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Trump Tax Plan Greatest Gift Establishment Ever Got
-- Published: Monday, 4 December 2017 | Print | Disqus
By David Haggith
As soon as President Trump put his Goldman boys, Gary Cohn and Steven Mnuchin, in charge of his tax plan, I knew Trump�s tax plan would never fulfill his and his henchmen�s promises of helping the middle class and of not giving additional tax breaks to the rich. The Trump Tax plan, as it now exists, proves those conjoined promises to be the greatest lie Trump ever told.
After two decades with Goldman Sachs, Munchkin (as he shall hereinafter be known for he lives on the Goldman-bricked road) bought his own bank, IndyMac. He renamed it OneWest and turned it into a mega repo machine in 2009, whirring out hyuuge amounts of crash cash during the Great Recession. His revamped bank set a speed record for putting homeowners out on the street, foreclosing one home every thirty seconds. A vice president of OneWest even admitted in court she shortened her signature so that she could spend less than thirty seconds processing each foreclosure. As a result of this rush to foreclose, the court found the bank had frequently mishandled documents because it did not even read many of them before foreclosing.
Munchkin�s grim reaper of a bank closed its greedy grip on a whopping 35,000 homes during the Great Recession. The bank was even so unscrupulous as to instruct homeowners to stop making payments, ostensibly because it was going to modify the loans, but in reality in order to purify its argument for repossession. (For more on the Munchkin�s greed, read �U.S. Treasury Becomes a Laughing Stock.�)
Cohn, meanwhile, was president and COO of Goldman Sachs during the years when the Goldman squid monstrously raped its own clients by encouraging them to make investments that it bet its own money against. Cohn claimed in his own testimony that never happened, and his defense consisted of arguing that his company lost money during the Great Recession, so this couldn�t be true � as if a complex company with many areas of business couldn�t lose money overall during a crisis while making money in one area of business where it bet against its own advice to its clients. (See WSJ: �Gary Cohn Testimony: Goldman Didn�t Bet Against Clients.�
The senate subcommittee Cohn was speaking to on the matter disagreed in its own conclusion:
�Investment banks such as Goldman Sachs were not simply market-makers, they were self-interested promoters of risky and complicated financial schemes that helped trigger the crisis. They bundled toxic mortgages into complex financial instruments, got the credit rating agencies to label them as AAA securities, and sold them to investors, magnifying and spreading risk throughout the financial system, and all too often betting against the instruments they sold and profiting at the expense of their clients.� (The Independent: �Goldman �bet against securities it sold to clients'�)
The SEC ultimately fined Goldman half a billion dollars for its dishonesty, and Goldman conceded to its dishonesty. (See �Goldman Sachs and The ABACUS Deal.�)
By placing these financial weasels in full charge of creating his tax plan, Trump proved to my satisfaction that he never intended to serve the middle class. Some people, however, did not accept my claims putting the worst swamp creatures in charge of his signature campaign pledge did not prove Trump would prove to be a Trojan horse for the establishment. Now that we have seen both Senate and House versions of the plan, however, the proof is in the pudding (the sloppy mess that envelops Trump�s tax plan).
The Trump tax plan, in either of its current conceptions, will be the worst thing that ever happened to America, even though it will certainly boost stocks, and I�ll tell you why below. Still, many will refuse to see the truth and will be addled in their evaluations down the road by the fact that the plan did kick the stock market into even higher gear.
Trump tax plan is a loophole haven for the richest of the rich
One of the biggest promises of tax reform was that it would, in Trump parlance, hyuugely simplify the tax code by eliminating loopholes. This loophole elimination would make sure that any reduction in the upper tax bracket for the rich did not create additional tax savings for the top one percent so that, this time around, tax revision would benefit the middle class.
Contrary to the Goldman boys� promises, both the senate and house versions of the Trump tax plan create the most massive tax cuts the rich have ever received because they leave most of the loopholes in place. Even President Reagan�s tax designer, David Stockman, calls the Trump tax plan �a wish list of � Wall Street.� Why wouldn�t it be when it was designed by Wall Street moguls whose snaky mouths revealed a forked tongue at their corner whenever they smiled and promised their plans would not include tax cuts for the rich?
This tax plan, in either incarnation, is the Christmas Wish Book for Wall Street, and it is built on total economic denial about the rampant deficits it will create as far as the eye can see.
The biggest loophole of all, the one loved by hedge-fund managers, lawyers and stock brokers, is left firmly in place. The House bill preserves for its wealthiest cronies on Wall Street the carried-interest tax loophole for private-equity managers, venture capitalists, hedge-fund managers and certain real estate investors � like Trump. Trump and Cohn specifically stated they were committed to ending this special provision that helps hedge-fund managers, but this grand loophole they bedeviled during the campaign is still there. (So, watch carefully to see how loudly they argue for its removal now that we can all see it remains firmly in place.)
The plan, as it stands in the Senate, allows �pass-through� businesses �. to deduct 22 percent of their income before paying taxes, up to a certain limit. In the House, it allows those pass-throughs to pay taxes at a special low rate. The pool of pass-through businesses includes any number of cookie shops and bodegas and corner stores, but also law firms, hedge funds, consulting firms, real-estate development companies, investment partnerships, and lobbying businesses. An estimated 70 percent of the benefits for such pass-through firms go to the top 1 percent of income earners�meaning this benefit is more about helping rich families than it is about helping small local businesses.
Moreover, such changes to the way pass-through businesses are taxed complicate the code and create a preferential category for rich individuals to try to work their income into�. The new provisions have �the potential to become the single greatest inducement to tax arbitrage ever enacted by a single Congress,� the tax expert Daniel Shaviro of New York University Law School has written, also saying that they �might end up being the single worst structural change in the history of the U.S. federal income tax.� (The Atlantic)
�After I saw that tax bill, I lost hope with the drain the swamp concept,� Gundlach said. �The swamp keeps getting bigger.� (NewsMax)
Swamp wins all in this plan. In either of its currently approved forms, the Trump tax plan trumps the middle class for decades to come!
Capital gains tax cuts preserved in Trump tax plan
If President Trump�s tax plan was intended to help the middle class, the first thing it would do is finally end the one tax provision that has created the biggest income disparity in history between the top ten percent of tax payers and all the rest of us. It would eliminate the special capital-gains tax break that has built real-estate bubbles and stock bubbles but done nothing to create jobs for the middle class in spite of endless promises that it will � promises that are now believed by blue-collar Republicans at the level of religious dogma.
While the new plans offer no additional capital-gains tax reduction for the rich, they keep this now sacred loophole locked in place. Republicans and Democrats wouldn�t dare talk about further reductions in this area because that would risk putting this special rate that has served the one percent so well at risk by putting it back into the discussion. Best to be happy with the massive gains the rich have already secured in this area and focus on opening entirely new areas of gains for the rich rather than to bring this up for discussion again.
I�m bringing it up precisely because they don�t.
Recently I�ve listened to Rush Limbaugh (because I listen to broadcasters on all sides) repeat and re-repreat his oft� told lie that the rich are already taxed more than the middle class because the rich � say the top twenty percent � pay more in income tax than the entire eighty percent beneath them. It�s a lie in the form of a half truth. Rush and others like him fully know this; but you will never hear them tell the remainder of the truth. The lie turns on your natural assumption when you hear the truth that 20% of the people are paying 80% of the income taxes � that the rich are clearly doing the lion�s share of the pulling.
Limbaugh and other establishment shills make it sound like the rich are incredibly generous but that only works because the real truth is so incredible � so obscene � that it never occurs to people. The untold half of this truth is that this 20% are making more than 80% of all the income in the US. So, if they were even paying an equal share, they would be paying more than eighty percent of all the income taxes in the US. (Limbaugh even as the audacity to rebrand himself as being anti-establishment as he repeats this old canard and supports Trump.)
Here�s the catch with the special capital-gains tax rate that has been enshrined in the tax code for decades: the rich do not make most of their money off of salaries! They make it off of their stock options in the companies they manage and other stock investments, and off of trading bonds and buying and selling real estate, football teams and art. All of the profit from those activities is taxed as capital gains, and if you hold those investments for longer than a year, income from those investments is all taxed at a rate that is insanely lower than the middle class income tax rates! The rich pay only 15%! (Only the top one percenters pay the slightly higher cap-gains tax rate of 20%, which is till lower than the tax rates paid on ordinary income by most of the middle class.)
Tell me that the privileged capital gains tax rate is not a tax savings that is almost exclusively for the richest of the very rich! Believe it not, 56% of the benefit of privileged lower tax rates on capital gains goes to the top 0.1% of the US population! Yes, you heard that right: not the top ten percent, not the top one percent, but just one-tenth of the top one percent receive 56% of ALL the tax savings realized by the nation�s preferred lower tax rate on capital gains!
That�s why this privileged loophole isn�t being talked about by anyone. It�s already the single-largest reason the rich pay far less than their fair share in taxes, and it is the single-greatest reason for the wealth disparity that has grown so wide in the US since the Reagan years. The form of money making that the rich use gets taxed at a much lower rate than your form of money making. That�s the dirty little secret that hides in plain sight.
The fact that the richest people do not make their money off of wages and salaries explains why Donald Trump could not care less about getting paid a salary to be president. His willingness to forego a presidential salary was pure showboating because even a presidential salary is chump change compared to how much money the Donald will make from becoming president if his new tax cuts become law (and how much he already saves by this preferential rate on his gains from real-estate investments which is new tax plan preserves for him and his kind). What Trump�s tax plan does is continue to enshrine for years to come the disproportionately beneficial tax treatment the rich already receive for their primary source of income.
Yet, the middle class majority happily allows the rich this filthy special privilege on their kind of income. They are beguiled by the current top income-tax rate of 39.6%, which is nothing but smoke and mirrors, to believe the rich are paying higher taxes. In truth, the rich rarely even pay that higher rate on their ordinary income due to loopholes, but ordinary income is by far the SMALLEST source of their personal income. That high tax rate is simply there to complete the illusion so the middle masses will continue to believe the rich are already doing more than their fair share. It enables Rush and others to say, �Look, the Rich are already paying more than their fair share.�
The establishment Republican�s argument for this privileged from of income in the tax code has always been that a lower cap-gains tax rate creates jobs. Really? Do you suppose that people getting capital-gains tax breaks are spending their savings building new factories, as Ronald Reagan promised they would when he first trotted out voodoo economics?
Of course, they are not. Why on earth would they? They use the money to buy more stock in companies that already exist, bidding up the stock market because that is the low-hanging fruit. Why would anyone build a factory in the US or any other kind of business that creates jobs with their tax savings when the deferred profit from that factory would all have to be taxed as ordinary income? Why would you try to reinvest your tax savings in a area where your next profits will be taxed at a much higher rate? That�s insane. Why wouldn�t you, instead, invest in more stocks where the future gains on your re-investment will all be taxed at the preferred cap-gains tax rate you just enjoyed? The concept that the rich would ever invest in new factories is ludicrous just from a simple tax principle.
Show me the thousands of new factories created across America since we started down this road under Reagan. Show me how the middle class has seen its income grow. Show me how much middle-class benefits have grown during our decades of lower capital-gains tax rates. Show me how the continuance of these low rates kept us out of economic crashes in the intervening years by providing sustained economic growth from Reagan to now. (A privileged rate has been in play that long, but we�ve had plenty of busts during that time.) Show how in any manner the middle class is better off today � more robust � because of this huge tax gift to the so-called �job creators.�
Even if you assume the rich are too dumb to reinvest the money they save back into stocks where they can continue to benefit from a much lower tax rate, why would they invest in building new factories with all the liabilities and legal and political obstacles involved in building a factory? Why would you take on the huge risk of a new venture when you can just invest in a going concern? It�s ludicrous to think that is where this tax savings goes.
So, why on earth do blue-collar Republicans continue to believe it is only fair to give the richest of all Americans a MUCH LOWER tax rate on the largest portion of their income than the middle class pays? (I put it in caps and underline it to scream it out because for decades people keep believing the nonsense that the rich establishment feeds them, and Democrats really do nothing to stop it because they serve the same establishment.)
Why? Because of the pure fantasy that someday they will be there. When their ship finally comes in, they don�t want it taxed away. It�s a lottery mentality. As in any lottery or casino, the jackpot almost never comes, but it hits just often enough to keep the fantasy afloat.
Follow the money. Where has the tax savings really gone? It was used to bid up the price of ball teams, to bid up the stock market, to bid up the real-estate market, to buy bigger yachts and more lavish mansions and bigger car collections and art collections. That�s why most of those things have appreciated extravagantly while the middle class has shrunk.
The savings are thoroughly locked up in assets that will be passed along (mostly untaxed) to the wealthiest of children, who will either piss it all away or, in rare cases, continue to build up daddy�s dynasty � not by creating jobs, just by hoarding more assets.
Disgustingly, there is one exception to the Republicans� choice not to tangle with capital-gains tax breaks under the new Trump tax plan. In the one area of capital gains that helps the average person the most � the elimination of all capital-gains tax on the first $250,000 in gains on the sale of one�s personal residence ($500k per couple) � Republicans want to make that exemption harder for the average person to get. They are now raising the number of years one must have resided in their personal residence from two years to five. It must have bothered members of congress to see that this tax exemption helped the average person disproportionately compared to the rich for whom the first $250,000 would be a small part of their total gains on the sale of their mansions. They also want to remove the tax loss you can claim if your house burns to the ground.
