Real victims seldom ask for anything. They rather just quietly suffer. They ask God for attention and help, but do not often presume to ask for yours.
When your attention or help are publicly begged, your presumption must be that the beggar is a liar.
Focus your attention and help on the poor sod lying unconscious by the side of the road, and you'll do just fine.
Virtue signalling – in sharp contrast to virtuous behavior – is free. You get what you pay for. A sacrifice that costs you little gains you little. So the virtue signalers have to keep at it. They cannot ever rest.
Do unto others as you would have them do unto you. So then likewise: as you do unto others, so would you have them do unto you.
Social Justice Warriors always project (hat tip: Vox Day). They insist that we foment violence and hatred, e.g., when it is of course they who mostly do so. They accuse us of being antiscientific, when of course they are the ones who reject the plain data and revolutionary discoveries of climatology and of genetics, which radically undermine their most precious most romantic notions of how humans really are and how life might be, if only it were not for our deplorable sort. They accuse us of being intolerant and close-minded, when of course they are the ones who are most intolerant and close-minded. They accuse us of irrational barbarity, when of course they are the ones who rage and foam inarticulately – who tear their clothes off in their madness (this is what the OT called "rending one's garments") – would be maenads, hapless, hopeless, who have no longer even the art of dismemberment, who know nothing of butchery, or even of sharpening, and a fortiori do not remember how to eat raw bloody male flesh.
There is no point here in rehearsing the myriad instances of such projections on their part. All of us on the Right are quite familiar with the phenomenon.
So here's the thing that struck me the other day. Our adversaries project upon us their own emotional and intellectual defects and inadequacies. They propose radical policies in response to those defects.
The question then is this: given that they diagnose us as suffering from the defects that in fact bedevil them, may we not infer that the way they propose to treat us is the way that they think – at some deep, unconscious level of their psychic economies – they themselves ought to be treated?
The Social Justice Warriors project their own Daddy issues onto politics, because that is safer than confronting Daddy. It is also safer than confronting their anger at Daddy. And it is easier and safer than doing the hard, scary psychotherapeutic work, and indeed spiritual work – the work of growing up, at last – that is needed if they are to understand their Daddy issues the way that adults understand things, and so lay them at last to rest.
We can tell it is Daddy issues that bedevil and urge the Left, because they tell us so: they blame all the defects of life upon old white Christian men, like their fathers, and hate such men.
I wonder if there was something about the men of the Greatest Generation that particularly inclined them to failure as fathers, and so fostered the rebellion and resentment of the Boomers – especially Boomer daughters. Was it WWII? How?
My earliest memories are of a time when the horrors of WWII were only 12 years past. Literally everything of my earliest childhood was colored by that war. Its memory loomed over every tiny mundane thing. Was it that Great War – really only a codicil to WWI, despite its much greater extent, so that the two were one gigantic catastrophe in the history of civilization – that queered the West?
I hope not. I so do.


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GO 800, 1000, 2000 series / Via series / Start 20 and 60 Series (MyDrive Connect)
Home › English › Navigation devices › GO 800, 1000, 2000 series / Via series / Start 20 and 60 Series (MyDrive Connect)
Voice search not available in Canada?
Alexo Posts: 30 [Outstanding Explorer]
December 2011 edited January 29 in GO 800, 1000, 2000 series / Via series / Start 20 and 60 Series (MyDrive Connect)
Got a TomTOm 2535TM WTE.
Logged in to MyTomTom and updated everything (including the NA map to 880). Using the "Samantha" voice for US English.
When I try to give the voice command "Navigate to an address", the device says: "Voice search in not available for this country, please enter the address manually".
JasonTT Posts: 64 [Prominent Wayfarer]
Voice search is working on my 1530tm. Is your software up to date?
dhn Posts: 33,151 Superusers
In another forum, the OP posted that he found the solution ....bizarre though it seems.
He switched to the Europe map and then back to the North America map and it started working.
ronbro Posts: 2 [Apprentice Traveler]
sorry the switghing maps did not work for me.
strange thin is when It was not updated every thing worked great.
It only happened once I updated the unit.
Try resetting the unit by holding the power button for about 10 seconds till you hear the drum sounds.
Sorry the hold the button for 10 sec till I hear the drums does not make the voice work. still says not available in your country.
I spoke with TT on the phone and he told me to return it to the store as there is nothing I can do to fix it......
