text:
Crowning my Feral Prince – CH011
Speaking of which, Leone seemed to be able to say a few short words.
"Leone. What words do you know how to say?"
Leone looked at her quietly, as if he didn't understand her question very well. When did Leone start acting like that? Who taught him some worlds, and who taught him to speak? If only he had already been in that state since she came into the world. Could he have been taught by a teacher? Why was he in that state in the first place?
It was strange that she wondered that at the current moment, but she couldn't help but to do so. She wondered what kind of life he had gone through.
"Well… What is it?"
And how far he understands.
He seemed to recognize his name. What is he used to? She pondered for a moment and then remembered what he had said.
"Damn it… Article? Who were you referring to?"
"Damn it, knight."
It was very clear and accurate.
"Maybe that's Adler… Wouldn't it?"
"Damn knight."
"Mmm. The damn knight is called Adler."
"Adler."
"Yes. I know you hate Adler."
'Ok. Call it whatever you are comfortable with. Where do you know who Adler is?'
"I hate it."
He seemed to only react to negative words. Spies, damn it, die… She thought of the words he had said and pointed her finger at herself.
"Trixie."
"You're Leone."
She pointed to Leone once. Leone seemed to ponder for a moment, then opened his mouth.
He speaks clearly as if he knows his name.
She said, pointing at her once more. Leone nodded.
It was repeated for a long time, and he frowned as he stared at the shape of her mouth carefully. Leone slowly pronounced something similar to her name.
"Exactly. That's my name. Trixie."
"Trish."
"Yes, Leone."
Leone's voice rang low. She had never heard my name so low and gentle before.
Leone, who finally could say her name, smiled faintly with satisfaction.
'Are you laughing? Leone, are you smiling now?'
She had never seen him smile before. It was such a strange and curious scene. Looking at his face, it seemed that her name was the most precious treasure in the world. So she wondered, 'Are you laughing now?' and looked at him without even asking.
She stared blankly at him for a moment, but her cheek tickled and she came to his senses. The late spring breeze contained a lukewarm warmth. There was also the scent of fresh greenery at the end, and he seemed to whisper that summer was coming soon.
As she turned her head in the direction of the wind, she saw the trees trembling and shaking in small pieces. The sound of the leaves was similar to the sound of a river. It was a beautiful sight.
"… Oh, yes, Leone. That's my nam… Ugh!"
She tried to convey the swirling emotion in my heart and say, 'Yes, that's my name,' but she couldn't finish because he pulled her close and put her on his shoulder. She closed her mouth in surprise.
Her cheeks touched his chest and abs without a top. She could feel the hot body, firm abs and wide chest. When he picked her up earlier, she didn't know why he touched her like that. She felt like she was doing something wrong with the gentle man's body that touched her skin.
"Leo… what ar…?"
As if to be quiet, he hugged her tighter. Barely opening his eyes upwards, he was glaring at the swaying bushes.
"Whoops… Monster, beast."
The foothills of Mount Meto were clearly free of dangerous animals. but the bush shook once more. She instinctively hugged Leone's waist. She felt like she should never fall away from him.
Then Leone whispered affectionately and patted her on the head just like she did for him. The touch was very warm.
"Hmm!"
She shouted in surprise. It wasn't that something had popped out of the bushes or that she was scared. Suddenly, her vision increased.
Before she realized it Leone was hugging her again.
His arms wrapped around her back and hugged her tightly, as if he would never let go of her.
'Hmm. In the original, it was said that it was safe here.'
『There are no wild beasts living at the foot of Mount Meto. It was just a peaceful place that was like a paradise on earth for herbivores. 』
'There must have been such a passage! Original novel, give me strength.'
No matter how much he had gritted his teeth, she didn't have the confidence to survive if a wild beast appeared. Then, as if something was about to pop out, the sound of leaves clashing against each other was heard fiercely.
'It comes out, it really comes out…!'
"Kr…!"
He shivered and managed to turn his head. Then the identity of the sound entered her eyes. It was clearly visible even as darkness fell. With pure white fur shining in the moonlight… It was a rabbit!
"It's a rabbit, isn't it?"
"Fuu… Leone is just as timid as I am."
She laughed and slapped Leone on the shoulder. But Leone was still frowning and baring her teeth.
Leone. It's a rabbit, a weak animal. It's alright! It's just cute. You can calm down."
She gently soothed him. He did frown, but he let her sit on a rock as she asked.
"Haha. We're real cowards. It's stupid."
"Cowar…?"
She smiled softly and gave him a smile, and Leone quickly became wary.
"Nope. Don't learn that."
She stretched out his palms in front of him like a stop sign and shook her head resolutely.
"I think it's a young rabbit, it's very small."
She heard that rabbits living in the wild were quite large, but they were still young and very small. She felt like she could have it in the palm of her hand. Perhaps because it grew up in an overly peaceful environment, the rabbit was not surprised or ran away when he saw us. Instead, he jumped with his chubby legs and quickly approached the water's edge. It wasn't that far away. Even when the time he chose to appear was kinda scary, he still had crispy white fur, two pricked ears, a lovely mouth that looks like the number 3 turned upside down, chubby cheeks…!
"Ugh… It's cute."
"Look at those paws, it's crazy! Isn't that crazily cute? Oh, so cute. How can it looks so cute? It's really cute…"
With his tiny mouth, he gnawed at the grass, then raised his head once in a while to look around. Meanwhile, the rabbit's ears shook a little, as if looking for something.
She clasped her hands together, possessed by the look. Her fingers clenched and her stomach tightened. She wanted to scream right away. So cute. The rabbit's cheeks and lips twitched, and his beard shook slightly. She just wanted to give it a kiss. Really.
"Oh. It's cute."
She felt like she could sit here and watch it all day, but they'd better just go.
"Leone. It's better to go. Let's go back now."
"Oh, um… Let's go to sleep. Like this."
Not understanding the words, she gestured and made hand gestures, picking out as many words he must have heard as often as possible. She was a little embarrassed when she pretended to sleep with her hands together on her cheeks. Leone shook his head at her. His swaying gold hair glowed as if stardust was falling from it.
"You don't like sleeping?"
He nodded. For the first time, she felt understood. But she wasn't sure if what he hated was sleeping or going back. Leone lowered himself and moved on all fours.
In the woods, a topless man was walking on all fours, which somehow seemed more obvious than funny or bizarre. It looked comfortable. There he was different from being trapped inside a mansion. Even though he was human, the manor's artificial structures didn't blend in with his body at all.
"Leone? I think the rabbit will be surprised if you go that way."
His answer was much sharper than the voice in the conversation we had just shared. No way.
Could it be Leone, are you trying to hunt now?
"Oh, no!"
As if about to rush quickly, his arm muscles swelled.
She jumped towards him.
As Leone lifted his feet off the ground, she hugged him by the waist tightly. One of her shoulders was injured, and as soon as she reached out her hand, she felt a lot of pain. At the end the two of them fall to the floor at the same time.
They were in the woods and the ground was wet. After falling she closed her eyes tightly, ready for a wound. Her shoulder already hurts, but it won't change if it hurts a little more. Or so she thought.
It was at that moment…
Something solid hugged her tightly. Warmth came through her body. That was the end of it. It was quite loud, but it didn't hurt at all. She slipped open her closed eyes and saw a rabbit grazing peacefully. Fortunately, it seemed to dry him off in time.
"Huh, huh. Don't be surprised…! Leone! What if you hunt it?"
She couldn't breathe, but when she saw Leone lying on the floor with her in his arms, she woke up startled. Wrapped me up, now?
"Leone!"
"Are you okay? Aren't you hurt? Oh my god."
It's a big deal. She was dressed, but Leone had a naked upper body. The floor was not a fluffy carpet. What if he was swept away by grass or stones? He looked at her. His round transparent eyes checked her face and soon relaxed.
"Nope. Aren't you hurt? Where does it hurt?"
She lifted Leone's arm, flipping his body over to check his back. Her shoulder hurt and it was difficult to use her arm, but Leone didn't hold on or rebel, so she could see it quickly. Fortunately, the grass was soft so he didn't have much more wounds. She was upset though. Originally, there were a lot of wounds, but she thought falling added more to it. She was going to fall, but he hugged her and protected her…
Is it that Leone who broke her shoulder? After looking for a while longer, she grabbed his torso to check his side one last time, but Leone made a strange noise.
He sounded surprised, and he looked embarrassed. She noticed at once when she saw Leone getting up from the floor and sneaking away from her.
"You… Ticklish?"
When she saw Leone's eyes wide, she unknowingly remembered a vicious smile.
Translator Note:
Hello there! This is RJR, thank you very much for reading!
Next post will be released on January 13.
I hope you liked this chapter, please tell me if you find any mistake 😉