Trump tax plan completely eliminates the estate tax
Trump and his good ol� Goldman boys score a victory that inures purely to the top one percent with this one, which means the beneficiaries include Trump. This gift goes only to the rich because the federal inheritance tax already includes an exemption for the first $5.49 million of any estate PER HEIR. (i.e., an $11 million exemption per married couple, even though � with the exception of the deepest backwoods swampy parts of the south � only one person in any couple is an actual heir by blood.
The estate tax has already been whittled down by Bush and others over the years to where only 0.2% of the estates in the US ever pay any estate/inheritance tax. In it�s already reduced form, the estate tax is a tax that only hits the dynasties of the wealthiest of all Americans, but the effective tax (already much lower than it used to be) can range as high as 40% of the estate. (Because of the massive exclusion, no estate ever pays anything near the rate of 50% that you hear people talk about.) The average windfall for the top 0.2% from the elimination of this tax will be about $3 million PER HEIR. For the cr�me de la cr�me, however, the tax savings is $20 million per heir and higher.
Those who love to feed the rich on a silver spoon call this a �death tax,� even though no one who dies in America pays this tax. It is only the very richest of wealthy heirs who continue living who pay this tax on the gift they receive from daddy�s dynasty.
Now you can see why Donald Trump, in his eighties, is willing to work the presidency for just $1 per year. When you are the Donald�s age and have so much time and ego tied up in establishing vast real-estate holdings, your greatest concern is preserving the empire you have worked your life to build and that displays your ego, especially when your name is written all over it. Handing down the dynasty into which you were born and which you further developed is your last great ego accomplishment, and the complete repeal of the estate tax will assure that all of the Donald�s wealthy children inherit the entire empire unbroken, completely tax free.
Trump�s nemesis, The New York Times, calculates this revision in the tax code will save Trump�s heirs over a billion dollars, making this one reform the greatest Christmas gift the Donald could give those who will remain as an extension of his ego when he passes on. This tax savings clearly does nothing to create jobs. It merely assures that the family mansions remain occupied by the progeny of the Great One.
The original idea of the estate tax was to plow these tycoon estates back into the common ground so they don�t keep building up as ever-expanding empires for generations to come. Those who feel sorry for the top 1% should be in favor of this tax break. This one serves only to make sure the families of the banksters of Wall Street keep their ill-gotten gains. At best for all the rest, it may assure we retain a handful of jobs as gardeners, butlers, and maids to warm their milk and tie their ties.
If you believe the nonsense that repeal of the estate tax will save some family farms, ranches and small businesses, forget it. Only about 80 small businesses and family farms in the entire United States would pay any estate tax in 2017 under current law, and most of those would pay very little because of the large exemption. It is estimated that those 80 farms and businesses that get taxed as estates in any year pay less than 6% of the estate�s value in inheritance tax.
Some will say that it is unfair to go after the rich, but consider how many of them are banksters who made their wealth in unscrupulous manner and who were bailed out by you when they broke their banks. This tax is a final way to claw back those unscrupulous gains after you�ve allowed the banksters to enjoy them to the end of their lives. If fact, I think it is a fairly safe bet that most of the 1% have only climbed to that rarified height by employing some fairly unscrupulous tactics. (Not all; just most. Call me jaded.)
If the Donald really cared about the middle class, he�d eliminate of the manifold loopholes (such as grantor retained annuity trusts) that the rich use to dodge estate taxes altogether. Most large estates would have sufficient liquid assets to cover the tax, and existing law allows payments to be made at little interest over a period of fifteen years. (Remember, that estates often have large sources of income they can use to make these payments without having to sell off assets.)
Of course, the assets of major estates like the Donald�s � whether tied up in buildings or stocks or art � is wealth that has appreciated during the many years those assets were held, which means the rich have not paid any capital-gains tax on that added wealth before passing the gain down to their children. It is entirely untaxed wealth accumulation (if there is no estate tax) that gets passed along and continues to build tax free until the asset is finally sold.
That is one of the big reasons estate tax was created in 1916 � to stop this pass through of completely untaxed gains by people like the Rockerfellers and Vanderbilts, who owned vast amounts of stock in their own corporations. Wouldn�t it be ghastly if the top one percent of rich kids had to work for their money, instead of just inherit it all tax-free after it has gained in value for decades?
Given the minuscule number of people who will benefit from this Trump revision, you might think elimination of the estate tax does not amount to enough government revenue being lost to even be worth contemplating. But think again: current estate taxes, reduced as they already are, provide enough revenue each year to fund the entire Food and Drug Administration and the Centers for Disease and Prevention and the EPA. O.K. so you�re one who hates the EPA. No problem, just substitute in the National Parks Service or some branch of government that you somewhat like.
You start talking about a billion dollars here and a billion dollars there, and pretty soon you�re talking about real money.
Trump tax plan cuts corporate income tax from 35% to 20%
I�m not opposed to eliminating corporate income tax on the basis that it is double taxation. (First, you tax the profits of the corporation as a corporation. Then you distribute the remainder of those profits to the stockholders and tax them again as personal income.) I also see that corporations are job-producing economic giants, so I can see an argument that says, �Let�s not suck all the fuel out of our economic engines. Tax it when it only when becomes personal income.�
HOWEVER, and it is a BIG �however� that must be writ large, that is not what will happen with this huge corporate tax cut. If Trump and his sly Goldman boys wanted to do that, their corporate tax cuts would come with restrictions that make certain the money is used for job creation. The problem I have with this huge new tax break is that it comes with no such provisions.
Here is what will really happen with almost all of that money, and we know if for a fact because of years of experience: stockholders have established a clear pattern in this country of making themselves rich through stock buybacks, which do nothing whatsoever to grow the business or to create jobs. That is what will happen with nearly all of these tax savings. Now that central banks are promising to suck money out of the system, which has fueled stock buybacks up to the present, the Trump Rescue team is coming in with a HYUUGE new source of money.
Corporate boards will spend their newfound tax savings either buying up other corporations and consolidating (which always kills jobs; it never creates jobs) or spend it on stock buybacks and dividends to shareholders. Here again, the top ten percent of the population benefit disproportionately over the rest of the populace.
Stock buybacks do two things simultaneously that directly benefit the rich board members who who are the ones who vote to do the buybacks: 1) they reduce the supply of shares on the market, bringing up the value of each remaining share; 2) they create a huge buyer (the corporation) that is more than willing to buy the board members� own stocks at any escalating price in order to keep pushing the price up.
The Dom Perignon corks will be popping all over Wall Street if this one becomes law as it is the biggest boost the establishment has seen since capital-gains tax breaks were introduced. It�s a whole new realm for growth in income disparity.
Now, if Trump ever intended to help the middle class or Cohn and Munchkin ever intended to live up to their promises that there would be no tax cuts for the rich, then this tax cut would come with the clear restriction that no company benefiting from the lower corporate tax rate could engage in stock buybacks or use it to boost dividends. I�ll bet you haven�t heard ANY talk about that, and you never will because it was always Trump�s, Cohn�s, and Munchkin�s intention to give the greatest tax break in history to the supremely rich and cover it by saying, �This is to help businesses build jobs.� No, if you wanted it to build jobs, you�d put provisions in the tax code that require all of this tax benefit to be spent doing exactly that! Then it would actually juice the overall economy and not just the stock market. Not there!
Ask yourself one question: Why would an American board of stockholders, infamously known as they are for focusing on short-term quarterly gains, choose to reinvest billions of dollars saved on corporate taxes into creating new US factories with all of the regulations, liabilities, employment issues, construction issues, etc. that are involved in such expansion when they can just buy back the company�s stocks, making their own shares worth 20% more every year with no effort and no liability and no wait for a return on investment?
There will be NO jobs created from this kind of corporate tax cut unless it comes with restrictions, which it won�t because job creation has never been the real concern. What will be created, if some form of the Trump tax plan passes both houses, is more inflation in the speculation-driven stock market � and about a trillion dollars (some say much more) of additional federal debt to pay for this gift to the rich so they can continue to play in their casinos a little longer before the tops come down.
You now know that Republicans only talk like deficit hawks when they know they�re not the party that will be in charge of actually passing a budget. This year, when they finally control all branches of government, fiscal spending was higher than in any year in the history of the US government, other than 2009 when the stops were first pulled out to try to end the financial crisis. The deficit from their profligate spending this year was well over half a trillion dollars, and that was with the second-highest income-tax revenue in the history of the United States, which will be greatly reduced if some version of this plan makes it through both houses.
Surprise, surprise, Republicans are not truly deficit hawks at all! Their debt concerns were pure fraud. It was easy to sound like they cared about fiscal responsibility when they knew Democrats would be the ones deciding the budget. The Republican budget recently passed didn�t curb any of this spending, and the projected revenue increases of the present tax plans are based on dreams that were already disproven in the Reagan era, when even Reagan�s tax man has admitted the administration had to scramble to quickly raise taxes back up some because of the yawning debt that immediately opened up when revenue failed to grow due to tax cuts to the extent the administration had promised. These cuts go far beyond those, so the damage will be worse.
You might wonder how Republicans are managing to pass these huge deficits through the Senate while avoiding the filibuster. The answer is, they are scheduling all the individual tax breaks that bust the budget to end in 2025. In fact, people making less than $75,000 a year will see a tax increase by 2027. That allows tax revenue to go back up just as the new tax plan becomes ten years old, meeting the �reconciliation� process says there can be no filibuster unless a bill creates a greater deficit ten years down the road.
While there will still be massive deficits after 2027, even with the end of the middle-class tax breaks, the Republican choice to run a massive deficit this past year has enabled them to establish an easy deficit threshold to come back down to. While the individual tax breaks that slightly help the middle class end quickly, the corporate tax breaks and capital-gains breaks that primarily help the rich will continue forever.
Middle class bears the burdens of breaks for the rich under Trump�s tax plan
The middle class pays for these tax-breaks to the rich by having their mortgage interest deduction capped, as well as their property tax deduction and their deductions for state and local taxes. These caps or eliminations hit the fabulously wealthy, too, but the wealthy get all the new benefits to far more than compensate while the middle class does not.
A study by Congress�s nonpartisan Joint Committee on Taxation says the senate plan will raise taxes for 13.8 million moderate-income American households making between 75,000 a year and 200,000. After 2023, 22% of Americans will pay more in taxes (and none of those will be in the one-percent class).
While the Trump tax plan throws a little candy in the form of tax breaks for the middle class initially to smooth its passage, you get trumped bigly in the end.
Even with all this boost for the establishment, Trump was not satisfied with the tax benefits for the rich and asked that even the smoke-screen 39.6% top income-tax rate be brought down to 35%. Even the window dressing rate apparently appeared too hard on the rich.
Trump is such a good snake-oil salesman that he has actually managed to con the middle class into cheering him with slogans at rallies as he shafts them and their children to enrich himself and his children in the years to come. His legacy will be that his kids are much richer than they are now, and yours are not. Cheer him all you want, but that�s where this ends up.
Kept entirely out of the tax discussion are payroll taxes, such as Social Security and Medicare where the rich pay much less as a percentage of their total income because those taxes have low caps on them and do not apply at all to capital gains. The rich pay nothing on any income above a certain level.
Democrat or Republican politicians prefer not to talk about that. What they talk about, instead, is the need to someday cut the amount you are entitled to. (You are entitled because they promised when they took your money they would give it back to you as retirement, so it is YOUR money they have been holding in trust. You�re entitled to it, because they took it from you with a promise to give it back later.) Instead, of cutting back on what the middle class is entitled to (since it was all their money taken in trust), they should talk about removing the tax caps that protect the rich in order to end the entitlement problem. They won�t.
If Trump and Republicans wanted real tax reform, they would eliminate income tax entirely and replace it with a value-added tax (or better yet, a simple sales tax on the end consumer), which would allow them to end the tyranny of the IRS by cutting the agency�s size by 90%, as sales tax is such an easy tax to monitor and collect. THAT would be true reform. Instead, their much ballyhooed reforms still leave us with the most complicated tax system in the world!
If these tax plans are reconciled and approved in something near their current shape, there will be a lot of merry moguls this Christmas.
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Amiens, a very attractive northern France city Sometimes called the "Little Northern Venice" because of its canals, Amiens is a 134.000 inhabitants city located in the North of France. In the middle of the Paris-London-Brussels triangle, it is a one of the most attractive city of the country. Learn more about Amiens
Book your journey from Arras to Amiens From €12 €13
1 ARRAS
06:37 AMIENS
06:37 ALBERT
2 ALBERT
06:37 07:37 01:00 1 1 1 1 0 1 0 0
1 AMIENS
05:38 ARRAS
Calais - Amiens
Paris - Amiens
Amiens - Calais