What model do you have and is it still under warranty?
kentana Posts: 4 [Master Traveler]
Resetting by holding the switch for ten seconds worked for me, thank you. I have the TomTom 2535TM WTE with the Jan 1, 2012 maps.
vs Posts: 5 [Master Explorer]
I have the same problem with 2535TM. Switching maps and resetting doesn't help. On TomTom's support advice I replaced my device at the store where I bought it. The new one worked. But only until I updated the software. Immediately after that the same problem popped up.
So it's became evident that it's a software bug. After repetedly asking support I received this answer recently:
"We would like to inform you that this is a known issue and is a bug in our software. Our corporate team is working on it. The issue should be resolved for you pretty soon, however there is no estimated time we can provide. We will post more info as soon as it gets updated."
Jeff_J_Brown Posts: 1 [Apprentice Traveler]
I have the same issue.
You'd think after leaving us stranded after the whole "leap-year" bug that they'd give us a software update that actually works.
I've tried restarting this device, switching maps, changing settings, and nothing seems to be working. I've talked to a number of people who own this same device, and are fed up. This is not the type of support I thought I'd get from a GPS device that costs $300+.
rabidcat77 Posts: 1 [Apprentice Traveler]
I had the same problem with the "voice search not available in this country..." on a GO2435TM unit I just purchased. I live in the USA. I was able to fix the problem by changing a destination to one in Mexico, then back to one in the US. However, it would seem you MUST be using the latest map for this to work.
This fix was outlined by another member of this forum in this post here and I tried doing that when I was running the latest version fo the TomTom software, but an older map and the fix did NOT work.
I had tried using my latest map guarantee by entering in the promo code, but that did not work online, and it gave me a weird error about the application not working. I figured I couldn't possibly have the latest map as I saw it was listed as an 8.7 version from 2011, and there have been newer maps than that that I've seen others reference online.
So, in a nutshell here's what I did to fix it:
1) Called TomTom tech support to try and fix the voice issue. After waiting for about 15 minutes on hold, I spoke with a very helpful representative. He had me reset the unit to factory defaults, the usual steps one does when troubleshooting. I then went through the steps I originally did to recreate the problem, and the problem occurred again - he even heard the unit speak the error, which he was surprised by. He asked if I could return the unit to try and swap it out, but I told him about how I had bought it online and segued into my promo code issue. He thought it might be of help to try fixing that to get the latest map, so on to point 2.
2) My other issue was that the lifetime maps promo code wasn't able to be associated with the unit online. The rep manually associated the unit's serial number with my account, along with the promo code and had me plug the unit into my pc, where it then found that a new map was available. At this point he assigned me a case number that I could reference after I had done the map update if that didn't work and I had to call back in. I thanked him for his help and he wished me luck.
3) After downloading the map update I tried the voice search feature, and it again failed.
4) I then tried manually entering in an address in Mexico, and had it figure out a route to that end destination. I then cancelled that route, and selected a destination in the US.I cleared that route, then tried the voice feature.
5) It worked!
For reference, I'm currently running v11.037.920860.84 (release date of 4/5/2012) of the Tomtom software and my map version is 885.4102 from 1/2012
kijiji Posts: 6 [Master Explorer]
I am having this notorious problem on a VIA1535TM. "voice search is not available for this country"... It started doing it after the latest updated map. I have done numerous resets. I manually select Canada since that is where I am using it. Then for a few times it works. Then randomly it comes back to saying voice search not available. It is a pain when you rely on the tomtom to find a dozen addresses a day. I will be abandoning the tomtom if I cant get some support or a patch to fix the problem. Very disappointing. After searching the forums it appears that tomtom has not fixed this glitch which seems to come and go in the software......
Yeah, a drum reset is the only (temporary) solution I know. you can try a complete factory reset (though you'll lose your custom settings) and see if that is any better.
Also, support:
Monday - Friday: 8:00 a.m. to 8:00 p.m. EDT
Saturday: 9:00 a.m. to 6:00 p.m. EDT
open today.........
One other thing..........
Try driving to an address but complete all steps manually, not using the voice search. Once that is 'set', perhaps voice search is more effective.
thanks for your suggestions. I think the problem could be fixed if there was an option in setup to tell the gps the country you are in and use it as home. When it refuses to use voice command it shows a screen and the first choice is a list of states in the USA. The program must be stuck in a default mode of that home country. Maybe if I downloaded a Canada only map.

