated the SSDG Scheme with a view to help Mauritius achieve the target 2% of electricity generation from on-grid PV by 2025.


These Devons are retired from show and/or breeding here at Facehuggers Devon Rex.
RW Facehuggers Dosiedotes, dob 3/9/09, mom is Facehugger's Lambsie D'Ivy, dad is Facehuggers Jules Winnfield. She has earned her SGC in TICA and her Grand in CFA!
DD is now a spay and I will consider a local home for her.
!! OMG !! I just found these pics of DD on a CD from Tetsu, can't believe I hadn't opened them!
DD earning the Best Kitten of the Best Litter in Chehalis!
You can also see rescues at this link. Rescue Devons!


This programme builds on principles of law studied in the first part of the course, English Legal System 1. It runs in Semester 2 and is designed to examine more closely certain aspects of both the criminal and civil justice systems.
To provide students with an insight into the workings of the criminal and civil justice systems, building on knowledge gained during the ELS1 course and examining in detail many area of controversy in both systems. Students are encouraged to develop a critical approach to understanding the issues raised and there will be scope to evaluate the effect of any recent changes in both criminal and civil justice policy as well as any proposals for further reform.
the institutions, structures and rationale of the English Legal System within the context of the law of England and Wales, as well as its relation to other legal systems especially the EU and ECHR.
demonstrate critical awareness of the wider political and social contexts of the law, the principles and values underpinning these and their implications for legal decision making and enforcement.
construct and defend an argument and communicate it both orally and in writing.
1. Police powers in the investigation of crime. 2. The accountability of the police. 3. The role of the Crown Prosecution Service. 4. Plea Bargaining. 5. Jury trials. 6. Sentencing policy. 7. The role of the prisons in the criminal justice system. 8. Reform of the civil justice system. 9. Alternatives to formal legal action in the resolution of disputes.
The course comprises one weekly lecture and one weekly tutorial. Lectures comprise the background of the particular subject to be studied. A handout of material is provided each week at the start of the lecture and placed on Blackboard after it. A tutorial on the relevant topic is held following the lecture. Students will have been alerted to specific issues to be addressed and given appropriate reading either from the prescribed textbook, other recommended books or articles from academic journals. Teaching methods include: One lecture and one tutorial per week, offering an opportunity for detailed discussion of specific question relating to the broader issues covered by the lectures. Both the lecture and tutorial provide an opportunity for you to ask questions. Learning activities include: Attendance at lectures and tutorials is compulsory. Contribution to the content of both is encouraged, interruptions during the lectures for questions or comments are welcomed. Tutorials include group and individual analysis of specific topics which are then discussed by the whole group.
Huxley-Binns and Martin (2017). Unlocking the English Legal System.
Slapper, G and Kelly, D (2018). The English Legal System.


text:
Internal Revenue Bulletin: 2011-14
Rev. Rul. 2011-10
T.D. 9515
Announcement 2011-25
Rev. Rul. 2011-10 Rev. Rul. 2011-10
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for April 2011.
T.D. 9515 T.D. 9515
Final and temporary regulations under section 1502 of the Code relate to the redetermination of intercompany gain as excluded from gross income. Temporary regulations under section 1.1502-13T are reissued.
Proposed regulations under section 6103(c) of the Code extends the period for submission to the IRS of taxpayer authorizations permitting disclosure of returns and return information to third-party designees. A public hearing is scheduled for June 9, 2011.
Guidance for Phase II of the qualifying advanced coal program under Section 48A and the qualifying gasification program under Section 48B. This notice updates the rules regarding the separation and sequestration of carbon dioxide emissions for Phase II of the qualifying advanced coal program under section 48A of the Code and the qualifying gasification program under section 48B. Specifically, the notice provides for the annual measurement of separated and sequestered carbon dioxide and applies the recapture rules of section 50(a) in the event that a taxpayer fails to attain or maintain the carbon dioxide separation and sequestration requirements of section 48A or section 48B. Notices 2009-23 and 2009-24 modified.
Credit for carbon dioxide sequestration; modification of Notice 2009-83. This notice modifies Notice 2009-83 by removing section 4.07, which provided that for purposes of section 45Q of the Code, qualified carbon dioxide (CO2) does not include CO2 that is captured and sequestered in a project as required under the qualifying advanced coal project program of section 48A or the qualifying gasification project program of section 48B. Notice 2009-83 modified.
Announcement 2011-25 Announcement 2011-25
The IRS has revoked its determination that Bennafield Enterprises, Inc., of Canton, OH; Challenge 2000, Inc., of Clackamas, OR; Christ Temple Breaking Free Ministry of Itta Bena, MS; Consumerwiz of Connecticut, Inc., of Groton, CT; Dakota Academy Charter School of Burnsville, MN; Human Shelter Innovation Institute, formerly Human Shelter Research Institute, of St. Louis, MO; LBOH, Inc., of Gainesville, FL; Larry T. Herrig Charitable Foundation of Dubuque, IA; National Spending & Credit Counseling Center of Spring Valley, CA; and S.H.O.C. Enterprise, Inc., of Corona, CA, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.
This document provides notice of a public hearing on proposed regulations (REG-149335-08, 2011-6 I.R.B. 468) relating to the capitalization and allocation of royalties that are incurred only upon the sale of property produced or property acquired for resale (sales-based royalties) and adjusting the cost of merchandise inventory for an allowance, discount, or price rebated based on merchandise sales (sales-based vendor allowances). The regulations modify the simplified production method and the simplified resale method. A public hearing is scheduled for April 13, 2011.
Provide America's taxpayers top-quality service by helping them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.
This revenue ruling provides various prescribed rates for federal income tax purposes for April 2011 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(1) for buildings placed in service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%. Finally, Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520.
REV. RUL. 2011-10 TABLE 1
Applicable Federal Rates (AFR) for April 2011
Period for Compounding
Semiannual
AFR .55% .55% .55% .55%
110% AFR .61% .61% .61% .61%
Mid-term
AFR 2.49% 2.47% 2.46% 2.46%
110% AFR 2.74% 2.72% 2.71% 2.70%
Adjusted AFR for April 2011
Short-term adjusted AFR .87% .87% .87% .87%
Mid-term adjusted AFR 2.09% 2.08% 2.07% 2.07%
Long-term adjusted AFR 4.30% 4.25% 4.23% 4.21%
Rates Under Section 382 for April 2011
Adjusted federal long-term rate for the current month 4.30%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 4.55%
Appropriate Percentages Under Section 42(b)(1) for April 2011
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit 7.78%
Rate Under Section 7520 for April 2011
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 3.0%
Guidance Under Section 1502; Amendment of Matching Rule for Certain Gains on Member Stock
DEPARTMENT OF THE TREASURY
26 CFR Part 1
Final and temporary regulations.