redpajama_set_name: RedPajamaCommonCrawl


text:
Q: bootstrap 3 grid issue - small columns overriding medium or larger I'm having an issue with the bootstrap grid. I'm trying to create (3) four column divs on medium screens, on small screens I'm trying to create six column divs that are offset 3 columns so they are centered. and on extra small screens twelve columns. Seems like something I've done a million times… but on medium or larger they are stacking using the .sm class… not sure what's happening?

col-xs-12 col-sm-6 col-sm-offset-3 col-md-4

col-xs-12 col-sm-6 col-sm-offset-3 col-md-4

col-xs-12 col-sm-6 col-sm-offset-3 col-md-4

here is a codepen: https://codepen.io/aaron4osu/pen/Powpezo

A: Your post is a bit confusing, but I'll try to help.
Your first issue is using .col-offset- improperly which is preventing your columns from operating correctly (read more about offsetting here: https://getbootstrap.com/docs/3.4/css/#grid-offsetting)
Your second issue is using .col-sm-6 three times.
With the Bootstrap grid system, your column classes must always equal 12 (because it's a 12 column grid). Having .col-sm-6 three times equals 18 (not 12) so Bootstrap will push your 3rd .col-sm-6 column underneath the others.
Also, always wrap a .container or .container-fluid around your .row or you're going to run into problems later like horizontal scrolling.
And finally, to center your divs on sm and xs, just use .col-xs-12 and then your divs will be centered (and 100% width) until they reach the .col-md- breakpoint, and then they will be .col-md-4 (3 columns, because 4 goes into 12 three times):

Column 1

Column 2

Column 3

redpajama_set_name: RedPajamaStackExchange


Saffiano Cuir, Black With Three Zipper Compatments With Middle Having An Additional Zipper And Two Pockets For Storage. Minor Scuff Mark In Front Of Bag(Pictured) Barely Noticeable. Worn Last Winter. Comes With Everything Pictured. Still Smells Like New Leather. Great Bag.


text:
Q: Dealing with model save and update with GWT Platform I'm trying to adapt my GWT web application from my home-grown MVC to GWT Platform.
I've managed to port the my application views with presenters, and essentially able to access views via PlaceRequest. And with changing the URL (#).
However I am not sure how to deal with Models using this GWT platform, in the common MVP I know there is a go() method in the presenter which fetches data, say from server via RPC.
In the GWT platform presenter here are the methods automatically generated by the Eclipse plugin:

*

*Constructor

*revealInParent

*onBind

*onReset

Where should I put the RPC code that will fetch and update my model. Say in the presenter I have:
ProfilePresenter.java:
public class ProfilePresenter
        extends
        Presenter<ProfilePresenter.MyView, ProfilePresenter.MyProxy> {

    public interface MyView extends View {
        HasText getFullname();
        HasText getLocation();
        HasText getAboutme();
        HasText getLastlogin();
    }

    private User user; // Model which represents the User information etc.