text:
Cash incentive instead of tax discount for hydroprojects
KATHMANDU, June 18
The government is preparing to give cash incentive at a time when the private sector has been demanding tax discount in development of infrastructure projects including hydropower projects.
The government has moved this concept of cash incentive forward through the upcoming budget stating that the established system is disrupted while providing discount directly in revenue and tax. The government says the facility will be implemented through the upcoming budget especially targeting the private investors who are working for development of hydropower sector. "The private sector has demanded for discount on value-added tax (VAT) for up to Rs 10 million but monitoring that will be difficult. The private sector later may also demand VAT and tax discount for other sectors as well," Vice Chairman of the National Planning Commission (NPC) Professor Govinda Raj Pokharel said. "Providing cash incentive after completion of the project will be more effective in all respects instead of harming the taxation system," he reasoned. He said that the government bodies are holding discussions about that and the issue will be included in the budget after formal decision. He revealed that the government is mulling about providing cash incentive of Rs 10-15 million to the promoters completing hydropower projects within five years to address the energy crisis.
The private sector has also said it will accept the cash incentive likely to be given. "We have also been discussing especially about tax discount in different stages with the government bodies. We have no issues about paying tax as it is an internationally accepted thing. But the tax rate to be imposed on the private sector has to be scientific and the cash incentive should instill enthusiasm in the developers," President of the Independent Power Producers' Association, Nepal (IPPAN) Khadga Bahadur Bista said. The private developers currently are paying tax to the state especially for contracts, construction materials, consultancy services and others.
The recommendations made by the Energy Ministry and the Investment Board (IB) to the Finance Ministry for discount on income tax, VAT and customs duty look set to be ignored with NPC preparing to provide cash incentive by continuing the process of levying tax as it is. All the under-construction projects will get cash incentive of Rs 10-15 million per MW as a lump sum after completion of the project instead of tax discount, according to Pokharel.
The Energy Ministry and IB had proposed full income tax waiver for 10 years and half for five years for the projects to be completed by 2023. But the projects to be finished after 2023 would not have been eligible for that, as per the proposals. This time limit will be applied even for the cash incentive, according to NPC sources that revealed that appropriate provisions will also be made about bonus and other issues after holding discussions.
The government has provided full income tax waiver for 10 years and half for five years for projects to be completed by 2015. Similarly, full tax waiver for seven years and half for another three years have been provided for the projects to be completed by 2019. The law is silent about the tax discount for projects to be completed after 2019.
Similarly, discount on customs duty has been recommended for import of cement, iron rods and other materials needed for construction of projects. But it has been recommended only if the materials are not produced in the country or are not produced in sufficient quantity. The Finance Ministry has also been providing discount on customs for electromechanical equipment as they are not produced in Nepal.
Source : Karobar Daily
Previous article'Investment in hydropower projects welcome'
Next articlePPA with BPC stalled due to Khimti
Excess wire removal expedited
Land acquisition of Budhi Gandaki project stalls due to short-staffing
Chhyangdi Hydropower to issue 2.70 lakh units IPO shares to the...
जलविद्युत्मा वैदेशिक लगानी
Buying fixed amount of hydro power may become mandatory
Herbert Smith Freehills advises on Nepal's biggest ever foreign investment deal
'Investment in hydropower projects welcome'
प्राधिकरणलाई माग व्यवस्थापनको सकस

redpajama_set_name: RedPajamaCommonCrawl


Are chia seeds good for kidney health? It is a common question among kidney disease patients. Since the strict restrictions on daily diet, they can not eat anything freely so as to control the progression of the illness condition. What's the answer? Follow this article, you can have a good understanding.
Nowadays, more and more people would like to add Chia seeds to their diets because of their abundant nutrients. For instance, they contain 52 nutrient elements, protein, calcium, iron, omega-3 and various antioxidants. For healthy people, the ingredients of chia seeds can help them prevent bone disease, reduce over weight, boost up the memory, improve anemia, fight against infections, prevent cardiovascular disease and do on. However, are these nutrients good or harmful for kidney health? Please keep reading.
Can kidney disease patients eat chia seeds?
Chia seeds are packed with abundant protein, and the protein content is much higher than milk. Unfortunately, it is a common sense that people with kidney disease should limit the intake of protein. For kidney disease patients, they should keep away from chia seeds so as to protect remaining renal function. as we all know, plant protein produces more waste than the meat, which increases burden on the kidneys to filter them out of the body. Besides, the phosphorus content and potassium content of chia seeds are also very high. Too much intake of phosphorus can cause itch skin and too much intake of potassium can cause irregular heart beat and weakness.
What should kidney disease patients eat?
High-quality protein foods are suggested to kidney disease, such as egg white, meat, milk.
They should take more fruits and vegetables to absorb the vitamins.
Keep away from high-sodium, phosphorus and potassium foods.
These are the part of friendly-kidney diet, if you wanna more, please keep in touch with your dietitian. In addition, if you or your loved one happen to be a kidney disease patient, you should pay enough attention to your daily diet to protect your renal function. If you have question about kidney disease, please feel free to contact our Online Doctor or leave a message below and we are glad to help you. Best wishes to you!


text:
Pericoma drepanopenis és una espècie d'insecte dípter pertanyent a la família dels psicòdids que es troba a Àfrica: Sud-àfrica.

Referències

Bibliografia
 Rüdiger Wagner, 2008. Moth‐flies of a central African mountain stream (Diptera, Psychodidae). Aquatic Insects. Vol. 1, núm. 1.

Enllaços externs
 Arctos
 The Animal Diversity Web

drepanopenis

redpajama_set_name: RedPajamaWikipedia


text:
namespace Nancy.Bootstrappers.Mef.Composition
{

    /// <summary>
    /// Keys to the various metadata inserted in exports and parts.
    /// </summary>
    public static class NancyMetadataKeys
    {

        public const string RegistrationBuilder = "Nancy.RegistrationBuilder";

    }

}

redpajama_set_name: RedPajamaGithub


For reasons of fair play according to IOF competition rules, a number of areas have been embargoed for potential WOC 2020 team members (athletes, coaches, team leaders and other persons who may influence the results of the competition).
The embargoed areas can be viewed at IOF Eventor and/or Google Maps.
You can view and download previous orienteering maps from within the embargoed areas here.
The cities Vejle, Fredericia and Kolding offer a wide range of accommodation, from five-star hotels to cabins. There's also a WOC2020 campsite in Jelling, just 20 minutes by car from the event centre.
The official WOC2020 hotel is Vejle Centre Hotel, right next to the event centre. Vejle Centre Hotel is a 10-minute walk from the railway station and just a five-minute walk from the city centre.
Teams are free to choose their own accommodation, but some areas are embargoed. It's your responsibility to check this and choose accommodation outside the embargoed areas.
The Triangle Region has many attractions and it gets very busy in summer. We therefore recommend you to book your accommodation in good time to take advantage of the great deals we've arranged with local hotels.
The Scandic hotels in Denmark offer discounts on accommodation for the participants and spectators to WOC2020.


TOCCA Life Holdings, Inc., the First Publicly Traded Sober Living Company in History, Clears Approximately $6 Million in Liabilities by Finalizing the Share Exchange Agreement Including Spinning-off Its Wholly Owned Subsidiary, Xirxi Co. Ltd.
The spin-off allows the company to focus on its core businesses in the addiction recovery and clinical toxicology space and is the final deliverable under the share exchange agreement among TOCCA Life Holdings, Inc. (fka T-Bay Holdings, Inc.), TOCCA Life Coaching, Inc. and the shareholders of TOCCA Life Coaching, Inc. Under the terms of the spin-off the company acquiring Xirxi Co. Ltd. ("Xirxi") will assume $5,700,000 in liabilities associated with that business in exchange for the business of Xirxi, including its assets carried on the books that are valued at $1,233,575. This clears almost $6 million in liabilities from the Company's financial statements. CEO, Tyler Cornell, stated, "I've always tried to practice patience and perseverance with daily positive progress independent of the risks associated with any one deal that I'm working. This time, my goals were complemented by more than building a business or being controlled by a business model instituted by my employer, but instead, by the TOCCA clients to whom we are responsible. Our clients' daily battle with the disease of addiction is so much harder than the delays inevitable in business. Clearing approximately $6 million of liabilities, thanks to those currently involved, is not only emblematic to the cause but clears the path for an extremely promising business model designed to help the more than 25% of American families directly affected by the disease of addiction."


After crossing the Prek Chak International Border in Cambodia on Monday, from the Ha Tien border in Vietnam, I drove about 32km to Kep and checked into the Tree Top Bungalows. Originally, I only planned to stay here for about three days, however it is going on my sixth full day and I'm not sad about it at all. I'm enjoying the experience of feeling like I'm sleeping in nature, even though I would do away with the bugs if I had it my way. Since I decided to take it easy for a few days, I thought it would be a great idea for me to catch up on editing some video footage, write a blog post or two, send a few emails and file my taxes. 🙂 On another note, I think Swing needs some R&R as well. He racked up about 5,352km (3,325 miles) on the roads of Vietnam and I think I'm starting to feel he's a little exhausted.
So far my experience in Cambodia has been peaceful. I've tried to practice learning some words in Khmer, the local language, but I have some ways to go before mastering even the simplest words like hello. The currency here seems a bit weird to me, for example 1000 riel is equivalent to $.25 USD and 10,000 Riel is equivalent to $2.50. I'm glad I don't have to fuss to much over the currency, because the country has everything listed in USD and the ATMs dispense both Riel and USD.
Thought my plans this week have extremely relaxed, I did manage to visit the Crab Market, which offers some of the freshest seafood I've ever had. The crab cakes I ate for lunch today at Kep Sur Mur restaurant were delicious. I also took a trip to Kep Market, which is a local market that sells fruit, meat and other daily necessities. I will admit, this market was no match for the markets I've experienced in Vietnam however, I did manage to find two light weight dresses to get me through the heat on the days I'm walking around town.
Back at Tree Top, earlier this week, I met a new friend named Ben. Ben is from France and he's traveling around the world, literally, for about three years and his only means of transportation will be by sea and land. He invited me to come along with him to Koh Tonsay "Rabbit" Island, located in the Gulf of Thailand and just 4km away from Kep. We departed on Friday morning at 8:30am and arrived to the Island around 9:45am This was not one of those fancy Islands where you go and find several activities for your entertaining pleasure, in fact this place was the complete opposite. The Island is one square mile in size which we managed to walk 3/4 of that distance around the Island, the other 1/4 was unpaved so we opted not to trek through the jungle-like terrain. The Island runs on a generator and all power is completely shut off between the hours of 10pm-11pm, without any warning. There is no WiFi on the Island so if you don't have 3G you can plan to spend your time swimming, snorkeling in the clear water, go fishing, get a massage, read a book or simply relax and watch the sunset in one of the many hammocks hanging throughout the Island. We stayed one night at Ngan Sokha, as recommended by an acquaintance of Ben, and enjoyed breakfast in the restaurant when we arrived. However, we chose to have lunch, dinner and breakfast number two over at Yum Yum restaurant, where the staff was full of energy, fun and much more inviting.
Overall, I would totally visit the Island again. In fact, if you are in Kep and in need of some time alone or just some time to relax and recoup, I highly recommend taking a trip to Rabbit Island. The cost is $10 and that includes a pick up from your hotel and a return ferry ride from the Island. Your accommodations on the Island can range from $5 and up, which you can select once you arrive.
I put together a little clip to capture a few highlights from our Island experience. I hope you enjoy.