This document contains final regulations concerning the treatment of certain intercompany gain with respect to stock owned by members of a consolidated group. These regulations provide for the redetermination of intercompany gain as excluded from gross income in certain transactions involving stock transfers between members of a consolidated group. The temporary regulations contained in this document are solely for the purpose of retaining the portion of the existing temporary regulations that were in the same temporary regulation section but that are not being promulgated as final regulations at this time. These regulations affect corporations filing consolidated returns.
Effective Date: These regulations are effective on March 4, 2011.
Applicability Date: Section 1.1502-13(c)(6)(ii)(C), (c)(6)(ii)(D), and (c)(7)(ii), Examples 16 and 17 apply with respect to items taken into account on or after March 4, 2011.
John F. Tarrant (202) 622-7790 or Lawrence M. Axelrod, (202) 622-7713 (not toll-free numbers).
On March 7, 2008, the IRS and the Treasury Department published temporary regulations §1.1502-13T. See T.D. 9383, 2008-1 C.B. 738 (73 FR 12265-01). Also on March 7, 2008, the IRS and the Treasury Department published a notice of proposed rulemaking cross-referencing those temporary regulations. See REG-137573-07, 2008-1 C.B. 750 (73 FR 12312-01).
The IRS and the Treasury Department did not receive written comments from the public during the prescribed comment period and no public hearing was requested or held. This Treasury decision adopts the proposed regulation (REG-137573-07) with the changes discussed in this preamble. In addition, this Treasury decision revises the temporary regulation, §1.1502-13T.
Summary of Comments and Explanation of Revisions
Finalization of 2008 temporary regulations.
The 2008 temporary regulations concern the treatment of certain intercompany gain with respect to consolidated group member stock. Section 1.1502-13 provides rules governing the timing and characterization of items resulting from transactions between consolidated group members. Section 1.1502-13(c) provides general rules under which the timing and character of those items can be deferred or recharacterized to clearly reflect the taxable income (and tax liability) of the group as a whole. These rules generally apply a "matching" principle under which the timing of inclusion of gain on the sale of property by the seller (S) is linked to the buyer's (B) recovery of its basis in the property and S and B's characterization are subject to redetermination in order to treat S and B as divisions of a single corporation.
The proposed regulations provide that intercompany gain with respect to member stock may be permanently excluded from gross income following certain stock basis elimination transactions (for example, tax-free spin-offs and liquidations). The IRS and the Treasury Department have reconsidered the requirement of the proposed regulations that, immediately before intercompany gain would otherwise be taken into account, the common parent (P) must be the member that holds the member stock with respect to which the intercompany gain was realized, and that the gain must be P's intercompany item. Given the other requirements of the regulation, namely that (i) the group has not and will not derive any Federal income tax benefit from the intercompany transaction; and (ii) the excluded gain will not be treated as tax-exempt income for purposes of the investment adjustment regulations-it is appropriate to provide relief where a member other than the common parent holds the subject stock. Accordingly, these final regulations allow the exclusion of gain where a member holds the target member stock with respect to which the intercompany gain was realized, and the holding member is either (i) B or S, as a successor to the other party (either B or S); or (ii) a third member that is the successor to both B and S.
The preamble to the proposed regulations requested comments as to whether the "Commissioner's Discretionary Rule" (§1.1502-13(c)(6)(ii)(D)) should be retained. The preamble also stated that the IRS and Treasury Department were considering eliminating the Commissioner's Discretionary Rule. Upon further consideration, the IRS and Treasury Department believe there may be circumstances where application of such discretion is warranted. Thus, for example, the final regulations do not provide automatic relief for transactions involving property other than member stock (such as the stock of non-members), but relief may be available after review by the IRS under the Commissioner's Discretionary Rule. Accordingly, the final regulations retain the Commissioner's Discretionary Rule in a form revised to describe the conditions to be satisfied for that discretion to be exercised, and to indicate that relief is available only through a request for a letter ruling.
Finally, the final regulations also expressly provide that the excluded gain is not treated as tax exempt income for purposes of §1.1502-32 and does not increase earnings and profits.
Reordering of Regulation.
On September 4, 2009, amendments to §1.1502-13T were published in the Federal Register to modify the election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation (the 2009 temporary regulations). A minor correction to the 2009 temporary regulations concerning the expiration date of the 2009 temporary regulations was published in the Federal Register on January 13, 2010. The changes made by the 2009 temporary regulations inadvertently appear in the wrong location in the official Federal Register version of §1.1502-13T. Some tax services have these provisions in their intended places. In order to take into account the finalization of the 2008 temporary regulations, as described in this preamble, and to avoid confusion concerning the location of the amendments made by the 2009 temporary regulations, this document revises §1.1502-13T and places the 2009 temporary regulations in the proper location. No substantive change is intended by this revision.
It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It has also been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to this regulation. Pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6), it is hereby certified that this rule will not have a significant economic impact on a substantial number of small entities. This certification is based on the fact that this regulation primarily affects members of consolidated groups which tend to be large corporations. Accordingly, a regulatory flexibility analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, the notice of proposed rulemaking preceding this regulation was submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on their impact on small business.
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
Section 1.1502-13 is also issued under 26 U.S.C. 1502.
Par. 2. Section 1.1502-13 is amended as follows:
1. Entries for Examples 16 and 17 are added to the table of examples for §1.1502-13(c)(7)(ii) in paragraph (a)(6)(ii).
2. Paragraphs (c)(6)(ii)(C), (c)(6)(ii)(D) are revised and Examples 16 and 17 are added to paragraph (c)(7)(ii).
3. Paragraph (c)(7)(iii) is added.
4. Paragraph (f)(7)(i) Examples 8 and 9 and paragraph (f)(7)(ii) are removed.
5. Paragraph (f)(7)(i) is redesignated as (f)(7).
The revisions and additions read as follows:
§1.1502-13 Intercompany transactions.
(6) * * *
(ii) * * *
Matching rule (§1.1502-13(c)(7)(ii))
Example 16. Intercompany stock distribution followed by section 332 liquidation.
Example 17. Intercompany stock sale followed by section 355 distribution.