And when the View associated with the Presenter is shown I need to fetch the User model from the server and update the model and then subsequently update the view through the interfaces it expose.
Also, say I have some buttons in the view, which then can be accessed by the presenter through HasClickHandler where should I put the event handlers?

A: I would put the RPC call in the onReset method.
See the presenter lifecycle
Personally I deal with events using the reversed MVP pattern. But you can also call a handler this way:
    getView().getSubmitButton().addClickHandler(new ClickHandler() {
        @Override
        public void onClick(ClickEvent event) {
        }
    });

with the following signature for getSubmitButton in your view interface:
HasClickHandlers getSubmitButton()

A: Sydney covered most of your questions.
In general onResetmethod is a good place to make backend calls.
Sometimes when the backend call takes longer and you want to display the view only after the data was loaded you can use manual reveal.
But for the profile page I don't think that is necessary.
I also agree with the reverse MVP pattern. It's way easer to test presenters using the reverse MVP Pattern than using the HasXXXHandlers interfaces.


Bomb (item) - WiKirby: it's a wiki, about Kirby!
Bombs are common items in the Kirby series. Almost without exception, they resemble common cartoon bombs - that is - black and blue spheres with a fuse on top. When tossed or spat, they explode on contact with enemies, dealing a large amount of damage.
Bombs were first seen in Kirby's Dream Land. They appear in fixed locations in certain stages, starting with Castle Lololo. Kirby can inhale them, but if he swallows them, nothing will happen. To use the bomb, Kirby has to spit it out, causing it to fly forward and explode, with a similar effect to a Penetrating Bullet. If left alone for too long, however, the bomb will blow up on its own.
In Kirby Air Ride, bombs appear as items in the Top Ride mode. Here, when picked up, Kirby gains the ability to toss up to six bombs in succession, knocking around any foe they hit. The bomb can be dropped prematurely if Kirby is hit, performs a Quick Spin, or falls into a stage hazard.
Aside from these instances, and more specific bombs listed below, bombs largely disappeared as a unique item when the Bomb Copy Ability came into common appearance.
Balloon Bomb - A bomb from Kirby's Return to Dream Land which grows in size and power as it is carried.
Sensor Bomb - A bomb that acts as a time/proximity mine in the City Trial mode of Kirby Air Ride.
Timed Dynamite - A bundle of dynamite on a timer which appears in Kirby: Triple Deluxe and Kirby: Battle Royale.
This page was last edited on 28 January 2018, at 21:48.


Bedroom Ideas For 7 Year Olds is free HD wallpaper. This wallpaper was upload at 04/06/2019 upload by darylfarahi in Bedroom Decoration.
Bedroom Ideas For 7 Year Olds is high definition wallpaper and size this wallpaper is 2400x1600. You can make Bedroom Ideas For 7 Year Olds For your Desktop Wallpaper, Tablet, Android or iPhone and another Smartphone device for free. To download and obtain the Bedroom Ideas For 7 Year Olds images by click the download button below to get multiple high-resversions.


It took me about 10 minutes to pass completely to the other side of the chanel. I realized it once I met Ryuzo there. As the game of creatinh a chanel and then passing through it finished, i set out to a new one: to mistranslate the whole work done in Cankarjev dom till now.
It took me some time. The most noteable effect of this was losing the grip on navigating my flow of mistranslation. It happened before in today's session. What I enjoyed there was observing Samo realizing he lost the grip on navigating of the flow. Of course the urge is to gain control over navigation. Dance enables to redirect the energy of this urge into observation.
Surprisingly also this game ended before the 7 x 7 minutes. So I took a new one and started to mistranslate what happened up till now. By this time the awareness started to seriously disintegrate and body awareness took over the navigation.
At one point I wanted to go to TV show presenter, but could not really navigate the flow there. It felt like we were in a membrane that I did not wanted to pierce through today.
All this is but a nice story. It might be true. It might be not. It might be important that it is true, it might not. The mistranslation actually puts extra demand on the tools and principles that do not support coding (capital's way). I have no name yet for them. Actually it is questionable if they have name. I know their effects. The tools that do not support coding send you to the extreme, edge, rim, border. They do that by their nature and could be seen by statistically normal person as wrong, demaged, useless. To take mistranslation as ground tool, send these tools and effect beyond that. This is my interpretation of Ryuzo saying: I want to improve states, tools, prinicples of work by mistranslation.


text:
Ghiyasuddin Mahmud Shah (, ) was the last Sultan of the Hussain Shahi dynasty of the Bengal Sultanate, reigning from 1533 to 1538 CE. The dynasty was founded by his father, Alauddin Husain Shah, in 1494.

History
Banglapedia assesses him as a "weak, pleasure loving and easy-going ruler" who "...had neither diplomatic foresight, nor any practical approach to the political problems which beset Bengal during his reign." His reign was marked by rebellions, including those by Khuda Bakhsh Khan, his general and governor of Chittagong, and Makhdum Alam, the governor of Hajipur.

During his reign the Portuguese arrived in Chittagong in 1534, and were captured and sent to Gaur as prisoners on charges of mischief. But, in the face of enemy superiority he reconciled with them and permitted them to establish factories and commercial stations at Chittagong and Hughli. Later, with the help of the Portuguese, the Sultan held the Teliagarhi pass (1536 AD) avoiding the invasion.  Ghiyasuddin Mahmud Shah and his Portuguese allies were defeated by Sher Shah Suri on 6 April 1538, as his appeals to the Mughal Emperor Humayun went unanswered.

See also
 List of rulers of Bengal
 History of Bengal
 History of Bangladesh
 History of India

References

1538 deaths
1533 in India
Year of birth unknown
16th-century Indian monarchs
Hussain Shahi dynasty

redpajama_set_name: RedPajamaWikipedia


Who Can Solve Your Plasma Physics Homework Problems?
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text:
Last edited 05 Jul 2019
Design and access statement
From 25 June 2013, design and access statements are only required for buildings of more than 1,000 sq. m, housing developments of 10 dwellings or more and developments requiring listed building consent. In conservation areas, design and access statements are required for single dwellings or buildings of more than 100 sq. m.
Requirements for design and access statements must also be proportionate to the scale of the proposed development, and any information requests must be necessary to validate the application. Applicants are allowed to challenge demands that they think are unnecessary and local authorities then either have to justify the demand or waive it.
For more information see The Town and Country Planning (Development Management Procedure) (England) (Amendment) Order 2013.
Design and access statements are prepared as part of the documentation to support a planning application. They explain the design principles and concepts that have been applied to particular aspects of the proposed development. Design and access statements may include plans, elevations and other illustrations, photographs and for large or complex schemes a model of the proposed development.
Design and access statements should explain:
Amount (how much development is proposed). For residential development, this the number of proposed units and for all other development, the proposed floor space for each proposed use.
The relationship between buildings and public and private spaces within and around the site.
Accessibility of the site for users, such as travel distances and gradients, and the orientation of blocks and units in relation to any site topography to afford optimum accessibility.
The impact of the layout on the energy consumption and thermal comfort during winter and summer performance.
Crime prevention measures.
The height, width and length of a building or buildings in relation to its surroundings.
The size of building parts, particularly entrances and facades.
Why particular heights have been selected.
How these relate to the site's surroundings and skyline.
How they relate to the human scale.
Purpose of landscaping private and public spaces.
Its relationship to the surrounding area.
A schedule of planting and landscaping materials.
Appearance of the development:
The appearance of the place or buildings proposed.
How this relates to the appearance and character of the development's surroundings.
How the decisions about texture, contrast, tone and lighting have considered accessibility.
Steps taken to understand the local context (physical, social and economic characteristics as well as planning policies).
How local context has influenced the design.
Consultation with the local community and local access groups as well as with local authority planning, building control, conservation and design and access officers. Explanation of how these views have been take into account.
Opportunities, constraints and conflicting issues.
Proposed use or uses.
Their distribution across the site.
Accessibility to and between them.
Their relationship to uses surrounding the site.
Access (access to the development, not internal aspects of buildings):
Access to buildings, spaces and transport.
Flexibility and responsiveness to changing needs.
Any consultation undertaken.
Access for emergency services if appropriate.
NB: The National Planning Policy Framework makes clear that there should be a presumption in favour of sustainable developments. This should be reflected in design and access statements.
Building regulations.
Constraints.
Detailed planning application.
Outline planning application.
National Planning Policy Framework.
Planning permission.
Statutory approvals.
Sustainability.
Department for communities and local government guidance on planning.
Planning portal guidance on design and access statements.
CABE guidance on design and access statements.
The Town and Country Planning (Development Management Procedure) (England) (Amendment) Order 2013.
Retrieved from "https://www.designingbuildings.co.uk/wiki/Design_and_access_statement"
http://www.legislation.gov.uk/uksi/2013/1238/article/4/made
This says 'the provision of a building or buildings where the floor space created by the development is 100 square metres or more.' Not 1000sqm.
Is this an error?
That is only in designated areas - ie conservation areas.
View comments history