Still searching for a good Mac-Mini-like Linux box.
I disagree.. KDE 3.X was absolutely great and KDE 4.8+ is great as well. Everything in the middle... Well.... Let's just say I stuck with KDE 3.X, plugged my ears, covered my eyes and held my nose until KDE 4.8+ came out... PHEW! At least the worst part is over! Hopefully no more major "upgrades" for a while.
This. A thousand times this. But never fear, there are forum fanboys who will insist you don't know what you're talking about.
I missed out on the invite. How has the BETA been going anyway?
I am on Debian Wheezy/sid 64bit.
Then, I was able to start and play TF2. The only issue I encourted was about missing letters(replaced by blank spaces) in some text like "W lcome in ..." but TF2 ran quiet well.
For information, check if you client version is up to date(directly in the Steam client), I did it and it worked.
Last edited by Debcool; 12-08-2012, 05:34 AM.
Et si je poussais une longue plainte déchirante pudiquement masquée sous la morsure cinglante de mon humour ravageur?
Any of you guys testing the games with open drivers (non intel that is)?? Are they good enough??
Goddamit, ever since I upgraded to Fedora 17 my binary AMD driver got broken..
Works great here with Intel HD 4000 graphics and Trisquel GNU/Linux.
Well, FPS could be higher, but it is playable if you set graphics options a little bit down from "full max everything".
Running fine here on Radeon HD 6970 with FOSS drivers. A few graphical glitches here and there, but I'll bet they are gone if I update drivers (kernel + newest mesa from git).


Our last text exchange had left the details of our get-together up in the air – we would check-in in the morning and decide when and where to meet up.
Around 9 am, I texted her with a "Well, I seem to be up. Good Morning!" and she responded back "Hi!". So, I called her.
After our good mornings, and a 'from what I see on FB, it looks like you had a fun night last night' conversation, she told me that she was going for a trail run. She was taking advantage of the beautiful weather before the rest of her day. She felt scared to tell me, but since we hadn't confirmed our plans together, she had made other ones.
And then, after we hung-up, I burst into tears.
I scrolled back up our texts and saw that, in fact, her last message had said "…let's play getting together by ear then…" not what I had understood it to say, which was "We're getting together but let's play the details by ear." A subtle, but big difference.
A flurry of thoughts swirled in my head.
I wasn't really that sad about not seeing her. I was more sad and angry about about the missed connection, the potential that had been squandered by such a silly little thing as misinterpreting her text. And the fact that I hadn't followed my repeated impulses to check-in with her the day before.
And, well ok, maybe I really did want to see her.
But, I had the distinct impression that my tears were in response to something deeper than all this – The fact that I had not clearly requested what I wanted.
This relatively inconsequential-in-the-big-scheme-of-things-exchange reminded me of the many other places and times in my life that I am not clear and direct about what I want.
I texted her saying that I had misinterpreted our previous exchange, and that if I had understood correctly, I totally would have been wiling to nail down a time and a place to meet her.
She responded that she appreciated me checking-back in with her and letting her know. And, that part of the reason she made other plans was that I had cancelled on her the last time we were supposed to get together.
I knew exactly which event she was referring to – and my exact thought was "Whaaaaat??!" Because I remember thinking at the time that we weren't getting together because she didn't want to! But sure enough, as I re-read that text exchange I saw that while I had not explicitly mis-read her words that time, I had not made a clear request either. And there was definitely room for both our interpretations of the situation.
Now I want to admit that at this point, I was tempted to explain what had really happened, defend my reputation, and point out that I had, in fact, felt slighted way back when. But luckily, I've been down that road enough times know to that it doesn't really go anywhere.
So I took a breath, and chose to return my attention to myself.
First, I decided that this was a friendly reminder that texting is not the optimal form of communication for more than the most simplistic of logistical conversations.
And second, I got that yes, there are things that don't go my way in life, for who knows what reasons, but when I don't communicate my requests clearly, I'm seriously hindering my odds (whatever they are) of getting what I actually want.
By the end of our conversation a few minutes later, I was appreciating her and the connection we had created, even though we didn't end up seeing each other.
On my drive home, other places in my life where I had not been making clear requests came to my attention.
Some were gaping holes, like secret desires that I was hoarding in the recesses of my brain hoping that someday, someone would figure them out.
And still others, were places where I was clear on what I wanted but just had not been direct in my communication.
Most were easily resolved by a few clarifying phone calls.
All this, and the fact that I made it home in time to meet up with some other dear friends who asked me over to their place just as I was entering LA county, made me decide that all those morning tears had actually been the perfect start to my day.
So my suggestion for you, is the next time you are not getting what you want or things don't seem to be going quite your way. Take a minute to check-in and ask yourself if there is a clear and direct request (or statement) that you have not made. And, then make it.
And, then wait and see if any others pop up, and make those.
You'll know you are on the right track if you feel more energized and alive as you go.


Effective internal capacitance max. 110 nF ; a cable length of 10 m is considered.
Effective internal inductance max. 200 µH ; a cable length of 10 m is considered.
Standards EN 60079-0:2012, EN 60079-11:2012 Ignition protection category "ic"
Effective internal inductance Li max. 200 µH ; A cable length of 10 m is considered.


If you've been reading this blog for a while, you know I love eating with the seasons. Something about it just slows me down long enough to appreciate the hands who grew and prepared my food. Seeking to live a simple life, cultivating gratitude for the mundane and simple joys of the everyday sets my heart on fire. You may not think this has anything to do with muffins, and maybe it doesn't, but it has everything to do with how we've been sourcing as much of our food as we can from local farms if possible. Recently we've been using a home delivery CSA (yes, they deliver veggies from their farm and meat TO.MY.DOOR) called Harvest to House. If you're local to North Texas, you need to try them!
And if you're new to eating seasonal (or just need some fresh inspiration!) and want to know what's in season for the summer and get some summer dinner ideas, check out this post.
As far as using up some of those delicious summer berries, we decided to add them to muffins as a snack. We love us some muffins around here, especially sweet baby Reaghan......who we still call that despite the fact that she's practically 16...I mean 3. My girl loves berries, so I decided to mix a couple of her favorite foods!
Make sure to check out the notes section below the recipe for a flour switch if you're not gluten free, and using cardamon spice!
*Notes: If you are not gluten free, you can substitute whole wheat flour. I get my buckwheat flour from Thrive Market, which you can learn more about here! Buckwheat flour is what I often have on hand, so even if you're not gluten free, this is a great flour to stock your pantry with since it packs a lot more nutrition per serving than regular wholewheat flour including protein, iron and zinc, copper and antioxidants. Also, cardamon is listed as optional above, because it's not a pantry staple, BUT I think everyone needs to try this spice. It smells almost minty when you open the jar, but gives a subtle spicey sweetness that I love in baked goods. It's hard to explain, but I hope you'll try it!
Blend all the wet ingredients (strawberries, applesauce, honey, eggs and vanilla) in a blender.
Pour the wet ingredients into the dry and mix together with a wooden spoon.
Spray muffin tin with cooking spray and fill with batter.
Cut up a few extra strawberries (about 5-6) into small pieces and push a few into the tops of the batter.
This is a great recipe to double and freeze for later, send in a care package to the next mama in your life who has a baby, or for a play date! What's your favorite summer produce?


I had made a note in my booking form that I would arrive at 04.00. On identifying myself, the door was opened without any waiting and the check-in transaction completed quickly and professionally. The attitude of the staff is of the very best. - Hotel is placed in very comfortable part of the city, very close to both railway station and bus stat... τι λέει ο κόσμος » ion. About 5 minutes to the city center and 10 minutes to walk to largest mall. Free Wi-Fi is a plus too.
I had very good time here, and I started to regularly stay there. Quite, green neighborhood, super-friendly staff, I felt almost like home. Nice breakfast and big room - It s quite fine.
Good for shopping, not actually so far from the Old city. Good internet wifi connection everywhere in hotel. Clean and comfortable rooms with good furniture and interior. Quiet, has internal climate control system. Free parking on the underground floor, good choice for winter :) - Every aspect of this hotel was amazing, and staff and quality of s... τι λέει ο κόσμος » ervice was outstanding. Also, the hotel is next to an amazing shopping district and an amazing new shopping mall. This hotel is highly recommended.
Staff were incredibly hospitable. Facilities were great and ideal for a short stay. It is right off the main square in Rzeszow with easy access to the very nice surrounding pubs and restaurants. I would definitely recommend and shall be staying there again on return. - The rooms were extremely comfortable and well furnished. The breakfast buffet ... τι λέει ο κόσμος » was very good. The location was suburb. The staff were friendly and helpful.
Great place with really unusual design. This hotel is located just next to the Old Market, which gives you an opportunity to explore the city centre even in the late, evening hours. Rooms are really nice and clean with small, but tastefull bathroom. Bathroom is equipped with clean towels, hair dryer and some shower gel/shampoo and soap. You can ev... τι λέει ο κόσμος » en find a shoe polish in your wardrobe :-) The bed was so comfortable, I slept like a baby. The breakfast buffet was satisfying - plenty food to choos - This is a hidden gem in Rzeszow and deserves attention. The rooms are beautiful and the staff look after you very well. You feel pampered. Breakfast had something for everyone and the coffee was delicious.
Across the street from the railway station this basic hotel was clean and tidy. No lift to my 3rd floor room. Good for one or two nights - Affordable, close to the station, and everything in the room you could ask for given the modest price tag.
Very friendly staff, speaking well English. Our dog was allowed, thanks for that. Good location, quiet but easy to get back to big street. Warm and friendly rooms. Good price. - Very pleasant staying, excelent breakfast, good location, we felt very well.
The hotel was clean, with friendly stuff who spoke English. The room was rather modest, but it's ok for this price. It's located somewhere far from the city center, but since we were with our car, it wasn't a problem for us. - Very good breakfast.
The owner is trustful man. Hotel is good for it's price.
Friendly English speaking staff, nice room, perfect location for travelers with a car, who passes Rzeszów. - Everything!