(C) Certain intercompany gains on stock—(1) In general. Notwithstanding paragraph (c)(6)(ii)(A)(1) of this section, intercompany gain with respect to a member's stock that was created by reason of an intercompany transfer of the stock, and that would not otherwise be taken into account upon a subsequent elimination of the stock's basis but for the transfer, is redetermined to be excluded from gross income if—
(i) B or S becomes a successor (as defined in paragraph (j)(2) of this section) to the other party (either B or S), or a third member becomes a successor to both B and S;
(ii) Immediately before the intercompany gain would be taken into account, the successor member holds the member's stock with respect to which the intercompany gain was realized;
(iii) The successor member's basis in the member's stock that reflects the intercompany gain that is taken into account is eliminated without the recognition of gain or loss (and such eliminated basis is not further reflected in the basis of any successor asset);
(iv) The effects of the intercompany transaction have not previously been reflected, directly or indirectly, on the group's consolidated return; and
(v) The group has not derived, and no taxpayer will derive, any Federal income tax benefit from the intercompany transaction that gave rise to the intercompany gain or the redetermination of the intercompany gain (including any adjustment to basis in member stock under §1.1502-32). For this purpose, the redetermination of the intercompany gain is not itself considered a Federal income tax benefit.
(2) Effect on earnings and profits and investment adjustments. Any amount excluded from gross income under paragraph (c)(6)(ii)(C)(1) of this section shall not be taken into account as earnings and profits of any member and shall not be treated as tax-exempt income under §1.1502-32(b)(2)(ii).
(D) Other amounts. (1) The Commissioner may determine that treating S's intercompany item as excluded from gross income is consistent with the purposes of this section and other applicable provisions of the Internal Revenue Code, regulations, and published guidance, if the following conditions are met, depending on whether the intercompany item is an item of income or an item of gain:
(i) In the case of an intercompany item of income, the corresponding item is permanently disallowed; or
(ii) If the intercompany item constitutes gain, the conditions described in paragraphs (c)(6)(ii)(C)(1)(iv) and (c)(6)(ii)(C)(1)(v) of this section are satisfied.
(2) A determination by the Commissioner may be obtained only through a letter ruling request.
Example 16. Intercompany stock distribution followed by section 332 liquidation. (a) Facts. P owns all of the stock of S, S owns all the stock of T, a member of the P group, and T owns all of the stock of T1, also a member of the P group. On January 1 of Year 1, S distributes all of the T stock to P in a distribution to which section 301 applies. At the time of this distribution, the value of the T stock is $100 and S has a $40 basis in the T stock. Under section 311(b), the distribution creates $60 of intercompany gain to S. Under section 301(d), P's basis in the T stock is $100. S will take its $60 intercompany gain into account under the matching rule. On January 1 of Year 4, in an independent transaction, S distributes all of its assets to P in a complete liquidation to which section 332 applies, and, under paragraph (j)(2) of this section, P succeeds to S's $60 gain. On January 1 of Year 7, T distributes all of its T1 stock to P in a transaction to which section 355 applies. At the time of this distribution, P has a basis in the T stock of $100, the value of the T stock (without regard to T1) is $75, and the value of the T1 stock is $25. Under section 358, P allocates $25 of its $100 basis in the T stock to the T1 stock, and, under paragraph (j)(1) of this section, the T1 stock becomes a successor asset to the T stock. On January 1 of Year 9, in an independent transaction, T distributes all of its assets to P in a complete liquidation to which section 332 applies.
(b) Analysis. Under paragraphs (b)(1) and (f)(2) of this section, S's distribution in Year 1 of the T stock to P is an intercompany transaction, S is the selling member, and P is the buying member. In Year 9 when T liquidates, P has no gain or loss under section 332. Under paragraph (b)(3)(ii) of this section, P's $0 gain or loss with respect to the T stock under section 332 is a corresponding item. P takes $45 (75/100 x $60) of its intercompany gain into account under the matching rule in Year 9 to reflect the difference between P's $0 of unrecognized gain and P's $45 of recomputed unrecognized gain. (If P and S were divisions of a single corporation, P would have had a $40 basis in the T stock, and, after the Year 7 distribution of the T1 stock, would have held the T stock with a $30 basis.) However, paragraph (c)(6) of this section does not prevent the redetermination of P's intercompany gain as excluded from gross income provided P succeeds to S's intercompany item; P and S are a single entity; P's basis in the T stock that reflects the $45 intercompany gain taken into account is eliminated without the recognition of gain or loss (and this eliminated basis is not further reflected in the basis of any successor asset); the group has not derived and no taxpayer will derive any Federal income tax benefit from the basis in the T stock and will not derive any Federal income tax benefit from a redetermination of this portion of the gain; and the effects of the intercompany transaction have not previously been reflected, directly or indirectly, on the P group's consolidated return. (See paragraph (c)(6)(ii)(C) of this section.) Accordingly, under paragraph (c)(6)(ii)(C) of this section, the $45 intercompany gain that P takes into account is redetermined to be excluded from gross income. P's basis in its T1 stock continues to reflect $15 of intercompany gain.
Example 17. Intercompany stock sale followed by section 355 distribution. (a) Facts. The facts are the same as Example 16, except that T does not distribute the stock of T1, instead, in Year 7, T makes a distribution of $50 to P in a transaction to which section 301 applies. Under §1.1502-32, P's basis in its T stock is reduced by $50 and, under paragraph (f)(2)(ii) of this section, the intercompany distribution is excluded from P's gross income. Further, in Year 9, instead of liquidating T, P distributes the T stock to its shareholders in a transaction to which section 355 applies.
(b) Analysis. On the distribution of the T stock in Year 9, P has $0 of unrecognized gain under section 355(c). Under paragraph (b)(3)(ii) of this section, P's $0 of unrecognized gain or loss with respect to the T stock under section 355(c) is a corresponding item. P takes its $60 intercompany gain into account under the matching rule in Year 9 to reflect the difference between P's $0 of unrecognized gain and P's $60 of recomputed gain ($50 unrecognized gain and $10 recognized gain). (If P and S were divisions of a single corporation, P would have had a $40 basis in the T stock, and, after the Year 7 distribution, would have held the T stock with a $10 excess loss account.) See paragraph (f)(7), Example 2 of this section. Paragraph (c)(6) of this section does not prevent the redetermination of P's intercompany gain as excluded from gross income provided P succeeds to S's intercompany item; P and S are a single entity; P's basis in the T stock that reflects the $60 intercompany gain taken into account is eliminated without the recognition of gain or loss (and this eliminated basis is not further reflected in any successor asset); the group has not derived any Federal income tax benefit from the basis in the T stock and will not derive any Federal income tax benefit from a redetermination of this portion of the gain; and the effects of the intercompany transaction have not previously been reflected, directly or indirectly, on the P group's consolidated return. (See paragraph (c)(6)(ii)(C) of this section.) The intercompany transaction with respect to the T stock resulted in an increase in the basis of the T stock, and this increase in the basis of the T stock prevented P from holding the T stock with a $10 excess loss account (as a result of the Year 7 distribution) at the time of the section 355 distribution. Accordingly, the group derived a Federal income tax benefit from the intercompany transaction to the extent of $10 and, under paragraph (c)(6)(ii)(C) of this section, only $50 of the $60 intercompany gain that P takes into account is redetermined to be excluded from gross income.