The authors reviewed data from three U.S. studies and found that the risk of suicide for adults who drank two to four cups of caffeinated coffee per day was about half that of those who drank decaffeinated coffee or very little or no coffee.
A medication typically prescribed to treat heart failure and cardiac arrhythmia is one of the few drugs that is inactivated by gut microbes, said Peter Turnbaugh (left), the senior author of a new paper on the topic. The research also identifies a possible way to stop the process from happening. Turnbaugh is pictured with Henry Haiser, who worked with him on the research.


text:
<?php
if(!defined('sugarEntry') || !sugarEntry) die('Not A Valid Entry Point');

/**
 * Homepage dashlet manager
 * @api
 */
class MySugar{
	var $type;

	function MySugar($type){
		$this->type = $type;
	}

    function checkDashletDisplay () {

		if((!in_array($this->type, $GLOBALS['moduleList'])
				&& !in_array($this->type, $GLOBALS['modInvisList']))
				&& (!in_array('Activities', $GLOBALS['moduleList']))){
			$displayDashlet = false;
		}
		elseif (ACLController::moduleSupportsACL($this->type) ) {
		    $bean = SugarModule::get($this->type)->loadBean();
		    if ( !ACLController::checkAccess($this->type,'list',true,$bean->acltype)) {
		        $displayDashlet = false;
		    }
		    $displayDashlet = true;
		}
		else{
			$displayDashlet = true;
		}

		return $displayDashlet;
    }

	function addDashlet(){
		if(!is_file(sugar_cached('dashlets/dashlets.php'))) {
            require_once('include/Dashlets/DashletCacheBuilder.php');

            $dc = new DashletCacheBuilder();
            $dc->buildCache();
		}
		require_once sugar_cached('dashlets/dashlets.php');

		global $current_user;

		if(isset($_REQUEST['id'])){
			$pages = $current_user->getPreference('pages', $this->type);

		    $dashlets = $current_user->getPreference('dashlets', $this->type);

		    $guid = create_guid();
			$options = array();
		    if (isset($_REQUEST['type']) && $_REQUEST['type'] == 'web') {
				$dashlet_module = 'Home';
				require_once('include/Dashlets/DashletRssFeedTitle.php');
				$options['url'] = $_REQUEST['type_module'];
				$webDashlet = new DashletRssFeedTitle($options['url']);
				$options['title'] = $webDashlet->generateTitle();
				unset($webDashlet);
		    }
			elseif (!empty($_REQUEST['type_module'])) {
				$dashlet_module = $_REQUEST['type_module'];
			}
			elseif (isset($dashletsFiles[$_REQUEST['id']]['module'])) {
				$dashlet_module = $dashletsFiles[$_REQUEST['id']]['module'];
			}
			else {
				$dashlet_module = 'Home';
			}

			    $dashlets[$guid] = array('className' => $dashletsFiles[$_REQUEST['id']]['class'],
										 'module' => $dashlet_module,
										 'options' => $options,
			                             'fileLocation' => $dashletsFiles[$_REQUEST['id']]['file']);

		    // add to beginning of the array
		    array_unshift($pages[$_REQUEST['activeTab']]['columns'][0]['dashlets'], $guid);

		    $current_user->setPreference('dashlets', $dashlets, 0, $this->type);

		    echo $guid;
		}
		else {
		    echo 'ofdaops';
		}
	}

	function displayDashlet(){
		global $current_user, $mod_strings, $app_strings;

		if(!empty($_REQUEST['id'])) {
		    $id = $_REQUEST['id'];
		    $dashlets = $current_user->getPreference('dashlets', $this->type);

		    $sortOrder = '';
		    $orderBy = '';
		    foreach($_REQUEST as $k => $v){
		        if($k == 'lvso'){
		            $sortOrder = $v;
		        }
		        else if(preg_match('/Home2_.+_ORDER_BY/', $k)){
		            $orderBy = $v;
		        }
		    }
		    if(!empty($sortOrder) && !empty($orderBy)){
		        $dashlets[$id]['sort_options'] = array('sortOrder' => $sortOrder, 'orderBy' => $orderBy);
		        $current_user->setPreference('dashlets', $dashlets, 0, $this->type);
		    }

		    require_once($dashlets[$id]['fileLocation']);
		    $dashlet = new $dashlets[$id]['className']($id, (isset($dashlets[$id]['options']) ? $dashlets[$id]['options'] : array()));
		    if(!empty($_REQUEST['configure']) && $_REQUEST['configure']) { // save settings
		        $dashletDefs[$id]['options'] = $dashlet->saveOptions($_REQUEST);
		        $current_user->setPreference('dashlets', $dashletDefs, 0, $this->type);
		    }
		    if(!empty($_REQUEST['dynamic']) && $_REQUEST['dynamic'] == 'true' && $dashlet->hasScript) {
		        $dashlet->isConfigurable = false;
		        echo $dashlet->getTitle('') . $app_strings['LBL_RELOAD_PAGE'];
		    }
		    else {
		        $lvsParams = array();
		        if(!empty($dashlets[$id]['sort_options'])){
		            $lvsParams = $dashlets[$id]['sort_options'];
                }
		        $dashlet->process($lvsParams);
		        $contents =  $dashlet->display();
                // Many dashlets expect to be able to initialize in the display() function, so we have to create the header second
                echo $dashlet->getHeader();
                echo $contents;
                echo $dashlet->getFooter();
		    }
		}
		else {
		    header("Location: index.php?action=index&module=". $this->type);
		}
	}

	function getPredefinedChartScript(){
		global $current_user, $mod_strings;

		if(!empty($_REQUEST['id'])) {
		    $id = $_REQUEST['id'];
		    $dashlets = $current_user->getPreference('dashlets', $this->type);

		    require_once($dashlets[$id]['fileLocation']);
		    $dashlet = new $dashlets[$id]['className']($id, (isset($dashlets[$id]['options']) ? $dashlets[$id]['options'] : array()));
	        $dashlet->process();
	        echo $dashlet->displayScript();
		}
		else {
		    header("Location: index.php?action=index&module=". $this->type);
		}
	}

	function deleteDashlet(){

		global $current_user;

		if(!empty($_REQUEST['id'])) {
		    $pages = $current_user->getPreference('pages', $this->type);
		    $dashlets = $current_user->getPreference('dashlets', $this->type);

				$activePage = '0';

			foreach($pages[$activePage]['columns'] as $colNum => $column) {
		        foreach($column['dashlets'] as $num => $dashletId) {
		            if($dashletId == $_REQUEST['id']) {
		                unset($pages[$activePage]['columns'][$colNum]['dashlets'][$num]);
		            }
		        }
		    }

		    foreach($dashlets as $dashletId => $data) {
		        if($dashletId == $_REQUEST['id']) {
		            unset($dashlets[$dashletId]);
		        }
		    }

		    $current_user->setPreference('dashlets', $dashlets, 0, $this->type);
		    $current_user->setPreference('pages', $pages, 0, $this->type);

		    echo '1';
		}
		else {
		    echo 'oops';
		}
	}

	function dashletsDialog(){
		require_once('include/MySugar/DashletsDialog/DashletsDialog.php');

		global $current_language, $app_strings;

		$chartsList = array();
		$DashletsDialog = new DashletsDialog();

		$DashletsDialog->getDashlets();
		$allDashlets = $DashletsDialog->dashlets;

		$dashletsList = $allDashlets['Module Views'];
		$chartsList = $allDashlets['Charts'];
		$toolsList = $allDashlets['Tools'];
		$sugar_smarty = new Sugar_Smarty();

		$mod_strings = return_module_language($current_language, 'Home');

		$sugar_smarty->assign('LBL_CLOSE_DASHLETS', $mod_strings['LBL_CLOSE_DASHLETS']);
		$sugar_smarty->assign('LBL_ADD_DASHLETS', $mod_strings['LBL_ADD_DASHLETS']);
		$sugar_smarty->assign('APP', $app_strings);
		$sugar_smarty->assign('moduleName', $this->type);

		if ($this->type == 'Home'){
			$sugar_smarty->assign('modules', $dashletsList);
			$sugar_smarty->assign('tools', $toolsList);
		}

		$sugar_smarty->assign('charts', $chartsList);

		$html = $sugar_smarty->fetch('include/MySugar/tpls/addDashletsDialog.tpl');
		// Bug 34451 - Added hack to make the "Add Dashlet" dialog window not look weird in IE6.
		$script = <<<EOJS
if (YAHOO.env.ua.ie > 5 && YAHOO.env.ua.ie < 7) {
    document.getElementById('dashletsList').style.width = '430px';
    document.getElementById('dashletsList').style.overflow = 'hidden';
}
EOJS;

		$json = getJSONobj();
		echo 'response = ' . $json->encode(array('html' => $html, 'script' => $script));
	}

	function searchModuleToolsDashlets($searchStr, $category){
		require_once('include/MySugar/DashletsDialog/DashletsDialog.php');

		global $app_strings;

		$DashletsDialog = new DashletsDialog();

		switch($category){
			case 'module':
				$DashletsDialog->getDashlets('module');
				$dashletIndex = 'Module Views';
				$searchCategoryString = $app_strings['LBL_SEARCH_MODULES'];
				break;
			case 'tools':
				$DashletsDialog->getDashlets('tools');
				$dashletIndex = 'Tools';
				$searchCategoryString = $app_strings['LBL_SEARCH_TOOLS'];
			default:
				break;
		}
		$allDashlets = $DashletsDialog->dashlets;