Hey! We're one week out from The Consuming Fire officially being released and me starting my book tour! Let's talk about these things!
In the event that no one guessed Kingman, I had a backup in mind, also in Arizona: Winslow, made famous in the Eagles' "Take It Easy." More than 40 of you picked that one. But Shatle had you all beat. Sorry.
2. The Consuming Fire is out next Tuesday, and people often ask what's the best way to buy it: In hardcover, in eBook or as an audiobook. My answer is always the same: Get it in the version you prefer, because I get paid more or less the same for each, and also fundamentally I want you to be happy with your purchase. My publishers would be happy to have me get on the NYT bestseller list (and I wouldn't mind, either), but the thing is at this point each format has its own NYT bestseller list (and there's also a combined print/ebook list), so, honestly, again, pick the format you like, it all goes into the sales pile.
3. If you have no real preference in format, get it in hardcover, and also pre-order, or buy it in the first couple of days. That will make everyone happy. If you are waiting to pick up the book when I'm on tour, go ahead and pre-order the book now from the bookstore you'll see me at — that way your sale still counts for the first week tally, and the bookstore will hold the book for you until I show up (I mean, or you can come pick it up from the bookstore any time before then, you don't have to wait).
4. On this subject of purchasing books, If you are coming to see me on tour, please really do get the book from the bookstore you'll see me at. It's how you support that local bookstore and encourage them to bring in authors to do events. If you just can't wait, and pick up the book prior to my event from somewhere else, when you're at the event, please buy another book from the bookseller to show your support. It doesn't even have to be one of mine! But bookstores need sales, and I need my events to do well for the bookstores. If neither happen, I stop being able to tour. So buy! Buy! Buy!
5. Speaking of the tour, here are all the tour dates this time around. All the events except Chicago's are free, but some are ticketed (and some give priority to people who purchase the book at the store, another reason to get the book there), so click through to the venue Web site and get the details. If the information isn't on the front page, check under "events".
At the events I will: Read from upcoming work that no one else except the people who come to see me get to hear, sign books, answer questions, and otherwise attempt to be charming and amusing. As always, if someone brings an already tuned ukulele, I will play a song, poorly (strangely, this seems to be a popular part of the event; you people are weird). The exception to this will be in Texas, where I will be in conversation with the super-awesome Victoria Schwab, but that's going to be very cool, I promise.
To pre-emptively answer some popular questions: Yes, I will usually sign more than the latest book but check with the venue for their signing policy; Yes, I will pose for pictures but please already have your camera ready to go (and again, this may be overridden by the venue); Yes, you can bring me gifts if you like (thank you!) but be aware that I am unlikely to travel with them (I will probably have the venue ship them home for me); No, I will probably not be able to hang out with you before or after the event because I am almost certainly already booked. Sorry. You're awesome! Tours are just busy.
6. Please please please do come to see me on tour, and bring along every single person you know. It'll be fun, I promise. I make an excellent performing monkey.
I think that's it for now. If you have any questions, put them in the comments!


text:
women in and beyond the global
analyzing and changing the status of women in households, prisons and cities
South Africa confirms the rights of all children to education!
December 18, 2019 by Dan Moshenberg Leave a Comment
It's the end of the year and decade, and we need some good news, right? As the United States continues to throw migrant children into the abyss of immigrant detention and India throws millions under the bus of lost citizenship, last week a court in the Eastern Cape province of South Africa came through. In a case concerning the rights of 37 undocumented children to attend school, the Judge President of the Eastern Cape Selby Mbenenge, writing for the Makhanda High Court, emphatically declared that the Constitution of South Africa enshrines the right of all children to access to education. Judge Mbenenge opened his decision: "Central to this application is the right to basic education enshrined, without any qualification, in section 29 of the Constitution … Education is a mighty tool in the hands of the possessor. Its efficacy depends largely on the bulwark that surrounds it – the right to education … In our constitutional dispensation basic education is a pivot of transformation." Children matter, democracy matters, education matters, rights matter, the Constitution matters, courts matter, judges matter, decency matters, compassion matters, transformation matters … without any qualification. Amen.
Who are the undocumented children of South Africa? According to the Department of Basic Education, of the 998,433 undocumented children currently enrolled in public schools, 880,968 are South African citizens. A little over 88% of those children are South African. Of the 37 children represented in the Eastern Cape case, 23, or a bit more than 60%, are South African citizens. South African children born at home often don't have birth certificates. There are other barriers. Eight of the children live in a safe house for abandoned and orphaned children. Their situation didn't matter. Without proper papers, they were expelled. Who are the undocumented children of South Africa? Poor. Black. Vulnerable. But first, they are children.
The Makhanda High Court has said that children's situation does not matter, because they are children and thus are due an education, and that obligation is without qualification. Section 29 of the Constitution of South Africa reads:
"Section 29 Education
(1) Everyone has the right –
(a) to a basic education, including adult basic education; and
(b) to further education, which the state, through reasonable measures, must make progressively available and accessible.
(2) Everyone has the right to receive education in the official language or languages of their choice in public educational institutions where that education is reasonably practicable. In order to ensure the effective access to, and implementation of, this right, the state must consider all reasonable educational alternatives, including single medium institutions, taking into account –
(a) equity;
(b) practicability; and
(c) the need to redress the results of past racially discriminatory laws and practices.
(3) Everyone has the right to establish and maintain, at their own expense, independent educational institutions that –
(a) do not discriminate on the basis of race;
(b) are registered with the state; and
(c) maintain standards that are not inferior to standards at comparable public educational institutions."
Everyone means everyone. Tell that to the governments of the United States and India, and all those fortress nations in between and beyond. This is a victory for vulnerable children as it is a victory for inalienable rights without qualification. Transformation is still possible.
(Photo credit: Daily Maverick)
Filed Under: General Tagged With: children, Dan Moshenberg, Haunts, right to education, South Africa
About Dan Moshenberg
Dan Moshenberg is an organizer educator who has worked with various social movements in the United States and South Africa. Find him on Twitter at @danwibg.
England's school seclusion rooms still form a landscape of atrocity and shame
Why is women's leadership so scary for men?
What happened to Veronica Nelson? Nothing. An Aboriginal woman died in custody
Attack on Democracy: CAA and NCR expose the hypocrisy of Modi and the BJP Government
Haiti: It is ten years since the earthquake. Who cares?
wibg: who we are
WIBG is a feminist open access forum. We investigate the exploitation of women within and beyond the global household, the prison, the city, and information networks.
England's school seclusion rooms still form a landscape of atrocity and shame https://t.co/EPsdc6o4Qv Yesterday at 9:47 pm
Woman is the first environment https://t.co/JEc0DLWwmN #Canada #women #Indigenouswomen Yesterday at 9:18 pm
What is left: after solitary confinement in schools https://t.co/oVy4dLXyi8 #solitary #seclusionrooms Yesterday at 2:54 pm
India strips millions of women in Assam of their citizenship. Call it femicide https://t.co/nHxWVajgew #India #Assam #women @GW_WGSS Yesterday at 2:54 pm
True Federalism Is the Counter-Narrative India Needs Right Now https://t.co/4XCjCam427 via @thewire_in #India #CAA #NCR #women Yesterday at 2:52 pm
WiBG on Twitter
abortion asylum asylum seekers austerity Australia Brigitte Marti Canada Cape Town children Dan Moshenberg David Kapp domestic workers Egypt France Greece Haunts immigrant detention India Kenya Mexico Nichole Smith Nigeria Pennsylvania police Pramila Venkateswaran prison rape refugees Resistances sexual violence solitary confinement South Africa Texas The very unfortunate torture Uganda United Kingdom United States violence women women asylum seekers women prisoners women workers Yarl's Wood Zimbabwe


Aankh Marey gets you grooving!
So the makers of Simmba have released the first song from the movie; Aankh Marey and the song but obviously is high on energy. It's Ranveer Singh we're talking about here so the energy obviously just comes naturally.
The song is a recreated version of Arshad Warsi's hit song from his debut film Tere Mere Sapne. The song Aankh Marey Oh Ladki Aankh Marey from the 1996 film was a big hit and it's been recreated in a fun, colorful way and the icing on the cake is that Arshad features in this special track too and the crazy Golmaal Gang Shreyas Talpade, Tusshar Kapoor, and Kunal Khemu join in the singing and dancing too.
It's a nice tribute to the original song. The song makes you nostalgic about the '90s. Both Sara Ali Khan and Ranveer have done justice to the song and they seem to be going all out and enjoying the song and dance.
The new version has been sung by Neha Kakkar and Mika Singh and the two add a fun and playful touch to the song. The original song from Tere Mere Sapne was sung by Kumar Sanu and Kavita Krishnamurthy.
The video starts with none other than Karan Johar dancing to the song and then Ranveer and Sara take over from him. They are joined by the Golmaal gang and Arshad makes his entry lip syncing to Kumar Sanu's voice.
The song is entertaining and now we just can't wait to watch this out and out entertaining film.


text:
Some Beyoncé Neptunes News
According to angryape.com, Beyoncé has collaborated with Justin Timberlake, Kanye West and Pharrell on her third solo album – which has a working title of 'Queen B!'. Although the LP is expected as early as November 18, two singles are due to precede the album. One is named 'Single Ladies', and the second is 'If I Were A Boy' – although some reports claims this may be called 'I'm Just A Boy'. Both West and Pharrell appear on the latter single and according to sources, most of 'Queen B!' was produced by Timbaland.
*angryape.com


The East and West Matukituki Valleys offer enjoyable day walks across farmland and beech forest flats, as well as access to a number of demanding tramping.
Cascade saddle in New Zealand's Mount Aspiring National Park is an amazing location, it's one of those places you can just sit and admire the scenery for hours. There are a two marked tracks leading to the saddle one from the Dart river valley and another from the Matukituki valley.
Cascade Track - Aspiring Hut - Cascade Saddle.
Aspiring hut is located in the Matukituki river valley, 2 and half hours up the valley from Raspberry Creek carpark. From Aspiring hut it takes about 4 hours of steep ascent to reach the high point of the track at the pylon, this is actually higher than the saddle itself at 1835m. Once at the pylon you will have climbed over 1000m so fortunately the hardest part is over but there is still another 2 hours to go before reaching the saddle. This route can be very slippery so great care must be taken.
Cascade saddle is at an altitude of 1524 metres. It offers brilliant views. The Dart glacier is nearby rumbling frequently as it gradually shifts. The Matukituki river winds it's way through the valley some 1000 below, you can see water falls cascading off the near vertical drop to the valley floor. In the distance you get a superb view of Mt Aspiring on a good day. At 1500 metres you have to watch the weather ... thick cloud, snow and strong winds are possible at any time of year.
The Cascade Saddle will take your breath away ... that's if you have any breath left to take after the ascent :-) So choose your route and get into it!