redpajama_set_name: RedPajamaCommonCrawl


Like so many of his contemporaries, Mantegna explored similar religious themes in their work. Portraits of the Madonna are one of the most common, with many artists creating multiple works of her and the baby Jesus. This is my first, but many more follow, and they're rapidly becoming a favourite subject of mine as well.


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Ohio State University Extension - May 13, 2013
Ticks, Lyme Disease Cases on the Rise
Warmer weather is finally here and with the rising temperatures comes the emergence of ticks that may carry dangerous diseases, and are now looking to feed.
"Ticks will be out looking for a blood meal," said Glen Needham, an entomologist and tick expert with Ohio State University Extension, the outreach arm of the university's College of Food, Agricultural, and Environmental Sciences. "We want people to understand there's a risk of getting sick from tick bites when they are outdoors, and that there are things they can do to keep themselves, their families and their pets safe."
Ticks are small arachnids that hang out along woodland edges, in woods, tall grass, weeds and underbrush. Like mosquitoes, ticks feed on the blood of birds, reptiles and mammals, including humans and pets. In doing so, ticks can transmit a variety of diseases, such as Rocky Mountain spotted fever and Lyme disease.
Deer ticks and Lyme disease
Needham said researchers and public health authorities are paying particular attention to Lyme disease, which was rare in Ohio in the past but has seen a significant increase statewide in recent years. Lyme disease is transmitted by the blacklegged deer tick, whose first established population was discovered in Coshocton County in 2010.
May has been declared Lyme Disease Awareness Month throughout the U.S. to increase knowledge about this ailment and how to prevent it. Blacklegged deer ticks are found primarily in wooded areas, so hikers, hunters and others who frequent those places should be particularly cautious.
"Blacklegged deer ticks have been found in 56 Ohio counties and are now likely established in 26 of those counties, mostly east of I-71 where we have deciduous forest," Needham said. "Most people who get Lyme disease will get it from the nymphal or juvenile stage of the blacklegged deer tick, which is very small, the size of a poppy seed, and is active in spring and summer.
"This makes it harder to identify and to know you may have been exposed to the disease."
Lyme disease causes flu-like symptoms such as fatigue, fever, headache, and muscle and joint aches. It also produces a distinctive large, circular red rash that looks like a bull's-eye. If caught early, the disease can be successfully treated with antibiotics. Though not known to be fatal, the disease can progress to chronic arthritis, neurological symptoms and cardiac problems if left untreated.
In 2010, 43 cases of Lyme disease were reported in Ohio, according to the Ohio Department of Health. That number grew to 50 in 2011 and 67 in 2012.
How to prevent Lyme disease
Needham recommends the following precautions to keep people and pets safe from Lyme disease and other tick-transmitted illnesses:
If possible, avoid going into wooded areas in counties where blacklegged deer ticks have been established.
When going into wooded areas, wear long pants and tuck them into socks, and tuck shirts into pants, to keep ticks on the outside of clothing where they are more easily visible.
Apply repellent containing permethrin to pants, socks and boots and allow them to dry; or use DEET-containing repellents with at least 25 percent active ingredient.
Use anti-tick products on pets; ask your veterinarian about Lyme disease vaccines for pets where blacklegged deer ticks are found.
Ticks have to feed for more than a day before they may transmit disease. If you are in a tick-infested area, check yourself, children and pets daily.
If you find a tick, grasp it as close to the skin as possible with a pair of tweezers, a commercially designed tick remover or protected thumb and finger; slowly pull the tick out. "Techniques such as using nail polish, rubbing alcohol, petroleum jelly or a hot object to 'back the tick out' don't work. Those are just myths and delay removal," Needham said.
Ticks on the rise
The blacklegged deer tick is not the only tick to be on the lookout for in Ohio. The American dog tick, the most commonly found tick in the state, is responsible for transmitting Rocky Mountain spotted fever. American dog ticks are much bigger and their main habitat is grassy areas along paths and roads.
Another common tick in Ohio is the Lone star tick, which can carry a disease known as Ehrlichiosis. The Lone star tick is found mostly in southern Ohio but it's beginning to move into central Ohio, aided by recent relatively mild winters and being dispersed by migratory birds, Needham said. It is typically found in wooded or shrubby areas.
"When I came to Ohio in the late 1970s, the only tick people had to worry about was the American dog tick," he said. "In the past few years, there has definitely been an increase both in the number of ticks out there and in the types of ticks becoming established in Ohio."
Larger tick populations and new types of ticks are not the only things that trouble Needham.