		$searchResult = array();
		$searchResult[$dashletIndex] = array();

		foreach($allDashlets[$dashletIndex] as $dashlet){
			if (stripos($dashlet['title'], $searchStr) !== false){
				array_push($searchResult[$dashletIndex], $dashlet);
			}
		}

		$sugar_smarty = new Sugar_Smarty();

		$sugar_smarty->assign('lblSearchResults', $app_strings['LBL_SEARCH_RESULTS']);
		$sugar_smarty->assign('lblSearchCategory', $searchCategoryString);

		$sugar_smarty->assign('moduleName', $this->type);
		$sugar_smarty->assign('searchString', $searchStr);

		$sugar_smarty->assign('dashlets', $searchResult[$dashletIndex]);

		return $sugar_smarty->fetch('include/MySugar/tpls/dashletsSearchResults.tpl');
	}

	function searchChartsDashlets($searchStr){
		require_once('include/MySugar/DashletsDialog/DashletsDialog.php');

		global $current_language, $app_strings;

		$chartsList = array();
		$DashletsDialog = new DashletsDialog();

		$DashletsDialog->getDashlets('charts');

		$allDashlets = $DashletsDialog->dashlets;

		foreach($allDashlets as $category=>$dashlets){
			$searchResult[$category] = array();
			foreach($dashlets as $dashlet){
				if (stripos($dashlet['title'], $searchStr) !== false){
					array_push($searchResult[$category],$dashlet);
				}
			}
		}

		$sugar_smarty = new Sugar_Smarty();

		$sugar_smarty->assign('lblSearchResults', $app_strings['LBL_SEARCH_RESULTS']);
		$sugar_smarty->assign('searchString', $searchStr);
		$sugar_smarty->assign('charts', $searchResult['Charts']);

		return $sugar_smarty->fetch('include/MySugar/tpls/chartDashletsSearchResults.tpl');
	}

	function searchDashlets(){
		$searchStr = $_REQUEST['search'];
		$category = $_REQUEST['category'];

		if ($category == 'module' || $category == 'tools'){
			$html = $this->searchModuleToolsDashlets($searchStr, $category);
		}
		else if ($category == 'chart'){
			$html = $this->searchChartsDashlets($searchStr);
		}

		$json = getJSONobj();
		echo 'response = ' . $json->encode(array('html' => $html, 'script' => ''));
	}

	function configureDashlet(){
		global $current_user, $app_strings, $mod_strings;

		if(!empty($_REQUEST['id'])) {
		    $id = $_REQUEST['id'];
		    $dashletDefs = $current_user->getPreference('dashlets', $this->type); // load user's dashlets config
		    $dashletLocation = $dashletDefs[$id]['fileLocation'];

		    require_once($dashletDefs[$id]['fileLocation']);

		    $dashlet = new $dashletDefs[$id]['className']($id, (isset($dashletDefs[$id]['options']) ? $dashletDefs[$id]['options'] : array()));
		    if(!empty($_REQUEST['configure']) && $_REQUEST['configure']) { // save settings
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		        $current_user->setPreference('dashlets', $dashletDefs, 0, $this->type);
		    }
		    else { // display options
		        $json = getJSONobj();
		        return 'result = ' . $json->encode((array('header' => $dashlet->title . ' : ' . $app_strings['LBL_OPTIONS'],
		                                                 'body'  => $dashlet->displayOptions())));
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		global $current_user;

		if(!empty($_REQUEST['layout'])) {
		    $newColumns = array();

		    $newLayout = explode('|', $_REQUEST['layout']);

			$pages = $current_user->getPreference('pages', $this->type);

			$newColumns = $pages[$_REQUEST['selectedPage']]['columns'];
		    foreach($newLayout as $col => $ids) {
		        $newColumns[$col]['dashlets'] = explode(',', $ids);
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			$pages[$_REQUEST['selectedPage']]['columns'] = $newColumns;
		    $current_user->setPreference('pages', $pages, 0, $this->type);

		    return '1';
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		else {
		    return '0';
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}

redpajama_set_name: RedPajamaGithub


text:
Your Tattoo Might Have Printer Ink or Car Paint in It
Emily Pratt wasn't impressed when she heard about the U.S. Food and Drug Administration probe into the potentially deleterious effects of tattoo ink. She would have shrugged to show how little she cared, but she was a bit sore from the tattoo machine that had just been smacking away at her left forearm.
This was her seventh inking, after all: a wrap-around bouquet of six roses in shades of yellow and red rendered at Embassy Tattoos in Washington. "The fact that I'm here," the 22-year-old said, recovering in the waiting room near a stuffed mongoose, "says I'm not worried about the side effects."
But the FDA is, as are some experts in the field. The concern has grown with the explosion in the body art's popularity and the availability of tools and inks online. The industry is growing about 9 percent a year, a rate research company IBISWorld projects will make it a $1.1 billion business by 2020.
"Even the most reputable places can't guarantee the safety of ink," said Arisa Ortiz, a dermatologist and assistant professor at the University of California, San Diego, and co-author of a 2011 article that cited reports by researchers in Spain, Germany and the U.S. who discovered substances including mercury and charcoal in tattoo dyes.
Industrial-Grade Colors
In the U.S., the inks are regulated as cosmetic products. The FDA can screen them before they hit the market but has rarely done so, according to its website, because of "competing public-health priorities and a previous lack of evidence of safety problems specifically associated with these pigments."
The agency does investigate when it receives complaints, and these have been on the rise: Hundreds have been filed since 2004 compared with just five between 1988 to 2003, reporting reactions including itching or scarring or inflamed skin even years after tattooing occurred.
One issue could be the proliferation of do-it-yourself equipment and inexpensive dyes, said "Sailor" Bill Johnson, vice president of the National Tattoo Association. "I've been using the same product for nearly 40 years and have never had a problem with it."
Scientists at the FDA's National Center for Toxicological Research in Jefferson, Arkansas, are exploring several aspects of ink's impact once it's been under the skin for a while, including how the chemicals metabolize in the body.
One-In-Four
"Many pigments used in tattoo inks are industrial-grade colors suitable for printers' ink or automobile paint," the agency says on its website. Chemists have discovered some yellows break down when exposed to sunlight or certain enzymes, though it hasn't been determined whether this is toxic. The FDA hasn't said when its ink study will be done.
By some estimates, about 30 percent of the U.S. population and one in four millennials sports at least one tattoo, though, according to the Pew Research Center, the majority have theirs in places that can be hidden from view.
"Tattooing has become mainstream," said Diane Pacom, a University of Ottawa sociologist. "The millennials, they're doing it as a statement of belonging to the system -- because everybody has tattoos now."
Including many filled with regret. Tattoo removal is also a growing business, with IBISWorld predicting it will be an $80-million-a-year industry in 2018, up from $40 million in 2008.
Would negative findings by the FDA greatly dim tattooing's allure? Lars Krutak, a tattoo-history expert at the Smithsonian Institution's National Museum of Natural History, doesn't believe so. After all, millions still smoke despite the risks. But what the FDA discovers, he said, may lead to "better regulation, quality standards, labeling and even the reclassification of tattooing ink itself."
The tastes of Generation Z may determine whether the U.S. has reached peak tattoo. Coming along behind the millennials, this cohort includes kids born from the mid-90s to the mid-2000s. According to researchers, Gen Z is more cautious and more driven to be successful after seeing older siblings struggle to find work and live with their parents in record numbers.
Anna Felicity Friedman, a tattoo historian who estimates 50 percent of her body is covered in ink, said no matter what the FDA concludes, the U.S. "may be at a tipping point in tattoo popularity." Young people she knows "are consciously deciding to remain untattooed, either to be rebellious, since tattoos are no longer a mark of rebellion, or to avoid being deemed a fashion victim."
Jason Recker, a 15-year-old from Peoria, Illinois, has already done some research. "You don't see a lot of tattoos on lawyers and engineers and teachers," he said, considering future careers. "I don't think I'll want to get a tattoo when I'm old enough."