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Twenty-nine detainees killed in Venezuela police station cellblock riot
Mariangel Moro
ACARIGUA, Venezuela (Reuters) - Twenty-nine detainees were killed and 19 police officers were wounded in a confrontation in a cellblock in central Venezuela in what a state official called a failed escape attempt, but human rights groups described as a massacre.
The incident took place in the town of Acarigua in a municipal police cellblock in the central state of Portuguesa.
"There was an attempted escape and a fight broke out among(rival) gangs," Portuguesa Citizen Security Secretary Oscar Valero told reporters. "With police intervention to prevent the escape, well, there were 29 deaths," he said, adding that some 355 people were being held in the cellblock.
Detainees detonated three grenades, which wounded 19 police officers, he said. Venezuela's Information Ministry did not immediately reply to a request for comment.
Human rights groups questioned the official version of the events.
"How is it that there was a confrontation between prisoners and police, but there are only dead prisoners?" Humberto Prado of the Venezuelan Prisons Observatory said in a telephone interview. "And if the prisoners had weapons, how did those weapons get in?"
Detainees for several days had been demanding that government ombudsmen help them avoid being transferred to distant prisons where they would not be able to receive visits from relatives, Prado said.
Authorities entered the cell block to carry out searches and remove visiting women when violence broke out, Prado said, estimating the facility in fact held some 540 inmates.
Police cellblocks in Venezuela are meant to hold citizens for 48 hours while they face formal charges. But detained citizens can spend months or even years in such facilities because prisons are too overcrowded to receive them and because of chronic delays in basic criminal justice proceedings required to indict them.
In 2018, a riot that led to a fire in a police cellblock in the central city of Valencia killed 68 people, including two women who were visiting.
Carlos Nieto of human rights group A Window to Freedom said the country has around 500 cellblocks with capacity to hold around 7,000 people that currently have nearly 55,000 detainees in custody.
Additional reporting by Vivian Sequera; writing by Brian Ellsworth; Editing by Leslie Adler


From the president's office at Mission College, Adriana Barrera can almost hear the ping of baseball and softball bats, and the footsteps of cross-country runners.
After months of uncertainty about when, or if, the school might reinstate its athletic program on a limited basis, Barrera is increasingly more confident that there will be sports at the Sylmar school.
"I anticipate I'll be able to name an athletic director in the fall," Barrera said.
Once that position is filled, Barrera expects Mission to move forward with the hiring of coaches and the recruitment of student-athletes to field baseball, softball and men's and women's cross-country teams for the 2002-03 school year.
The timeline doesn't conform to the 2001-02 target date announced by school officials early last year, and is not as expeditious as some community activists wanted, but Barrera said it is the prudent approach.
"I wanted to make sure we followed proper procedures," Barrera said.
Barrera, who became Mission's president last July, had to reconcile the prospect of adding a sports program while there are more pressing and higher-priority needs at the college.
She said several key concerns, such as the hiring of additional faculty and staff to handle a rapidly growing student population and resurrecting its performing arts program, were on the Mission agenda alongside sports.
Barrera also wanted to ensure the faculty that academic needs would not be compromised for the sake of athletics.
"At this point and time, I've pretty much talked with various faculty leaders and I've gotten their support," Barrera said. "From their standpoint, fulfilling some of the commitments, like increasing full-time teacher hiring, has eased their concerns."
Barrera said Mission has a full-time staff of 82, including counselors and other personnel, to serve a student body that reached 7,100 last semester. The school hired five teachers in the spring and plans to hire eight teachers in the fall and five more next spring.
The attention paid by Barrera to academic issues are welcome by faculty members such as Mike Reynolds, an outspoken science professor and former swimmer at Stanford.
"I have nothing politically or philosophically against sports," Reynolds said. "But given the finite resources here, it's hard for me to see funds that could go to other programs go to sports.
"We need to first take care of the bread and butter. I'm not going to go out and buy my kid a pair of $150 shoes if I can't feed his brother. . . . I just want to see these kids learn more basic skills."
Barrera said she intends to jump-start Mission's sports program not just to offer students an extra-curricular activity, but to help balance the college's demographics.
"The average age of our students is 27 years," Barrera said. "We are working very closely with our high schools to recruit the graduating seniors. Having an arts program and a sports program will certainly help our students gain a sense of college life and attract younger students."
But launching those programs, especially athletics, is not cheap. For existing sports programs at other junior colleges, most of them relatively cash-strapped, the trick is to maintain their equipment and uniforms, spending money on replacements only when absolutely necessary.
At Mission, they have to start from scratch. No sooner had Mission dropped sports in 1997 than thieves broke into a baseball storage facility and carted off uniforms, catching gear, equipment and pitching machines.
"The budget plan that has been put together, for the four sports I mentioned, has roughly a $150,000 figure to it," Barrera said. "I thought that was kind of low."
Two athletic directors in the region, Chuck Ferrero of Valley and Len Mohney of Canyons, estimate the start-up cost for a junior college baseball program at around $50,000, not including coaches' salaries and the rental and maintenance costs of fields, which Mission would have to secure through the Los Angeles County Parks and Recreations Dept. for El Cariso Park.
A baseball budget at an existing program, like most sports, must account for replacement uniforms, refurbishing equipment, transportation, annual membership fees to an athletic conference, game officials, lodging and meals at some road games and other expenses.
Baseball would be the flagship sport at Mission, likely to draw the most interest from high school players, especially those in the northeast Valley. But Gary Donatella, longtime baseball coach at Sylmar High, remains only "cautiously optimistic" about the college restoring the sport.
"It's a crying shame they haven't put the program back together sooner," Donatella said. "Many kids in this area can't afford cars and going to play baseball at Valley or Glendale or Canyons is out of the question for them.
"I believe sometimes administrators take the road of least resistance. If an administrator thinks that reinstating athletics is going to create potential headaches for him or her, they feel that sometimes the best thing to do is lay quiet until they get enough resistance that they have to do something."
Administrators at Mission weren't able to fly under the radar for too long after former president William E. Norlund eliminated the school's six sports in 1997 for financial reasons. The response from community leaders and activists was swift.
The most vocal and relentless of the critics was Duke Russell, a retired electrician from Hollywood who had spearheaded similar campaigns to save athletic programs at other colleges in the region, mainly Los Angeles City and Cal State Northridge.
Russell organized rallies, pleaded with the Los Angeles Community College board of trustees to force Mission into restoring sports and sought support from politicians. The board told Russell that trustees did not "micromanage" campuses and would not force Mission to restore athletics. No politicians came forward to aid activists.
Sometimes Mission officials didn't help. In 1998, Norlund accepted blame for the college's forfeiture of $4.7 million in state funds for expansion of the campus. Norlund failed to solicit opinions from the public early enough to meet a deadline for using the funds.
Other school officials made miscalculations, drawing heat from the public when their grandiose plans didn't pan out. Tom Oliver, Mission's interim president between Norlund and Barrera, pledged the college would bring back sports by the 2001-2002 school year.
Such unfulfilled promises are among the arguments raised by Russell, who hasn't let up on his crusade.
He believes Mission is putting up a smoke screen and could easily afford to reinstate sports through the $4,000 the school would receive from the state for each student-athlete.
Barrera said the figure is slightly less and much of the money goes toward operating expenses.
"It depends on the number of classes they are taking and the type of classes they are taking," Barrera said.
Barrera said $111 million has been earmarked for Mission through Proposition A, to be allocated piecemeal according to the projects undertaken by the college.
Some of the funds will be used to finance a proposed on-campus gymnasium and lockers. The money also would go toward building more classrooms.
"It would be tight, but we have some space left on the 22 acres we occupy," Barrera said. "We are moving in the right direction. I just want to have the infrastructure in place and bring back sports the right way."


Used in 134 recipes at an average of 1.432%.
A mix over the famous chocolate. 3 layers, chocolate, biscuit and caramel. Acetyl Pyrazine helps the biscuits become crunchier. Steep 7 days.
Let's face it. Chocolate vapes are terrifying. Most of them taste like… something not appropriate to mention here. Well, forget everything you know about chocolate vapes. i managed to create a milk chocolate lover's dream in this mix, with a natural, creamy, sweet, authentic-tasting milk chocolate flavor, wrapped around a gooey caramel coated, creamy vanilla custard blend.
The Bûche de Noël is a Christmas tradition among the French that dates back to the 19th century. The cake represents the yule log that families would burn starting on Christmas Eve. The burning of the yule log symbolized the new year to come and would bring good luck to the family. While no one is positive on exactly how the yule log turned into a cake, everyone can agree it's a delicious tradition we never want to end.
The cake in this mix is represented by FA Chocolate Glazed Doughnut, I chose this because I wanted to incorporate the chocolate and cake notes of the doughnut.
The heavy cream is replicated by using FA Fresh Cream and VT Pudding Base to make a heavy and sweet cream with a hint of vanilla.
For the icing I used a combination of VT Chocolate Base and VT Dark Chocolate to make it sweet and a slightly bitter at the same time.
TFA Butter is used as an emulsifier and the FA Madagascar is used to help with the authenticity of the dessert.
OOO Powdered Sugar is like the garnish on top and FW Sweetener because it's a cake. It's supposed to be sweet.
This was an experiment that came out great. I blended together different recipes test samples, to create this chocolate strawberry milk. Sorry I had to revise recipe due to me miss calculating % of mix.
Let it steep for 7-10 days.
in that mix to see how it works.
but i noticed that it does somehow affects the chocolate and the nuts... in a positive way.
This was mixed on the show Mixing with me mates on the Diydownunder network.
So i have been working on this for a wile now i didn't think the chocolate was up to scratch to begin with but after trying a few different ones like molinberry glamor chocolate i settled on this as it was the most authentic to the actual cherry ripe you get from the shops. Needs a week steep and you can probably sub out the raspberry with another raspberry as it is just there to support the cherry. The dedicated coconut and cherry mix really give you that authentic cherry ripe filling tast and mouth feel.
Chocolate creamy pudding with a Graham crust for Mixing with me Mates!