(c) Application of section 355(e). If it were determined that section 355(e) applied to P's distribution of the T stock, P would recognize $0 of gain and derive a Federal income tax benefit to the extent of the full $60 increase in the basis of the T stock. Therefore, no portion of P's intercompany gain would be redetermined to be excluded from gross income under paragraph (c)(6)(ii)(C) of this section.
(iii) Effective/applicability date—(A) In general. Paragraphs (c)(6)(ii)(C), (c)(6)(ii)(D), and (c)(7)(ii) Examples 16 and 17 of this section apply with respect to items taken into account on or after April 4, 2011.
(B) Prior periods. For items taken into account on or after March 7, 2008, and before April 4, 2011, see §1.1502-13T(c)(6)(ii)(C) and (f)(7), Examples 7 and 8 as contained in 26 CFR part 1 in effect on April 1, 2009. For items taken into account before March 7, 2008, see §1.1502-13 as contained in 26 CFR part 1 in effect on April 1, 2007.
Par. 3. Section 1.1502-13T is revised to read as follows:
§1.1502-13T Intercompany transactions (temporary).
(a) through (f)(5)(ii)(A) [Reserved]. For further guidance, see §1.1502-13(a) through (f)(5)(ii)(A).
(B) Section 332—(1) In general. If section 332 would otherwise apply to T's (old T's) liquidation into B, and B transfers substantially all of old T's assets to a new member (new T), and if a direct transfer of substantially all of old T's assets to new T would qualify as a reorganization described in section 368(a), then, for all Federal income tax purposes, T's liquidation into B and B's transfer of substantially all of old T's assets to new T will be disregarded and instead, the transaction will be treated as if old T transferred substantially all of its assets to new T in exchange for new T stock and the assumption of T's liabilities in a reorganization described in section 368(a). (Under §1.1502-13(j)(1), B's stock in new T would be a successor asset to B's stock in old T, and S's gain would be taken into account based on the new T stock.)
(2) Time limitation and adjustments. The transfer of old T's assets to new T qualifies under paragraph (f)(5)(ii)(B)(1) of this section only if B has entered into a written plan, on or before the due date of the group's consolidated income tax return (including extensions), to transfer the T assets to new T, and the statement described in paragraph (f)(5)(ii)(E) of this section is included on or with a timely filed consolidated tax return for the tax year that includes the date of the liquidation (including extensions). However, see paragraph (f)(5)(ii)(F) of this section for certain situations in which the plan may be entered into after the due date of the return and the statement described in paragraph (f)(5)(ii)(E) of this section may be included on either an original tax return or an amended tax return filed after the due date of the return. In either case, the transfer of substantially all of T's assets to new T must be completed within 12 months of the filing of the return. Appropriate adjustments are made to reflect any events occurring before the formation of new T and to reflect any assets not transferred to new T, or liabilities not assumed by new T. For example, if B retains an asset of old T, the asset is treated under §1.1502-13(f)(3) as acquired by new T but distributed to B immediately after the reorganization.
(f)(5)(ii)(B)(3) through (f)(5)(ii)(E) [Reserved]. For further guidance, see §1.1502-13(f)(5)(ii)(B)(3) through (f)(5)(ii)(E).
(F) Effective/Applicability dates—(1) General rule. Paragraphs (f)(5)(ii)(B)(1) and (f)(5)(ii)(B)(2) of this section apply to transactions in which old T's liquidation into B occurs on or after October 25, 2007.
(2) Prior periods. For transactions in which old T's liquidation into B occurs before October 25, 2007, see §1.1502-13(f)(5)(ii)(B)(1) and (f)(5)(ii)(B)(2) in effect prior to October 25, 2007 as contained in 26 CFR part 1, revised April 1, 2009.
(3) Special rule for tax returns filed before November 3, 2009. In the case of a liquidation on or after October 25, 2007, by a taxpayer whose original tax return for the year of liquidation was filed on or before November 3, 2009, then, notwithstanding paragraph (f)(5)(ii)(B)(2) of this section and §1.1502-13(f)(5)(ii)(E), the election to apply paragraph (f)(5)(ii)(B) of this section may be made by entering into the written plan described in paragraph (f)(5)(ii)(B) of this section on or before November 3, 2009, including the statement described in §1.1502-13(f)(5)(ii)(E) on or with an original tax return or an amended tax return for the tax year that includes the liquidation filed on or before November 3, 2009, and transferring substantially all of T's assets to new T within 12 months of the filing of such original or amended return.
(G) Expiration date. These temporary regulations will expire on September 3, 2012.
Steven T. Miller,
Approved February 24, 2011.
Michael Mundaca,
Assistant Secretary of
the Treasury (Tax Policy).
(Filed by the Office of the Federal Register on March 3, 2011, 8:45 a.m., and published in the issue of the Federal Register for March 4, 2011, 76 F.R. 11956)
The principal author of this regulation is John F. Tarrant, Office of Associate Chief Counsel (Corporate). However, other personnel from the IRS and the Treasury Department participated in its development.
Guidance for Phase II of the Qualifying Advanced Coal Program Under Section 48A and the Qualifying Gasification Program Under Section 48B
This notice updates the rules relating to the qualifying advanced coal project program under § 48A and the qualifying gasification project program under § 48B of the Internal Revenue Code. Specifically, this notice applies to any qualifying project that includes equipment that separates and sequesters such project's total carbon dioxide emissions. Except as specifically provided in this notice, the qualifying advanced coal project program and the qualifying gasification project program will be conducted in the manner and under the procedures provided in Notice 2009-24, 2009-16 I.R.B. 817, and Notice 2009-23, 2009-16 I.R.B. 802.
.01 Section 46 provides that the amount of the investment credit for any taxable year is the sum of the credits listed in § 46. That list includes the qualifying advanced coal project credit under § 48A and the qualifying gasification project credit under § 48B.
.02 Section 48A allows a qualifying advanced coal project credit in an amount equal to (1) 20 percent of the qualified investment (as defined in § 48A(b)) for that taxable year in qualifying advanced coal projects (as defined in § 48A(c)(1) and (e)) described in § 48A(d)(3)(B)(i), (2) 15 percent of the qualified investment for that taxable year in qualified advanced coal projects described in § 48A(d)(3)(B)(ii), and (3) 30 percent of the qualified investment for that taxable year in qualifying advanced coal projects described in § 48A(d)(3)(B)(iii).