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Meet the horses of Mackinac Island's Grand Hotel
By Tanda Gmiter | Posted July 10, 2019 at 07:36 AM
Photo courtesy of Grand Hotel
By Tanda Gmiter | MLive
MACKINAC ISLAND, MI - When you are visiting Mackinac Island's Grand Hotel, you're never very far from the elegant, high-stepping silhouette of a Hackney horse.
The hotel keeps a four-legged fleet of this special breed of horse, which is used to pull the light, fancy carriages carrying VIP guests and the hotel owner's family. But more than that, the Hackney has become Grand Hotel's signature image.
It's part of the logo that graces each email and receipt from the iconic, column-fronted resort. The horse's image is stitched on shower curtains in each guest room, and is even painted on the bottom of its famous swimming pool.
But this summer has been a big transition season for the Hackneys who call Grand Hotel Stables home. Of the eight Hackney horses there, five are new to Mackinac Island.
"This is a huge turnover year for us with the Hackneys," Stable Manager Ben Mosley said.
As fall approached last year, Mosley knew it was time for him to find new homes for a handful of the 2018 horses. Some had been part of Grand Hotel's family for a few years. One had worked there for a decade.
Settling them into good homes that fit their personalities would take a little work, he knew. But so would selecting new Hackneys that showed potential for carriage duty. The tricky part? Finding new horses that could handle working on an island without cars where summer means heavy traffic that includes whizzing bicycles, crowds of tourists and streets full of other horse-drawn carriages.
With only about 800 horses in the Hackney registry, it's a fairly small circle to work within. Mosley started a series of calls and emails, much like a coach trying to assemble a new roster of players.
In the end, he brought back to the stables three of his most reliable Hackneys: Jester, Squire and Chief. To those regulars he added two Hackney brothers from Illinois who are just here for a season of island life - think of it as a kind of "summer camp" experience. He added a gem of a horse called Royal, and picked up a mother-daughter duo of mares from New Jersey - one of whom Mosley has had on his mind for years, ever since seeing a video of her when she was a little filly.
Looking at this long row of horses now filling the stalls at Grand Hotel Stables, Mosley is excited about what this influx of newcomers will mean. Training started in the spring, and lessons are still being learned, but already their individual equine personalities are shining through.
"This is one of the nicest groups of horses to be around that I've ever met in my entire life," said Mosley, whose horse sense runs deep, both as a stable master and a former farrier. "They are all easy to work with. They are all very cooperative. It's great that I'm allowed to go out and look for horses that fit in with the ones we have."
If you're a guest at Grand Hotel, you'll likely see the Hackneys prancing by, pulling the smaller carriages. Mosley likes to match them not only by their coloration, but by their conformation. That way, their natural high-stepping "knee action" looks like a synchronized dance when they go down the street.
If you're hoping to see them in person, the hotel still has some vacation specials running this month.
You don't have to be a hotel guest to visit the stables and see its horses and vintage carriage and sleigh collection. Tours of Grand Hotel Stables are free and open to the public. There's even an interactive, self-guided tour that gives you detailed descriptions of many items in that collection, which is hosted jointly by the hotel and Mackinac Island Carriage Tours.
But if it's the horses you really want to see, here's a peek at the eight Hackneys currently filling the stables, and even a few of their big-muscled Percheron draft horse cousins who pull the heavier carriages.
Scotty, a Hackney from Illinois who is just visiting Mackinac Island for the summer


text:
Jean-Luc Domenach (born 11 August 1945 in Hauterives) is a French historian, sinologist and political scientist. He is a senior research fellow at Fondation nationale des sciences politiques. His research focuses on chinese and asian politics. From 1985 to 1994, Jean-Luc Domenach was the director of the Centre d'études et de recherches internationales (CERI). From 1995 to 2000, he was scientific director of the Fondation Nationale des Sciences Politiques. From 2002, he was based in Beijing, as head of French-Chinese doctoral workshop of Tsinghua University, which later morphed into the Centre Franco-Chinois. After 2007, he taught at the Paris Institute of Political Studies.

Notable Books
In "The Origins Of The Great Leap Forward", the first major study of the Great Leap, Jean-Luc Domenach focuses on the central China province of Henan, which emerged as a national model of the Great Leap and was one of the most devastated by its failure. In "The Forgotten Gulag: China's Hidden Prison Camps", he presented a comprehensive description of the Chinese Gulag system.

Selected Bibliography
 The Origins Of The Great Leap Forward: The Case Of One Chinese Province, by Westview Press (1995) and Routledge (1996); Translation of "Aux origines du Grand Bond en avant, le cas d'une province chinoise", Paris, Presses de la FNSP, 1982.
 The Forgotten Gulag: China's Hidden Prison Camps, Simon & Schuster Limited, 1994. Translation of "Chine : L'archipel oublié", Paris, Fayard, 1992.
 With Philippe Richer : La Chine 1949-1994, Paris, Le Seuil, 1985.
 With David Camroux : L'Asie retrouvée, Paris, Le Seuil, 1997.
 L'Asie en danger, Paris, Fayard, 1998 ()
 With Aimé Savard : L'Asie et nous, Paris, Desclée de Brouwer, 2001 ()
 China's Uncertain Future , Columbia University Press, 2012. China's Uncertain Future, Columbia University Press, (). Translation of Où va la Chine ?, Paris, Fayard, 2002.
 Comprendre la Chine d'aujourd'hui, Paris, Perrin, 2007
 La Chine m'inquiète, Paris, Perrin, 2008.
 Mao, sa cour et ses complots. Derrière les Murs rouges, Fayard, 2012.
 Les fils de princes. Une génération au pouvoir en Chine, Fayard, 2016

References

1945 births
Living people


server to help people get going with this Pedang mapping.
That's on my TODO list, i currently have no home internet (!!!!!) so finding it difficult to find the time to do this.  But hopefully i'll have one or two done by this time next week.
>Yes there's absolutely no need to ask for permission to do that!
>(If you didn't already do so) create an account on OpenStreetMap.org and run through the beginners guide or maybe this guide: http://en.flossmanuals.net/openstreetmap/  to learn a bit about using the editors, and just go ahead and try it!
>If you want to help in with other aspects (more or less technical aspects) this should be generally done with a good understanding of how basic OpenStreetMap mapping works. The above steps to get started are the most sensible way to get a feel for everything, even if you want to contribute in other ways.
>But maybe you know all this, and did all this already.  In which case there's many ways you can help with more techy skills.
>Anyone any good at making screencasts? I was suggesting last night that we could do with a screencast video tutorial on using the hot tasking server to help people get going with this Pedang mapping.
That's on my TODO list, i currently have no home internet (!!!!!) so finding it difficult to find the time to do this.
>Of course you can.Anyone can work on any job in the tasking manager any time. The only constraint is to have an OSM user account and minimal mapping skills.
moment I don't have job. So I have some free time.


text:
Charter Schooling & Citizenship
I'm an advocate for charter schooling. Regular readers of my blog know that this is not because I'm convinced they're the answer to the "achievement gap" or to driving up math and reading scores, but because chartering offers an opportunity to rethink how we go about teaching, learning, and schooling. In that context, I've long been concerned that our rethinking is almost entirely focused on reading and math scores and graduation rates and the result can yield a reflexive, frail conception of schooling. If we're going to reinvent schools, I'd like us to do so in a manner that respects the broad purpose of the schoolhouse, which means paying due attention to the arts, to a rich curriculum, and, perhaps most important of all, to helping students develop as moral individuals and citizens.
As part of our ongoing effort to explore and promote citizenship education at AEI (see, for instance, here), we had the pleasure of convening an array of terrific charter school leaders and teachers in San Francisco yesterday. The topic: how they approach citizenship education and gauge their performance, and what steps might help to encourage or support such efforts.
A bunch of intriguing issues arose, and charter impresario Robin Lake will be exploring them in a white paper that we'll be issuing this fall. For the moment, five particular points stuck with me:
First, I was pleasantly surprised by the admirable humility of the terrific charter school leaders and educators. I'd feared that this collection of educators would be dismissive of concerns as to whether they were doing all they could to develop moral character, civic knowledge, and engaged citizens. I need not have worried. In a conversation that included representatives from KIPP, YES Prep, Cesar Chavez High School for Public Policy, UNO, High Tech High, Basis, National Heritage Academies, Basis, and Democracy Prep, among others, participants talked bluntly about the need to do far better when it comes to developing character, cultivating citizenship, and monitoring their performance in these areas.
Second, the question arose as to whether parents actually care about whether schools are cultivating good citizens. One educator asked, "Do parents choose [us] because of the civic mission?" He answered his own question, "No." That was the consensus. Another school founder observed that, generally speaking, "Our parents don't give a [hoot] about democracy walking in the door. They come because of our academic performance, and because their kids will be safe." That said, it also seemed true that schools which deliver academically earn the parental trust that positions them to move as aggressively as they wish on issues of citizenship and character; the question is what they do with that.
Third, charters are particularly well-suited to tackle these questions because they don't have to wrestle with all the parental griping and constituency politics that hamper district efforts to establish strong codes of conduct, to encourage political participation, or to promote character development. Charter schools can make their civic vision an explicit part of their appeal, so that supportive families can seek them out, and others can go elsewhere.
Fourth, questions of citizenship are peripheral when it comes to charter authorizing. National Association of Charter School Authorizers president Greg Richmond pointed out that there are real, substantive disagreements over how to understand the civic mission of schooling. And, "when you can't agree what to measure, it's hard to focus on metrics"–so authorizers focus on less controversial measures, like reading and math scores. He also pointed out that public school officials long excused mediocrity by saying, "Maybe our kids can't read or write, but we're preparing them to be good citizens." This abuse, he noted, resulted in "toxic backlash." Today, Richmond couldn't think of any authorizer that meaningfully incorporates citizenship criteria into its decisions. Seth Andrews of Democracy Prep raised the question of how educators might start to transform citizenship from a "soft skill" into a "hard skill."
Fifth, the question arose as to whether schools serving disadvantaged students can or should actively seek to encourage students to feel an affection or attachment to the nation. Green Dot founder Steve Barr made the case that schools can't simply expect to teach at-risk students to be patriotic, because these kids haven't seen much from their nation that would incline them to love it–and that these kids need to build trust in the U.S. system before they can be expected to feel attached to it. He said, "When you're around [intense] poverty and injustice, citizenship has a different meaning. Just shaking hands and getting along is a big deal. If you want more, it requires building trust."
Finally, for what it's worth, a few terrific lines really struck me during the day:
"One complication with encouraging student activism is it can burn them out. We had a kid who went to two anti-war protests and, when the war didn't stop, he lost interest."
"The best way to imagine what I want our grads to be like is, if I'm a criminal defendant, I want kids who graduate who I'd want to be on my jury."
"Right now, [citizenship] just isn't a priority. I've got five jobs, and that's my fifth. I'm a history teacher, then an ELL teacher, than a dance teacher, then a 9th grade chair, and then the service learning coordinator. This means service learning is what I do Sunday night."
"We don't operate as a democracy [in the school], we're preparing students to be citizens in a democracy."
– Fredrick Hess
This post also appears on Rick Hess Straight Up.
What We're Watching: Live Webcast of Carrots, Sticks and the Bully Pulpit
What We're Watching: School Choice: A Multiple Choice for Families
What We're Watching: Building a Learning Culture in America
What We're Watching: Improving Career and Technical Education by Reforming High Schools and Community Colleges