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Q: How to get the 'Endpoint' of a deployed 'Lambda' function in AWS? I am developing a serverless application using the Serverless Framework. I deployed my application using
$ serverless deploy

After deploying, I got the endpoints for my functions which look like this
https://ly5webovq4.execute-api.us-east-1.amazonaws.com/prod/notes

which I did not note down. Now I need it, but could not find it. Where can I find the Endpoints?

A: Just run
$ sls info

And you'll get all the information on the deployed endpoints and functions.

redpajama_set_name: RedPajamaStackExchange


text:
package com.pawelmandera.duplicates

import scala.util.Try

import com.pawelmandera.hash.ElementHashes

trait MinHashFunctions {
  /** Calculate sketch for an element. */
  def sketch[A: ElementHashes](x: A, hf: HashFunctions): Try[Sketch] = {
    val initHashes = implicitly[ElementHashes[A]].hashes(x)
    initHashes map { h => hf map { minhash(_, h) } }
  }

  /**
    * Calculate sketches for a set of elements.
    *
    * @param xs set of elements of an ElementHashes type class
    * @param hf hash functions
    * @return a map with elements as keys and sketch as values
    */
  def sketchesMap[A: ElementHashes](xs: Set[A], hf: HashFunctions): Map[A, Sketch] = {
    val sketchesMapTry = (xs.par map { e => (e, sketch(e, hf)) }).seq
    (sketchesMapTry filter { _._2.isSuccess } map { e => (e._1, e._2.get) }).toMap
  }

  /** Generate random hash functions
    *
    * @param n number of hash functions
    * @param seed a random seed
    * @return a vector of hash functions
    */
  def hashFunctions(n: Int, seed: Int): HashFunctions = {
    val randomGen = new scala.util.Random(seed)

    def randHashF: Long => Long = {
      val a: Long = randomGen.nextLong()
      val b: Long = randomGen.nextLong()
      (x: Long) => (a * x + b) % 768614336404564651L
    }

    Vector.fill(n)(randHashF)
  }

  /** Calculates a minhash given a hash function and a set of numbers. */
  def minhash(hashFunc: Long => Long, s: Set[Long]): Long = (s map { hashFunc(_) }).min

  /** Calculates a similarity based on minhashes. */
  def similarity(s1: Sketch, s2: Sketch): Double =
    (s1 zip s2 count { case (e1, e2) => e1 == e2 }).toDouble/s1.length
}


60 Litre, 10 UK Gallon, 12 US gallon Fermenter. High quality food grade plastic.
Comes with lid (pre-drilled to fit black airlock grommet), rubber lid seal and base with measurements up to 60 litres marked on the side. Base also comes pre-threaded to fit a White barrel tap. If you dont wish to fit a tap then simply leave nut in place.
This fermenter is suitable for making 2 x 23 litre beer kits, gingerbeer kits, cider kits and wine kits and for making a 50 Litre spirit wash.
If you would like any matching fittings: airlock, grommet, tap, stick-on thermometer please click on "accessories" to easily select them..
Height is approx 68cm, allow for additional height an airlock will contribute, diameter approx 39cm.


text:
Going To The Caribbean? Read THD's One-Minute Rum Guide And Look Suave At The Bar
Gary Walther Contributor
ForbesLife Magazine
I solve the key hotel mystery: Which rooms are best?
Rum has always been a mystery to The Hotel Detective. But on a trip to Nevis (see my review of Montpelier Plantation), THD had the opportunity to participate in a rum tasting and learn all about a spirit that is omnipresent but that hasn't created a cult following for itself (although there are rum cultists). That may be because it's "the wild west" when it comes to rules on production in the words of Dave Russell, rum expert and master of the well designed and written website The Rum Gallery (rumgallery.com). Here's one bit of proof: In the Dominican Republic, rum is made in one style, while across the border in Haiti, it is made in a completely different one. So here's a quick guide to the spirit.
What is rum?
A spirit, usually about 80 proof in the U.S., but sometimes stronger in the Caribbean, produced by fermenting sugarcane juice or a by-product of sugarcane production, usually molasses, and then distilling the resulting liquid. To be called rum, the distillate must be aged at least one year in barrels, usually used bourbon or whiskey casks. The Caribbean is where rum was invented and still the source of more than 80% of all rum.
Is there system that makes it easy to understand rum? Not in the least. Only Martinique and Guadeloupe use a system based on terroir. (See next question.) "It's the most interesting spirit category because it can be made anywhere in the world," says St. John Frizell, proprietor of Sunken Harbor Club in Red Hook, Brooklyn, which has one of New York's top rum lists. (His favorite: English Harbor, which he says makes a great Old-Fashioned.)
What's the proper way to taste rum?
This from Mark Theron, a noted rum importer based in Nevis. Don't swirl it, just tilt the glass slightly and sniff the top, letting the flavor notes come to you. Then take a sip.
I've seen bottles labeled 'Rhum.' What does that mean?
Very good question. It means that the spirit came from Martinique or Guadeloupe. Martinique is unique in having the only AOC rules for rum in the world, which is why its rums are held in such esteem.
What are the basic styles?
Rhum Agricole: Rum from Martinique and Guadeloupe. It's made strictly from freshly pressed sugar cane that must be fermented within 24 hours, and it makes up only five per cent of the world's rum. Clement 70 is a distillery revered by rum connoisseurs.
Light or Spanish Style: Rums from former Spanish colonies in the Caribbean and Central and South America. Most are made from molasses. Countries vary in additives allowed; caramel is often used to color the rum and sugar sometimes added to brighten flavor.
English or Heavy Style: From former British colonies. Mt. Gay on Barbados claims to be the oldest rum house in the world and its XO (meaning extra old), a blend of 12-15-year-old rums, is a good example of the style.
Demarara Style: From Guyana and named for the country's only surviving distillery. Dark, sweet, intense. El Dorado, a 15-year rum is a good example, viscous, walnutty, and with a long finish.
What does the label-age mean?
Rums are often a blend of spirits from different years, like Champagne. In the U.S., the label-age refers to the youngest rum in the blend. In the French Caribbean, the word "vieux" on the label means all the rum in the bottle has been aged at least three years. In the end, it doesn't mean very much said one expert.
What are the top selling rums?
In 2014 the five top brands were in order: Bacardi White and Silver, Tandauy (Phillipines), McDowells (India), Havana Club #7 (from Cuba), and Captain Morgan Spice Gold.
Gary Walther
I have misspent my life staying in luxury hotels. It started in 1975 on my post-college Eurailpass pilgrimage, when I stayed in a cheap place on the rue Gay Lussac in Pa...