.03 Section 48A(d)(3)(B)(iii), as added by section 111 of the Energy Improvement and Extension Act of 2008, Pub. L. No. 110-343, 122 Stat. 3765 (October 3, 2008), provides for a second phase of the qualifying advanced coal project program and authorizes the Secretary to certify $1.25 billion of additional credits for advanced coal-based generation technology projects ("the Phase II advanced coal program" and "the Phase II advanced coal projects.")
.04 Under § 48A(e)(1)(G), any project the application for which is submitted under the Phase II advanced coal program must include equipment that separates and sequesters—
(1) At least 65 percent of such project's total carbon dioxide ("CO2") emissions in the case of an application other than an application for reallocated credits under § 48A(d)(4); and
(2) At least 70 percent of such project's total CO2 emissions in the case of an application for reallocated credits under § 48A(d)(4).
.05 On April 20, 2009, the Internal Revenue Service ("Service") issued Notice 2009-24 to announce procedures for the allocation of credits under the Phase II advanced coal program.
.06 Section 48B(a) allows a qualifying gasification project credit for a taxable year in an amount equal to 20 percent (30 percent in the case of projects for which credits are allocated under § 48B(d)(1)(B)) of the qualified investment for such taxable year.
.07 Section 48B(d)(1)(B), as added by section 112 of the Energy Improvement and Extension Act of 2008 provides for a second phase of the qualifying gasification project program and authorizes the Secretary to certify an additional $250 million of credits to qualifying projects that include equipment that separates and sequesters at least 75 percent of such project's total CO2 emissions ("Phase II gasification program" and "Phase II gasification projects.")
.08 On April 20, 2009, the Service issued Notice 2009-23 to announce procedures for the allocation of credit under the Phase II gasification program.
.09 On September 27, 2010, the Service issued Announcement 2010-56, 2010-39 I.R.B. 398, setting forth the results of the first round of allocations under the Phase II advanced coal program and the Phase II gasification program.
SECTION 3. RULE RELATED TO SEPARATION AND SEQUESTRATION OF CARBON DIOXIDE EMISSIONS.
.01 In General. Section 48A(i) requires a recapture of the qualifying advanced coal project credit with respect to any project that fails to attain or maintain the separation and sequestration requirements of § 48A(e)(1)(G). Section 7.04 of Notice 2009-24 states that the § 48A credit allocated to a Phase II advanced coal project will be recaptured if, at any time during the applicable recovery period (as defined in § 168(c)) for such project, the project fails to attain or maintain the separation and sequestration requirements for such project under § 48A(e)(1)(G).
Similarly, § 48B(f) requires a recapture of the qualifying gasification project credit with respect to any project that fails to attain or maintain the separation and sequestration requirements for such project under § 48B(d)(1)(B). Section 6.04 of Notice 2009-23 provides that the § 48B credit allocated to a Phase II gasification project will be recaptured if, at any time during the applicable recovery period (as defined in § 168(c)) for such project, the project fails to attain or maintain the separation and sequestration requirements for such project under § 48B(d)(1)(B).
Additionally, credits allowed under § 48A and § 48B are subject to the recapture rules of § 50(a) as provided under section 2.12 of Notice 2009-24 and section 2.07 of Notice 2009-23, respectively. Section 50(a)(1) provides, generally, for recapture of the investment credit if, during any taxable year, investment tax credit property is disposed of or otherwise ceases to be investment credit property with respect to the taxpayer before the close of the recapture period. The recapture period under § 50(a) is the 5-year period beginning on the date the property is placed in service.
.02 Applicability of the Recapture Rule of § 50(a). The Service recognizes that § 168(c) provides a wide range of recovery periods that apply to Phase II advanced coal projects or Phase II gasification projects. This may create uncertainty for taxpayers regarding which recovery period to use if a project fails to attain or maintain the separation and sequestration requirements of § 48A and § 48B.
Moreover, different recapture periods provided under § 168(c) and § 50(a) may create further confusion and difficulty to taxpayers and to the Service. Therefore, the Service has determined that the recapture rules under § 50(a) will apply for all events that trigger recapture of the credits allowed under § 48A or § 48B, including a failure to attain or maintain the separation and sequestration requirements of § 48A(e)(1)(G) or § 48B(d)(1)(B).
.03 Annual Basis During Normal Plant Operations. For purposes of determining whether a project meets the requirements of § 48A(e)(1)(G) or § 48B(d)(1)(B), the amount of the project's total CO2 emissions and the amount of CO2 separated and sequestered will be measured on an annual basis during normal plant operations. An annual period other than the taxpayer's taxable year may be used for these purposes if the same period is consistently used. If a period other than the taxable year is used, any failure to meet the requirements of § 48A(e)(1)(G) or § 48B(d)(1)(B) will be treated as occurring in the taxable year that includes the last day of the annual period in which the failure occurs. The term "normal plant operations" is defined as operations other than during periods of initial plant certification, plant startup, plant shutdown, integrated gasifier shutdown for gasification system maintenance, or interruption of the coal supply to the project resulting from an event of force majeure (including an act of God, war, strike, or other similar event beyond the control of the taxpayer).
SECTION 4. EFFECT ON OTHER DOCUMENTS
Notice 2009-23 and Notice 2009-24 are modified.
SECTION 5. EFFECTIVE DATE
This notice is effective for all projects that receive either § 48A credits under the Phase II advanced coal program or § 48B credits under the Phase II gasification program.
The principal author of this notice is Jennifer C. Bernardini of the Office of Associate Chief Counsel (Passthroughs & Special Industries). For further information regarding this notice, contact Jennifer C. Bernardini at (202) 622-3110 (not a toll-free call).
Credit for Carbon Dioxide Sequestration; Modification of Notice 2009-83
This notice modifies Notice 2009-83, 2009-44 I.R.B. 588, by removing section 4.07 of the Notice. Section 4.07 provided that for purposes of § 45Q of the Internal Revenue Code, qualified carbon dioxide (CO2) does not include CO2 that is captured and sequestered in a project as required under an agreement entered into in connection with the qualifying advanced coal project program of § 48A or the qualifying gasification project program of § 48B.
Section 45Q was enacted by § 115 of the Energy Improvement and Extension Act of 2008, Pub. L. No. 110-343, 122 Stat. 3829 (October 3, 2008), as amended by section 1131 of the American Recovery and Reinvestment Tax Act of 2009, Division B of Pub. L. 111-5, 123 Stat 115 (Feb. 17, 2009). Section 45Q(a) provides that a credit for CO2 sequestration is generally available to a taxpayer that captures qualified CO2 at a qualified facility and disposes of qualified CO2 in secure geological storage within the United States, effective for CO2 captured after October 3, 2008.