text:
Communities & CollectionsTitlesAuthorsSubjectsDate
Limited access: U-M users only Access by request Access via HathiTrust Access via Fulcrum
titledatedeposit date
Now showing items 62568-62592 of 147381
I am a Family Guy
Reilly, Travis (2015-05)
I Am One and Also Two
Silverman, Saree (2011/04)
(2.5MB)
I Am too Competitive to Do Something Only Half Way Swimming ethos and the development of the University of Michigan Women's Swim and Dive Team between 1958-1973.
Beyer, Courtney (2010-05)
I Am Wharton: Hear Me Write, the Four Voices of American Culture
Wilcox, Wendy (2001-02-22)
I AM: In Conversation with the Redemption Triptych
Germaine, Rachel (2018-04)
I Brought All the Flies to Your Funeral: A Collection of Five Short Stories
Safipour, Noveed (2011-04)
"I can almost taste it:" Why people with strong positive emotions experience higher levels of food craving, salivation and eating intentions
Moore, David J.; Konrath, Sara (Association for Consumer ResearchWiley Periodicals, Inc., 2015-01)
I can do that alone…or not? How idea generators juggle between the pros and cons of teamwork
Deichmann, Dirk; Jensen, Michael (John Wiley & Sons, Ltd, 2018-02)
(560.9KB) (4.2MB)
I Can See Queerly Now: Visualizing Queer Theory by Creating a Personal Gay History
Gutoskey, John (2014-05)
"I Could Make a Difference" Research and Theory on Fostering Adolescents' Political Efficacy and Engagement.
Levy, Brett Miller (2011)
I do not wear safety belts because... Final report
Scott, Robert E. (1983)
I Do Want It All: Weddings, Materialism, and Marital Satisfaction
Burcham, Heather (2012-04)
I Don't Know What You Mean
Weiser, Ariel (2015-05)
(89.5KB)
'I don't sing': Exploring perceptions of selected high school students
Bowman, Sarah L. (2012)
"I Don't Want Someone to Watch Me While I'm Working": Gendered Views of Facial Recognition Technology in Workplace Surveillance
Stark, Luke; Stanhaus, Amanda; Anthony, Denise L. (John Wiley & Sons, Inc., 2020-09)
(1.2MB) (332.6KB)
"'I Durst Not Write So Boldly,' or How to Read Hobbes' Theological-Political Treatise"
Curley, Edwin (Bibliopolis, 1992)
"I got to catch my own baby": a qualitative study of out of hospital birth
Sperlich, Mickey; Gabriel, Cynthia (2022-02-14)
I have no genius for marriage: Bachelorhood in urban America, 1870--1930.
Laipson, Peter (2000)
'I Have Seen My Death': How the World Discovered the X-Ray
Markel, Howard (PBS, 2012-12-20)
"I just glove up and do what has to be done": A mixed‐methods exploration of dementia care challenges and care management strategies
Leggett, Amanda N; Connell, Cathleen M; Gitlin, Laura N; Kales, Helen C (Wiley Periodicals, Inc., 2020-12)
i left the museum with a caravaggio in my pants
Hanson, Riley (2017)
I Letter to the editor in response to the paper: Efficacy of ganciclovir in combination with zidovudine against cytomegalovirus in vitro and in vivo : Freitas, V.R., Fraser-Smith, E.B., Chiu, S., Michelson, S. and Schatzman, R.C. (1993) Antiviral Res. 21, 301-315
Prichard, Mark N.; Shipman, Charles Jr. (Elsevier, 1994-08)
I like it combined: Consumer responses to on -line composite versus partitioned prices.
Kim, Hyeong Min (2001)
I like those glasses on you, but not in the mirror: Fluency, preference, and virtual mirrors
Cho, Hyejeung; Schwarz, Norbert (University of California PressWiley Periodicals, Inc., 2010-10)
I Live Here; You're Not Important to me Anymore
Heisler, Mary Kate (2008-04-21)
About Deep Blue Documents
Works found in Deep Blue Documents are protected by copyright unless otherwise indicated.
© 2023, Regents of the University of Michigan. Built with DSpace


Big news, kiddos. As of yesterday (I know, that's a century in internet time) I am the Hartford Advocate's latest blogger. Here's my first post. I promise not to cross-advertise too much between this personal project and that professional one, but still, it's an exciting notch in my writing life. The idea is mine, and the good people at the Advocate were supportive from the get-go. I believe very much in the project and I'm really excited.
Thanks for your support, and please follow that blog if you're interested in cities, walking, Hartford, or looking at things up close.


text:
Paige v Coyner and Board of Commissioners
The 6th Circuit Court of Appeals released a very interesting opinion towards the end of July. In Paige v Coyner and Board of Commissioners, the plaintiff attended a public hearing and spoke in opposition to a new interstate highway project. Although the plaintiff did not identify herself as an employee, she was in fact employed by a firm involved in development in the area, and her opposition allegedly caused the public official in charge of getting approval for the project to call her employers. During the phone call, the public official mistakenly told the employer that the plaintiff identified herself as their employee during the public hearing and encourage them to discharge plaintiff from their employ. Within a week, they fired her.
Retaliation by public officials for the exercise of First Amendment freedoms is certainly nothing new. The question in this case however was whether the alleged encouragement by the public official to a private employer was sufficient to vest a right to sue under §1983. The Court of Appeals found that it was.
[The public official] could thus be liable not because the firing itself was state action, but because a jury might find that the firing was a reasonably foreseeable consequence of the action taken by [that official]. In other words, once there has been state action (here, the phone call), the proper test for the scope of responsibility for events flowing from that action is reasonable foreseeability, not how close the nexus is between the private actors and the state actors.
The Sixth Circuit went on to analyze the remaining elements of the First Amendment retaliation claim, as well as whether or not there was a sufficient allegation to hold the Board of Commissioners, concluding in each case that there was, and as a result reversing the decision of the District Court dismissing the case.
This decision makes very interesting reading and once again serves to emphasize that public officials should not be involved in taking any action that might be deemed an effort to curtail freedom of speech.
Posted by George Dean at 8:50 AM No comments:
A Sorry State of Affairs: The Writ of Certiorari
We don't really need a reminder, but we got one the other day from the Tennessee Court of Appeals: to file a petition for (common law or statutory) writ of certiorari properly, the facts must be verified, that is, sworn to by someone with knowledge. In Brundage v Cumberland County (Tenn App August 4, 2010), a statutory writ of certiorari was requested but not verified. The petition sought to challenge the development of a landfill. But without verification within 60 days of the action of the administrative body, the trial court lacks subject matter jurisdiction and the case must be dismissed. Which is what happened here; the Court of Appeals affirmed. As the court said:
The case law consistently holds that the failure of the petitioner to verify the petition as required by the Constitution and the statute is proper grounds for dismissal, as the court does not obtain jurisdiction without a properly verified petition.
This is truly unfortunate. It is simply a trap for the unwary. The courts are correct about the law, but why should a case not be decided on the merits? Why should it be tossed out for failure to verify? In fact, in most of these kinds of cases, the facts are almost agreed upon by the parties anyway. The real issue usually is how is the law to be applied to the facts. Verification is largely irrelevant. Tennessee needs a different method of review, one that doesn't have numerous traps for unwary litigants.
Let me review for just a moment the number of little tricks in the writ of certiorari:
The petition must:
– be verified, that is notarized and sworn to as true (TCA § 27-8-106)
– state that it is the first application for extraordinary relief (TCA § 27-8-106)
– state that there is no other plain, speedy or adequate remedy (TCA §27-8-101)
– allege that the petitioner is aggrieved (TCA §27-9-101)
– be filed within 60 days (TCA §27-9-102)
And, by the way, if the neighbors are the petitioners, then the attorney must be extra careful to establish standing.
I have used these technical challenges to obtain dismissals of cert petitions myself. But I never feel very good about it. It's time Tennessee had a better way of reviewing local government land use decisions. Certiorari has out lived its usefulness.
Posted by George Dean at 11:33 PM No comments:
Stoneybrook Golf Course v. City of Columbia
Stoneybrook Golf Course v. City of Columbia is an interesting new (dated July 26, 2010) zoning decision from the Tennessee Court of Appeals. The primary issue is whether an ostensible "agreement" between a developer and a city (or rather certain members of the city council) to annex and zone property in a certain way is an enforceable "contract." Well, of course it isn't. No one who works in this area of the law would ever believe that. That's way real estate development is so risky: city council members change their minds, even if they were ever in the developer's corner in the first place.
Typically, the developer may speak to members of the city council and they may agree that the proposal sounds like a good one. But of course, once the word gets out about the proposal, and public hearings begin, the neighbors may point out problems with the proposal. Should the city be bound by such informal agreements? By a judgment made without the benefit of notice and an opportunity to be heard by the surrounding neighbors? No. And that's what the law says.
In fact, even if the government passes a zoning ordinance and then changes its mind and repeals it, even if the developer has now bought the property and is in the process of developing it, the law says that the government may change the zoning without harm. Only if the developer has obtained a building permit and substantial construction has taken place is there any issue of vested rights which might preclude the zoning change. Frankly, in 30 years of practice, I've never seen a case of substantial construction. It is very difficult to argue vested rights in Tennessee or elsewhere.
This case also has an interesting section about general or comprehensive plans.