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General firearms news, starting with Rep. Hank Johnson
being called out and called a number of unpleasant things(all of which fit).
I won't begin this with letter with the salutation "Dear," because I only have contempt for you, and the disgusting responses you gave to The Daily Caller when they asked you about the Congressional investigation into the Fast and Furious "gunwalking" international criminal conspiracy (see article for video--Examiner.com does not accomodate the html code to embed it here).
And it continues from there.
Blocked funding for ATF's planned shotgun import ban already paying dividends
Last November, the "Fiscal Year 2012 Agriculture, Commerce/Justice/Science and Transportation/Housing/Urban Development Appropriations bills" omnnibus was signed into law. One provision of that law blocks funding for a Bureau of Alcohol, Tobacco, Firearms and Explosives (BATFE) plan to ban the importation of certain shotguns, based on their not being sufficiently suited to "sporting purposes."
And I want to see that AKDAL shotgun; that looks really interesting.
On Gunwalker and media:
In re new media, I believe Gunwalker is a milestone of sorts, because it truly is a major story that had to be brought to the networks and newspapers, and they still resist reporting on it at all, let alone not embedding their reporting with their own agenda. I believe it shows the monolith press is no longer the sole gatekeeper for information, as the internet has given us a way to bypass them. I've documented time and again how Mike and I have beaten them, with all their resources, to the punch, and also how they have acted more like collaborators than journalists.
That they still are trying to be the ones to set memes in motion is evident by the APs list of top ten stories for 2011: Fast and Furious didn't make the cut. That led me to observe:
There's another big story the Fourth Estate Fifth Columnists missed for 2011: Their growing, self-created irrelevance, and how in spite of their deliberate indifference, coupled with agenda-driven manipulation, they are no longer the sole gatekeepers of information.
So leave it to them to put a positive spin on the fact that they're overwhelmingly distrusted. And welcome to the dawning of the age of the "unauthorized journalist."
Issa has some words for Holder & Co.:
House oversight committee chairman Rep. Darrell Issa told The Daily Caller that Attorney General Eric Holder owes an apology to the Mexican government and to the families of Operation Fast and Furious victims south of the border.
"Justice has blood on their hands," Issa said Wednesday during an exclusive interview with TheDC, referring to the U.S. Department of Justice.
"The attorney general, as the head of Justice, has to explain that to the families of survivors," Issa said. "Yes, he should find a way to make it very clear to our neighbors to the south — at least to the government and at least publicly — that there needs to be deep regret for what happened and there needs to be reassurances that it never happens again."
Something I'll add: the article notes At least 300 people in Mexico were killed with Fast and Furious weapons, as was U.S. Border Patrol agent Brian Terry. I'd change that 'were killed' to 'have been killed so far, that we know of'.
Oh boy, just found this:
"Oversight and Government Reform Committee Chairman Darrell Issa demanded in [a] letter to Attorney General Holder that the Justice Department make Arizona U.S. Attorney's Office Assistant United States Attorney Michael Morrissey available to speak with Committee investigators about his role in and knowledge of Operation Fast and Furious," a release issued moments ago by the committee reveals:
His supervisor, Patrick Cunningham, has stated he will exercise his Fifth Amendment and refuse to answer any questions pertaining to Operation Fast and Furious – such an assertion is extremely rare and suggests possible criminal culpability on the part of a high ranking Justice Department official. Morrissey, who reported directly to Cunningham's and was intimately involved with Operation Fast and Furious.
"Since August, the Department has identified Patrick Cunningham as the best person in the U.S. Attorney's Office to provide information about Fast and Furious to the Committee," Issa said in his letter to Holder. "The Department has refused to make Michael Morrissey and Emory Hurley, both Assistant United States Attorneys supervised by Mr. Cunningham, available to speak with the Committee, citing a policy of not making "line attorneys" available for congressional scrutiny. Mr. Morrissey, however, was Mr. Hurley's direct supervisor, and an integral part of Fast and Furious. Importantly, both Morrissey and Hurley are unique in their possession of key factual knowledge about Fast and Furious not readily available from any other source."
The Chairman also reiterated that the Justice Department still has not complied with the subpoenas issued to date, including subpoenaed documents from Cunningham, Morrissey and Hurley.
Further, Cunningham's decision to invoke a self-incrimination refusal was the subject of a letter sent by Issa to Attorney General Eric Holder on Tuesday, in which he wrote:
The implication that Mr. Cunningham may have engaged in criminal conduct with respect to Fast and Furious is a major escalation of the Department's culpability. The significance of these developments cannot be overstated, and this assertion raises many questions about ongoing criminal cases currently pending in federal court in Arizona—including prosecutions related to Fast and Furious.
As to the "We never let guns walk!" lie,
Witnesses have reported that AUSA Hurley may have stifled ATF agents' attempts to interdict weapons on numerous occasions. Many ATF agents working on Operation Fast and Furious were under the impressions that even some of the most basic law enforcement techniques typically used to interdict weapons required the explicit approval of your office, specifically from AUSA Hurley. It is our understanding that this approval was withheld on numerous occasions...We have further been informed that AUSA Hurley improperly instructed ATF agents that they need to meet unnecessarily strict evidentiary standards merely in order to temporarily detain or speak with suspects.
More at the link. LOTS more.
A post at Sipsey on the subject of what calls for confiscation actually mean:
Three Death Penalties for Prohibited Arms Possession.
A special German court in Zamość [near Krakow] sentenced to death 19 year-old Franciszek Pokrywka of Powieki, 27 year-old Iwan Zilnyk and 35 year-old Paweł Huzar, both of Ułazów, for prohibited possession of firearms as well as for violating the duty to report possession of firearms.
Pokrywka had an automatic pistol with six cartridges and, despite the universally-known order about surrendering the arms, he did not give it up. Sometime later he sold the pistol to Zilnyk, who a few days after that offered the firearm for sale to Huzar, who, though he did not buy it, still failed to fulfill his duty to report it to the proper authorities.
The above-mentioned death sentences have already been carried out. -- Nowy Kurjer Warszawski [New Warsaw Courier], Jan. 22, 1941, quoted in Stephen Halbrook's Citizens in Arms.
I've been scanning a lot of Stephen Halbrook's work lately, trying to find the right chapter heading quotes for Absolved. Particularly impressive is his The Swiss & The Nazis: How the Alpine Republic Survived in the Shadow of the Third Reich.
In the process I encountered the dry newspaper announcement above. You know, I have been criticized mightily across the political spectrum for my response to an an impatient gun grabber, "If you try to take our firearms, we will kill you." But the thing is, those who propose to take our liberty and our property have already decided -- in their ignorance of the unintended consequences -- that it is worth it to them (or, at least, inconsequential) if we are killed in the process.
As I observed in my call to break Democrat Party headquarters windows in advance of the passage of the tyrannical Obamacare mandate:
Nancy Pelosi's Intolerable Act is within days of passage by devious means so corrupt and twisted that even members of her own party recoil in disgust.
This act will order all of us to play or pay, and if we do not wish to, we will be fined.
If we refuse to pay the fine out of principle, we will be jailed.
If we resist arrest, we will be killed.
They will send the Internal Revenue Service and other federal police to do this in thousands of small Wacos, if that is what it takes to force us to submit.
This arrogant elite pretends that this oppression is for our own good, while everyone else understands that this is about their selfish, insatiable appetite for control over our liberty, our money, our property and our lives.
All gun confiscation proposals come from the same motivation. Thus, if we say, "If you try to take our firearms we will kill you," it is important to remember that this is a threat of defensive violence to counter their original threat of offensive violence.
Properly formulated, shorn of all bushwah and pretense, what these people are saying to us first is this:
"We will take your firearms if we have to get the government to kill you to do it."
Such people will be insulted if you call them National Socialists, but is there a functional difference in the exercise of their demands?
You could ask Franciszek Pokrywka, Iwan Zilnyk and Paweł Huzar -- three human beings executed for the knowledge and possession of just one pistol -- if they thought so. Oh, that's right, they're long dead, killed by the exercise of that "government monopoly of force" that the gun grabbers of CSGV are so proud to advocate.
And last,
The shooting happened about 7:45 a.m. at 301 Kendra Drive where an armed man kicked in a door of the home. Inside, a growling dog alerted the homeowner who grabbed a gun and fired one shot after confronting the burglar. Police say the suspect was rushed to the Midwest City hospital where he died.
Labels: 2nd Amendment, Gun Bigots, Gunwalker, Media Malpractice
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If the judge allows this suit, he should be