Section 45Q(b)(1) defines qualified CO2 as CO2 from an industrial source which (A) would otherwise be released into the atmosphere as industrial emission of greenhouse gas, and (B) is measured at the source of capture and verified at the point of disposal or injection.
On November 2, 2009, the Internal Revenue Service (Service) issued Notice 2009-83, providing guidance on determining eligibility for the credit and the amount of the credit, as well as rules regarding adequate security measures for secure geological storage of CO2. Section 4.07 of Notice 2009-83 provides that "qualified CO2 for purposes of the § 45Q credit does not include CO2 that is captured and sequestered in a project to the extent required under an agreement executed with the Service under the qualifying advanced coal project program of § 48A or the qualifying gasification project program of § 48B."
Since the issuance of Notice 2009-83, several commenters asserted that the interpretation of § 45Q(b)(1) in section 4.07 is too restrictive and is inconsistent with the tax and energy policy underlying the § 45Q credit, the § 48A program, and the § 48B program. According to these commenters, the intent of § 45Q(b)(1) is not to exclude CO2 that has been captured and sequestered under the § 48A program or the § 48B program, but to ensure merely that the § 45Q credit is limited to CO2 captured from an industrial source that, but for the physical act of capture, would otherwise be released into the atmosphere as an industrial emission of greenhouse gas.
SECTION 2. MODIFICATION OF NOTICE 2009-83
This notice removes section 4.07 of Notice 2009-83. Accordingly, qualified CO2, as defined under § 45Q(b)(1), does not exclude CO2 that is required to be captured and sequestered under the § 48A program or the § 48B program.
Notice 2009-83 is modified as provided in this notice. Except as explicitly provided, this notice does not otherwise affect the guidance provided in Notice 2009-83.
This notice is effective November 2, 2009, the effective date of Notice 2009-83.
Notice of Proposed Rulemaking and Notice of Public Hearing Disclosure of Returns and Return Information to Designee of Taxpayer
This document contains a proposed regulation pertaining to the period for submission to the IRS of taxpayer authorizations permitting disclosure of returns and return information to third-party designees. Specifically, the proposed regulation extends from 60 days to 120 days the period within which a signed and dated authorization must be received by the IRS (or an agent or contractor of the IRS) in order for it to be effective. The proposed regulation extends the period as some institutions charged with assisting taxpayers in their financial dealings have encountered difficulty in obtaining written authorizations and submitting the authorizations within the 60-day period allowed by the existing regulations. The proposed regulation will affect taxpayers who submit authorizations permitting disclosure of returns and return information to third-party designees. This document also provides notice of a public hearing on the proposed regulation.
Written or electronic comments must be received by May 17, 2011. Outlines of topics to be discussed at the public hearing scheduled for Thursday, June 9, 2011 at 10 a.m. must be received by Wednesday, May 18, 2011.
Send submissions to CC:PA:LPD:PR (REG-153338-09), room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to: CC:PA:LPD:PR (REG-153338-09), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue, N.W., Washington, DC, or sent electronically via the Federal eRulemaking Portal at www.regulations.gov (IRS REG-153338-09). The public hearing will be held in Auditorium, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC.
Concerning the proposed regulation, contact Amy Mielke, (202) 622-4570; concerning submissions of comments, the hearing, or to be placed on the building access list to attend the hearing, Oluwafunmilayo Taylor, (202) 622-7180 (not toll-free numbers).
The collection of information contained in this proposed regulation has been previously approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)) under control number 1545-1816.
Books and records relating to the collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103.
This document contains proposed amendments to the Procedure and Administration Regulations (26 CFR part 301). Section 6103(c) of the Internal Revenue Code (Code) authorizes the IRS (or an agent or contractor of the IRS) to disclose returns and return information to such person or persons as the taxpayer may designate in a request for or consent to disclosure. The proposed regulation amends §301.6103(c)-1 by extending the period for submission to the IRS of taxpayer authorizations permitting disclosure of returns and return information to designees of a taxpayer. Specifically, the proposed regulation extends from 60 days to 120 days the period within which a signed and dated authorization must be received by the IRS (or an agent or contractor of the IRS) in order for it to be effective.
On December 18, 2009, the IRS published Notice 2010-8, 2010-3 I.R.B. 297, which announced an intention to amend the regulation under §301.6103(c)-1 to expand the time frame for submission of section 6103(c) authorizations. The notice additionally announced interim rules extending from 60 days to 120 days the period within which section 6103(c) authorizations must be received in order to be effective. The interim rules apply to authorizations signed and dated on or after October 19, 2009. Per Notice 2010-8, the interim rules remain in effect until promulgation of a final regulation under section 6103(c). See §601.601(d)(2)(ii)(d).
The IRS recognizes the importance of limiting the effective period of authorizations provided pursuant to section 6103(c). Reasonable limitation on the effective period of written authorizations helps ensure the currency of the authorization and protects taxpayer privacy. The 60-day period allowed by the existing regulation, however, has proven problematic. Some institutions charged with assisting taxpayers in their financial dealings have encountered difficulty in obtaining written authorizations and submitting the authorizations to the IRS within the 60 days allowed by the existing regulation. To reduce the burden on taxpayers and the institutions and professionals assisting them, the IRS proposes amending the regulation under section 6103(c) to extend from 60 days to 120 days the period within which taxpayer-provided authorizations must be received by the IRS (or an agent or contractor of the IRS) in order to be effective.
This regulation, as proposed, will be effective upon publication in the Federal Register of a Treasury decision adopting this rule as a final regulation. The regulation, once effective, will apply to section 6103(c) authorizations signed on or after October 19, 2009.
Notice 2010-8, 2010-3 I.R.B. 297, will be obsolete upon publication in the Federal Register of a Treasury decision adopting this rule as a final regulation.
It has been determined that this proposed regulation is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It has also been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to this regulation. Pursuant to section 7805(f) of the Code, this notice of proposed rulemaking has been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small businesses.
When an agency issues a rulemaking proposal, the Regulatory Flexibility Act (5 U.S.C. chapter 6), requires the agency to "prepare and make available for public comment an initial regulatory flexibility analysis" that will "describe the impact of the proposed rule on small entities." (5 U.S.C. 603(a)). Section 605 of the RFA provides an exception to this requirement if the agency certifies that the proposed rulemaking will not have a significant economic impact on a substantial number of small entities. It is hereby certified that the collection of information in this regulation will not have a significant economic impact on a substantial number of small entities. This certification is based upon the fact that any burden on taxpayers is minimal, since the regulation only applies to taxpayers which request or consent to the disclosure of returns or return information, and since the information collected is only that necessary to carry out the disclosure of returns or return information requested or consented to by the taxpayer (such as the name and taxpayer identification number of the taxpayer, the return or return information to be disclosed, and the identity of the designee). Moreover, it is based upon the fact that the regulation reduces the burden imposed upon taxpayers by the prior regulation by extending the period in which consents may be received by the IRS. Accordingly, a Regulatory Flexibility Analysis is not required.
Before this proposed regulation is adopted as a final regulation, consideration will be given to any written comments (a signed original and eight (8) copies) and electronic comments that are timely submitted to the IRS. The IRS and the Treasury Department request comments on the clarity of the proposed rules and how they can be made easier to understand. All comments will be available for public inspection and copying.
The public hearing is scheduled for Thursday, June 9, 2011 at 10 a.m., and will be held in Auditorium, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC. Due to building security procedures, visitors must enter at the Constitution Avenue entrance. All visitors must present photo identification to enter the building. Because of access restrictions, visitors will not be admitted beyond the immediate entrance area more than 30 minutes before the hearing starts. For information about having your name placed on the building access list to attend the hearing, see the section of this preamble titled "FOR FURTHER INFORMATION CONTACT."
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who wish to present oral comments at the hearing must submit electronic or written comments and an outline of the topics to be discussed and the time to be devoted to each topic (signed original and eight (8) copies) by Wednesday, May 18, 2011. A period of 10 minutes will be allotted to each person for the making of comments. An agenda showing the scheduling of the speakers will be prepared after the deadline for receiving outlines has passed. Copies of the agenda will be available free of charge at the hearing.
Accordingly, 26 CFR part 301 is proposed to be amended as follows:
PART 301—PROCEDURE AND ADMINISTRATION
Paragraph 1. The authority citation for part 301 continues to read as follows:
Authority: 26 U.S.C. 7805***
Par. 2. Section 301.6103(c)-1 is amended by revising paragraphs (b)(2), (f) and adding paragraph (g) to read as follows:
§301.6103(c)-1 Disclosure of returns and return information to designee of taxpayer.
(b) * * *
(2) Requirement that request or consent be received within one hundred twenty days of when signed and dated. The disclosure of a return or return information authorized by a written request for or written consent to the disclosure shall not be made unless the request or consent is received by the Internal Revenue Service (or an agent or contractor of the Internal Revenue Service) within 120 days following the date upon which the request or consent was signed and dated by the taxpayer.
(f) Applicability date. This section is applicable to section 6103(c) authorizations signed on or after October 19, 2009.
(g) Effective date. This section is effective on the date that the final regulations are published in the Federal Register.
(Filed by the Office of the Federal Register on March 17, 2011, 8:45 a.m., and published in the issue of the Federal Register for March 18, 2011, 76 F.R. 14827)
The principal author of this proposed regulation is Amy Mielke, Office of the Associate Chief Counsel (Procedure and Administration).
Deletions From Cumulative List of Organizations Contributions to Which are Deductible Under Section 170 of the Code
The Internal Revenue Service has revoked its determination that the organizations listed below qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.
Generally, the Service will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the Service is not precluded from disallowing a deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omissions of the organization that brought about this revocation.
If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on April 4, 2011 and would end on the date the court first determines that the organization is not described in section 170(c)(2) as more particularly set forth in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the organization that were the basis for revocation.
Org. Name
Bennafield Enterprises, Inc. Canton OH
Challenge 2000, Inc. Clackamas OR
Christ Temple Breaking Free Ministry Itta Bena MS
Consumerwiz of Connecticut, Inc. Groton CT
Dakota Academy Charter School Burnsville MN
Human Shelter Innovation Institute formerly Human Shelter Research Institute St. Louis MO
LBOH, INC Gainesville FL
Larry T. Herrig Charitable Foundation Dubuque IA
National Spending & Credit Counseling Center Spring Valley CA
S.H.O.C. Enterprise, Inc. Corona CA
Sales-Based Royalties and Vendor Allowances; Hearing
Notice of public hearing on proposed rulemaking.
This document provides notice of public hearing on a notice of proposed rulemaking (REG-149335-08, 2011-6 I.R.B. 468) relating to the capitalization and allocation of royalties that are incurred only upon the sale of property produced or property acquired for resale (sales-based royalties) and adjusting the cost of merchandise inventory for an allowance, discount, or price rebated based on merchandise sales (sales-based vendor allowances). The regulations modify the simplified production method and the simplified resale method of allocating capitalized costs between ending inventory and cost of goods sold. The regulations affect taxpayers that incur capitalizable sales-based royalties and earn sales-based vendor allowances.
The public hearing is being held on Wednesday, April 13, 2011, at 10 a.m. The IRS must receive outlines of the topics to be discussed at the hearing by Monday, March 28, 2011.
The public hearing is being held in the auditorium, Internal Revenue Building, 1111 Constitution Avenue, NW, Washington, DC. Send submissions to: CC:PA:LPD:PR (REG-149335-08), room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-149335-08), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC. Alternatively, taxpayers may submit electronic outlines of oral comments via the Federal eRulemaking Portal at http://www.regulations.gov.
Concerning the proposed regulations, John Roman Faron at (202) 622-4930; concerning submissions of comments, the hearing, and/or to be placed on the building access list to attend the hearing, Richard A. Hurst at Richard.A.Hurst@irscounsel.treas.gov or (202) 622-7180 (not toll-free numbers).
The subject of the public hearing is the notice of proposed rulemaking (REG-149335-08) that was published in the Federal Register on Friday, December 17, 2010 (75 FR 78940).
Persons, who wish to present oral comments at the hearing that submitted written comments, must submit an outline of the topics to be discussed and the amount of time to be devoted to each topic (signed original and eight (8) copies) by Monday, March 28, 2011.
A period of 10 minutes is allotted to each person for presenting oral comments. After the deadline for receiving outlines has passed, the IRS will prepare an agenda containing the schedule of speakers. Copies of the agenda will be made available, free of charge, at the hearing or in the Freedom of Information Reading Room (FOIA RR) (Room 1621) which is located at the 11th and Pennsylvania Avenue NW entrance, 1111 Constitution Avenue, NW, Washington, DC.
Because of access restrictions, the IRS will not admit visitors beyond the immediate entrance area more than 30 minutes before the hearing starts. For information about having your name placed on the building access list to attend the hearing, see the FOR FURTHER INFORMATION CONTACT section of this document.
LaNita Van Dyke,
Chief, Publications and Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
Z—Corporation.