COUNSEL: Denton N. Thomas and Susan Gorman, Andrews & Kurth, Houston, Texas, and William H. Lancaster, Andrews & Kurth, Los Angeles, California, for the plaintiffs-appellants.
Jonathan S. Cohen, Tamara W. Ashford, Tax Division, United States Department of Justice, Washington, D.C., for the defendant-appellee.
Before: Harry Pregerson and Kim McLane Wardlaw, Circuit Judges, and Milton I. Shadur, District Judge.
Taxpayers Frederick and Robin Tedori (collectively "Tedoris"), sole shareholders of an Interest Charge Domestic International Sales Corporation ("DISC"), have claimed as a deduction on their 1989 and 1990 joint federal income tax returns the interest they had paid to the United States on the deferred amounts of their DISC-related tax liability. This litigation stems from the Government's denial of those deductions on the premise that the interest paid was non-deductible personal interest under 26 U.S.C. S163(h).2 Acting on crossmotions for summary judgment, the district court ruled for the Government and against Tedoris, dismissing their suit for refund. We have jurisdiction pursuant to 28 U.S.C.S1291. For the reasons given below, we affirm.
(A) at least 95% of its gross receipts were "quali fied export receipts,"
(B) in terms of their adjusted bases, at least 95% of its assets were "qualified export assets,"
(C) it did "not have more than one class of stock and the par or stated value of its outstanding stock [was] at least $2,500 on each day of the taxable year,"
(E) it was "not a member of any controlled group of which a [Foreign Sales Corporation] is a mem ber."
"Qualified export receipts" and "qualified export assets" are respectively defined in Sections 993(a) and (b).
Though obligated to file informational income tax returns, a DISC is not a taxable entity, but is instead taxed at the shareholder level under Section 995.3 Each DISC shareholder is ratably taxed currently on a portion of the DISC's income as a constructive dividend ("deemed distribution"), regardless of whether that income is actually distributed.4 But the shareholders are not taxed on the remaining part of the income until (1) it is actually distributed or is deemed distributed, (2) the shareholders dispose of their stock in the DISC or (3) the DISC loses its special status (see Section 995(c)). As footnote 3 indicates, each DISC shareholder must pay an interest charge on the deferred amount.
On audit the Internal Revenue Service ("IRS") rejected both of those deductions because the interest payments were deemed nondeductible personal interest. That disallowance created tax deficiencies for Tedoris of $22,720 for 1989 and $32,344 for 1990. Both deficiencies were paid, and Tedoris then filed timely claims for refund, contending that the interest payments were not personal interest because they were properly deductible either as "properly allocable to a trade or business" under Section 163(h) (2) (A) or as "investment interest" under Section 163(h) (2) (B).
Tedoris filed a timely notice of appeal, and (as stated earlier) jurisdiction exists under 28 U.S.C. S1291. We review the district court's grant of summary judgment and its interpretation of the Code de novo (Ingham v. United States, 167 F.3d 1240, 1243 (9th Cir. 1999)).
(1) In general.--In the case of a taxpayer other than a corporation, no deduction shall be allowed under this chapter for personal interest paid or accrued during the taxable year.
(B) any investment interest (within the meaning of subsection (d)) . . . .
Tedoris urge that the interest charge for their DISC-related deferred tax liability is not "personal interest " because it comes within each of the Section 163(h) (2) (A) and (B) exceptions (only one of those arguments needs to succeed in order for Tedoris to prevail). No caselaw has dealt with the precise question whether either of those exceptions applies to such a DISC-generated interest charge.
Because Redlark, 141 F.3d at 939-40 held that the phrase "properly allocable" in Section 163(h) (2) (A) was ambiguous and that the Regulation was a reasonable interpretation of the Code, the Regulation's validity is beyond question here. Indeed, four other circuits have held that the Regulation is valid and that income tax deficiencies cannot be considered "indebtedness properly allocable to a trade or business" even when the income underlying the deficiency originates from the taxpayer's own business (in order of decision, Miller v. United States, 65 F.3d 687 (8th Cir. 1995); Allen v. United States, 173 F.3d 533 (4th Cir. 1999); McDonnell v. United States, 180 F.3d 721 (6th Cir. 1999) and Kikalos v. Commissioner, 190 F.3d 791 (7th Cir. 1999)). While Redlark involved the deduction of interest payments made on tax deficiencies by a couple running an unincorporated business, the same ambiguous phrase is implicated in this case, where the question is whether interest on deferred DISC-related tax liability is "properly allocable" to a trade or business.
(A) Paid on underpayments of individual Federal, State or local income taxes and on indebtedness used to pay such taxes (within the meaning of S1.168-8T), regardless of the source of the income generating the tax liability.
While the Government says that deferred DISC-related tax liability is an "underpayment," so that the deduction of interest on that amount is prohibited by the Regulation, Tedoris counter that a "deferment" is something distinct from an "underpayment," hence rendering the Regulation inapplicable.
Section 995(f) (6) says that the DISC interest charge is "treated, for purposes of this title, as interest payable under section 6601 . . . ." But Section 6601, entitled "Interest on Underpayment, Nonpayment, or Extensions of Time for payment of Tax," does not enlighten us beyond its heading. Nevertheless both sides seek comfort from that title (despite the firmly established proposition that a statutory title is not part of the statute itself).10 If that were the issue, we would agree with Tedoris that a deferment is more akin to, though not synonymous with, an extension of time.
But that is not the real issue as we view it. Instead the plain meaning of "underpayment," confirmed by its use throughout the Code, reveals that the term refers to a situation in which money is presently owed but not paid by a taxpayer.11 Certainly the interest payments at issue in this case were not underpayments in the sense that they were literally tax deficiencies on money presently owed.12 Instead Section 995(f), by postponing payment of Tedoris' obligation, clearly relieved them of any current duty to pay taxes on the deferred DISC income except for the interest charge. In other words, as the statute says, the government "deferred " Tedoris' obligation to pay taxes: Tedoris did not fail to pay money presently owed--that is, they did not underpay.
Based on the language of Section 163(h) (2) (A) and (B) of the Code, ascribing the common and ordinary meaning to the words used therein, does allowance of either exception to the Tedoris constitute an "ab surdity . . . so gross as to shock the general moral or common sense"?
We look then to sources extrinsic to the statutory language itself. No guidance is provided by the structure or legislative history of Section 163(h), though the parties strive to urge otherwise. Tedoris assert that because Section 163(h) was enacted after Section 995(f), "if Congress had intended to now deny the previously allowed deduction for interest paid under Section 995(f), presumably it would have specifically so provided." Taking the opposite view, the Government says that " [p]resumably, if Congress had intended to permit a deduction for the interest paid under Section 995(f) by an individual, it would have specifically provided for it when it spelled out certain types of deductible interest in I.R.C. S163(h) (2)." Neither of those attenuated inferences offers any real value to the task at hand.
(B) the base period T-bill rate.
Enterplast, however, is a separate legal entity whose business is not the business of its shareholders (see, e.g., Erickson v. Commissioner, 598 F.2d 528, 530 (9th Cir. 1979)).16 While Tedoris are Enterplast's sole shareholders and also manage the corporation, that is really not relevant. Having chosen to operate in corporate form and to derive whatever benefits that structure provides,17 Tedoris must live with the consequences of that choice. As shareholders, Tedoris cannot label Enterplast's business as "our business" any more than any shareholder in any closely held (or publicly held) corporation can do so. From that perspective, Tedoris are on far weaker ground in "trade or business" terms than the taxpayers in Redlark, who were a husband and wife operating an unincorporated business.
In sum, a shareholder's interest payments on a DISC's deferred tax liability are not "properly allocable to a trade or business" because the only "trade or business " involved is that of the DISC corporation and not that of the shareholders. Hence those interest payments are personal to the shareholder, and Tedoris have submitted nothing that can entitle them to the double benefit of deferred income taxes plus the tax deductibility of the interest paid as the price for that deferral.
Alternatively Tedoris (quoting Section 163(d) (3) (A), which in turn defines "investment interest" as used in Section 163(h) (2) (B)) argue that the interest charge is properly deductible as "investment interest" because it is "indebtedness properly allocable to `property held for investment.' " Again Tedoris begin from a false premise, thus assuring a false conclusion (the equivalent of GIGO--"garbage in, garbage out" --in the world of the computer). That is so because the deferred DISC-related tax liability is simply not the result of an "investment activity."
If by contrast Tedoris had borrowed money to enable them to make an additional capital contribution to Enterplast, they could fairly deduct the interest on that loan as having been "paid . . . on indebtedness properly allocable to property held for investment" (Section 163(d) (3) (A)). But once more Tedoris are bound by the structure that they themselves have chosen for the conduct of Enterplast's business. Just because the DISC-permitted deferral of income tax on the undistributed portion of Enterplast's income may provide Tedoris with the economic equivalent of an interest only loan from the Government (see n.17), that does not permit Tedoris to ignore the reality that they have not opted to have Enterplast distribute those earnings to Tedoris (thus triggering Tedoris' current obligation to pay income taxes) so that Tedoris could then choose whether or not to reinvest those funds in Enterplast.
As in so many areas where the tax impact of taxpayer conduct is at issue, taxpayers are allowed an almost unlimited universe of choices as to how they conduct their affairs. But given that freedom of choice, they cannot complain of the tax consequences that attach to the path that they have chosen, nor are they free to assert that the tax consequences should be identical to those that would flow from a different course of conduct that the taxpayers have not elected to follow.
So just as with Tedoris' earlier argument, even though their decision as Enterplast's managers to defer taxes may also benefit the business as a collateral consequence of providing Tedoris with the primary benefit of deferred taxes, the interjection of the corporate entity separates the Tedoris as corporate managers from Tedoris as shareholders. And because it is Tedoris as shareholders--more precisely, as individuals-who have paid the interest charge, the interest payment is a personal expenditure and is treated for purposes of Section 163(h) as personal interest.
While the Regulation does not control this case, an interest charge for deferred DISC-related tax liability is neither "properly allocable to a trade or business" nor appropriate "investment interest" under Section 163(h) (2). Because Tedoris' payments were therefore of "personal interest " within the meaning of the Code, no deductions are allowed for those payments except for those already consented to by the government under the phase-in rules. We AFFIRM the decision of the district court.
Citations to the Internal Revenue Code ("Code") will take the form "Section, " omitting the prefatory"26 U.S.C." Temporary Treasury Regulation S1.163-9T(b) (2) (i) (1987), the only adopted Regulation implicated in this case, will be referred to simply as the "Regulation."
Section 501 of the Revenue Act of 1971 introduced the DISC concept as a means of aiding United States exports and correcting perceived trade imbalances. Congress then altered the DISC rules in the Deficit Reduction Act of 1984, which established the Foreign Sales Corporation ("FSC") provisions for larger companies and the "Interest Charge DISC" rules for smaller ones such as Enterplast. As for the latter category, if the DISC's shareholders agree to pay an interest charge on deferred taxes, the DISC is allowed to defer in each year all of its taxable income attributable to as much as $10 million in qualified export receipts (see Section 995(b) (1) (E)).
Under Section 995(b) a "shareholder of a DISC shall be treated as having received a distribution taxable as a dividend " equal to his or her prorata share of certain items of DISC taxable income in a given year. That income amount is derived from the formula set out in Section 995(b) (1) (A) through (G).
In their 1989 return Tedoris reported the $46,656 as a miscellaneous itemized deduction. In the 1990 return the $115,514 interest charge was deducted from the dividend income that Tedoris reported from Enterplast.
Thereafter, however, after the entry of its summary judgment order, the district court entered a May 6, 1998 order approving the parties' stipulation that Tedoris are entitled to deduct 20% of the interest paid in 1989 and 10% of the interest paid in 1990 pursuant to Sections 163(d) (6) (A) and (B). Those provisions relate to a phase-in for the disallowance of investment interest over the years 1987 to 1990.
Before the district court Tedoris had strenuously argued that the Regulation was invalid in light of the "plain language" of Section 163(h) (2) (A), citing Redlark v. Commissioner, 106 T.C. 31 (1996) to support that contention. But the district court disagreed, holding that the term "properly allocable" in Section 163(h) (2) (A) was ambiguous and that the Regulation was reasonable in light of that ambiguity. Since then Redlark itself has been overturned by this court (Redlark v. Commissioner, 141 F.3d 936 (9th Cir. 1998)), in an opinion handed down just seven days after the district court had granted summary judgment against Tedoris.
It should be noted that the district court never discussed whether the "investment interest" exception applied, even though that had been argued in the Tedoris' summary judgment brief. As we discuss later, that contention is also without merit.
No explanation has been forthcoming from the government as to why such a "temporary regulation," issued in 1987 shortly after enactment of the Tax Reform Act of 1986, should remain "temporary" well over a decade later (see Kikalos, 190 F.3d at 795-96). But we need not address any doubts raised by that factor, for our analysis rejects the Government's position on the merits.
Note that while "underpayments" and "extensions of time" are given the same treatment by Section 6601 in terms of the accrual of an interest obligation when either is present, that similar treatment does not necessarily mean (or even suggest) that the terms must be synonymous for present purposes. Just as procedure is not substance, so similar treatment is not necessarily definitional.
Underpayment = W (X + Y Z), where W = the amount of income tax imposed; X = the amount shown as the tax by the tax payer on his return; Y = amounts not so shown previously assessed (or collected without assessment); and Z = the amount of rebates made.
This scenario is thus unlike that of the taxpayers in Redlark, because Tedoris were not obligated to pay a certain amount on their year-end taxes.
Accord, In re AppleTree Markets, Inc., 19 F.3d 969, 973 (5th Cir. 1994) ("proposed regulations are entitled to no deference until final"); LeCroy Research Sys. Corp. v. Commissioner, 751 F.2d 123, 127 (2d Cir. 1984) ("Proposed regulations are suggestions made for comment; they modify nothing"). Indeed, whatever may be said about "temporary" regulations that have not gained permanent status after 13 years (see n.9), any notion of ascribing weight to anything that has remained in the "proposed regulation" limbo for a like period is totally unpersuasive. But cf. VanScoter v. Sullivan, 920 F.2d 1441, 1449 (9th Cir. 1990), noting that although a proposed regulation or rule does not have "the force of law," if it is "reasonable" it may be entitled to deference by the court.
DISC income, to the extent it is not deferred, is treated as received directly by the DISC's shareholders, and the tax on that income currently becomes due and payable. Thus, the DISC related tax deferral can be equated with a consensual underpay ment of tax. . . .
Amazingly, Tedoris never discuss Redlark or any of the other cases unanimously holding that the language in Section 163(h) (2) (A) is ambiguous.
Like a partnership (see Section 701) or a Subchapter S corporation (see Section 1363), a DISC is a nontaxable entity.
Absence of personal liability is the most obvious, though by no means the only, perceived advantage of the normal corporate structure. In the special situation of the DISC corporation, the Code's provisions create the economic equivalent of an interest-only loan from the Government (the effect of deferring income tax liability on a large chunk of ordinary income) that is unavailable to an individual or individuals owning and operating the identical business in noncorporate form.


Beginning on October 3, 2017, the Chowan University Communication Arts Department in conjunction with the Hertford County Arts Council are proud to offer Community Pottery Classes. Pat Clement will be sharing her expertise with hand building projects, Dr. Mitch Henke and Rob Buller will assist in demonstrating throwing techniques on the potter's wheel. Projects will be provided, or, if you already have something in mind that you would like to make, we will make it happen. Everyone leaves the class with their own hand made pottery!
Contact Rob Buller via email: buller@chowan.edu to reserve your spot.
This is a non-credit class offered to the entire Chowan Community; you do not have to be registered as a student at CU.