Bulletins 2011-1 through 2011-14
2011-18 2011-12 I.R.B. 2011-12 567
2011-25 2011-14 I.R.B. 2011-14
140108-08 2011-13 I.R.B. 2011-13 591
149335-08 2011-6 I.R.B. 2011-6 468
153338-09 2011-14 I.R.B. 2011-14
2011-5 2011-13 I.R.B. 2011-13 577
Treasury Decisions
9507 2011-3 I.R.B. 2011-3 305
9515 2011-14 I.R.B. 2011-14
9516 2011-13 I.R.B. 2011-13 575
85-88 Obsoleted by Rev. Proc. 2011-10 2011-2 I.R.B. 2011-2 294
2008-11 Modified by Ann. 2011-6 2011-4 I.R.B. 2011-4 433
2009-62 Obsoleted by Rev. Proc. 2011-10 2011-2 I.R.B. 2011-2 294
2006-87 Superseded by Notice 2011-8 2011-8 I.R.B. 2011-8 503
2008-107 Superseded by Notice 2011-8 2011-8 I.R.B. 2011-8 503
2009-23 Modified by Notice 2011-24 2011-14 I.R.B. 2011-14
2010-59 Modified by Notice 2011-5 2011-3 I.R.B. 2011-3 314
2010-71 Modified and superseded by Notice 2011-9 2011-6 I.R.B. 2011-6 459
2010-79 Clarified and modified by Notice 2011-4 2011-2 I.R.B. 2011-2 282
132554-08 Corrected by Ann. 2011-11 2011-7 I.R.B. 2011-7 500
149335-08 Hearing scheduled by Ann. 2011-26 2011-14 I.R.B. 2011-14
72-50 Modified and superseded by Rev. Proc. 2011-10 2011-2 I.R.B. 2011-2 294
76-34 Modified and supersed by Rev. Proc. 2011-10 2011-2 I.R.B. 2011-2 294
97-27 Clarified and modified by Rev. Proc. 2011-4 2011-1 I.R.B. 2011-1 330
2001-10 Modified by Rev. Proc. 2011-4 2011-4 I.R.B. 2011-4 330
2003-21 Modified and superseded by Rev. Proc. 2011-15 2011-3 I.R.B. 2011-3 322
2004-34 Modified by Rev. Proc. 2011-14 2011-4 I.R.B. 2011-4 330
2004-34 Modified and clarified by Rev. Proc. 2011-18 2011-5 I.R.B. 2011-5 443
2008-52 Superseded in part by Rev. Proc. 2011-14 2011-4 I.R.B. 2011-4 330
2010-15 Updated by Rev. Proc. 2011-13 2011-3 I.R.B. 2011-3 318
2010-18 Amplified and modified by Rev. Proc. 2011-21 2011-12 I.R.B. 2011-12 560
2011-1 Corrected by Ann. 2011-7 2011-5 I.R.B. 2011-5 446
2011-11 Corrected by Ann. 2011-9 2011-7 I.R.B. 2011-7 499
81-100 Modified by Rev. Rul. 2011-1 2011-2 I.R.B. 2011-2 251
2004-67 Modified by Rev. Rul. 2011-1 2011-2 I.R.B. 2011-2 251
2011-3 Corrected by Ann. 2011-16 2011-7 I.R.B. 2011-7 500
9391 Corrected by Ann. 2011-12 2011-9 I.R.B. 2011-9 532
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Businesses. Under Businesses Topics, select More Topics. Then select Internal Revenue Bulletins.
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the
IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224.


Math isn't one of the things you hear fashion editors talk about while they wait for runway shows to start. (We're right-brained people!) But Yeohlee Teng likes to think about numbers and geometry when she designs her clothes. At first glance, Teng's Spring collection was as simple as it gets—all button-down shirts, scoop-neck T-shirt dresses, and pencil skirts—but most pieces were designed with equations in mind. Pockets were placed in perfect 6-by-6-inch squares, and a spongy, bonded wool coat was cut from a giant circle. The models even stood on a 36-by-36-by-12-inch platform in the middle of her tucked-away 29th Street store.
Teng also considered how clothes fill up the negative space around the body—see the rounded ecru coat with pouf sleeves, which concealed the model's every curve, or the sheer filigree shirts, which seemed to take up no space at all. Of course, the average shopper likely won't consider those factors when she grabs a Yeohlee parka off the rack, but the emphasis on numbers and form did lend a sense of order to the designer's sometimes vague aesthetic.


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Letter: Block Association in Teaneck continues to be in good hands
The North East Teaneck Block Association has been a powerful voice for positive, productive change
Letter: Block Association in Teaneck continues to be in good hands The North East Teaneck Block Association has been a powerful voice for positive, productive change Check out this story on northjersey.com: https://njersy.co/2A4ee9l
NorthJersey Published 11:14 a.m. ET Nov. 3, 2017
Letters(Photo: File photo)
Gwendolyn Acree has long been a role model and inspiration to so many people in Teaneck over the years -- including me -- thanks to her dedication to community activism and her leadership as President of the North East Block Association. Moreover, Gwen has been an incredible mentor to those who are fortunate enough to call her a friend. We wish Gwen the very best in her retirement as president of the association but know that she will remain involved in local affairs due to her kind, generous heart, and her abundant knowledge of and love for Teaneck. Gwen is a friend among friends, and we wish her the very best in her retirement.
Also, congratulations to Jacqueline Wilson on becoming the new president of the association. Jacqui has the knowledge, experience and commitment to help the association grow and accomplish even more in the years to come. The North East Teaneck Block Association has been a powerful voice for positive, productive change in our hometown for decades, and will continue to be an inspiring force thanks to the outstanding work and vision of it leaders.
Michael Pagan
Read or Share this story: https://njersy.co/2A4ee9l
Opinion: NJ on right path for pedestrian safety


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Azadegan League (1997/1998) był 13. edycją najwyższej klasy rozgrywkowej w piłce nożnej w Iranie. Liga skupiała 16 zespołów. Tytułu nie obroniła drużyna Persepolis Teheran. Nowym mistrz Iranu została drużyna Esteghlal Teheran. Tytuł króla strzelców zdobył Hossejn Chatibi, który w barwach klubu Teraktor Sazi Tebriz strzelił 16 bramek.

Tabela końcowa

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Zespół Persepolis Teheran zrezygnował z udziału w lidze w tym sezonie z powodu zaangażowania w rozgrywkach międzynarodowych.

Najlepsi strzelcy

Zobacz też
 Iran Pro League

Bibliografia

1997 w piłce nożnej
1998 w piłce nożnej
Pierwszy poziom rozgrywek piłkarskich w Iranie
1997 w Iranie
1998 w Iranie

redpajama_set_name: RedPajamaWikipedia