The Ohio Department of Health's Zoonotic Disease Program, which tracks the spread of mosquito- and tick-borne diseases, is slated to lose its funding as a result of state budget cuts that will go into effect July 1. Needham works closely with this program.
"Without this resource, we won't know where blacklegged deer ticks are in the state, which will make the work on prevention of Lyme disease much more challenging," he said.
View all posts by Ohio State University Extension
Healthy Living Lyme Disease Ohio State University Extension Our Ohio Ticks Tips & Trends


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Automatic voter registration goes to Rauner; he likes idea
(Erik Hersman/Flickr)
SPRINGFIELD, Ill. (AP) - Visitors to one of a handful of Illinois state agencies would be automatically registered to vote under legislation lawmakers sent to Gov. Bruce Rauner on Tuesday.
The House approved the idea 86-30 on the final day of the General Assembly's spring session, after days of tweaking to make it palatable to state officials who must carry it out. With the Republican governor's approval, the Prairie State would join just four other states that have or are planning automatic registration programs.
In Illinois, people who do business with one of five state agencies — the Department on Aging and the departments of Human Services, Healthcare and Family Services, Employment Security and the Secretary of State — would have information automatically filed with election authorities to allow them to enter voting booths.
Supporters predict expanding the franchise to 2 million people. Republicans fear a ploy to gin up Democrats to flood polling places. It would take effect in 2018.
"This is simply to make sure all citizens are registered to vote — and they can opt out," said the House sponsor, Rep. Robyn Gabel of Evanston.
At most agencies, visitors would be asked whether they want to register. They may refuse at that point. If they choose to register, they would be asked for documents sufficient to satisfy the State Board of Elections, which then would verify eligibility.
Because of the Secretary of State's existing machinery, those getting driver's licenses or other services at motor vehicle centers would have information automatically sent to the elections board. Later, those eligible would get a mailed form that would require a signature before voting.
Oregon automatically registers voters. California, West Virginia, and Vermont have approved similar plans. At least two dozen others are considering similar plans, according to the Brennan Center for Justice.
Critics complained it's too easy. Rep. David Harris, an Arlington Heights Republican, said a voter who doesn't get off the couch to register won't do the work necessary to be properly informed on Election day.
"It's important for the voter to have a little bit of initiative to do what they need to do and just be automatically signed up," Harris said.
Democratic Rep. Will Guzzardi of Chicago countered that voting is a "fundamental right" not subject to tests or taxes or other hurdles.
Elections board officials opposed earlier versions of the plan, fearing the board wouldn't receive sufficient information from agencies other than the Secretary of State and flinching at a one-year "lookback" which required the board to retroactively sift a year's worth of data from the agencies' constituents.
Rauner did not comment Tuesday on the plan. He told reporters two weeks ago he wanted to see the details, but added, "I am a big fan of simplifying the voter registration process and trying to get everyone who should be able to vote, to get them registered and vote."
The bill is SB250
Online: http://www.ilga.gov
Contact Political Writer John O'Connor at https://twitter.com/apoconnor . His work can be found at http://bigstory.ap.org/content/john-oconnor .
Chicago man dies after stolen Maserati slams into pole in Gary


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Home » Taxpayers Bear the Tax Consequences of Business Decisions
Taxpayers Bear the Tax Consequences of Business Decisions
By Lou Vlahos on August 21, 2017
Posted in Federal Tax Issues
Form v. Substance
It is a basic precept of the tax law that the substance of a transaction, rather than its form, should determine its tax consequences when the form of the transaction does not coincide with its economic reality. This substance-over-form argument is a powerful tool in the hands of a taxing authority.
According to another basic precept of the tax law, a taxpayer will generally be bound, for purposes of determining the tax consequences of a transaction, by the form of the transaction that he has used to achieve a particular business goal; the taxpayer may not freely re-characterize a transaction.
That being said, a taxpayer may assert a substance-over-form argument under certain circumstances. In those situations, however, the taxpayer faces a higher than usual burden of proof; indeed, the taxpayer must adduce "strong proof" to establish his entitlement to a position that is at variance with the form of the transaction reported on the taxpayer's return.
The case discussed below addressed the classic tax issue of form versus substance as the Third Circuit considered a taxpayer's attempt at re-characterizing a transaction.[1]
Taxpayer, a U.S. person, was the majority shareholder of a U.S. corporation ("Target") that owned and operated two Russian LLCs that, in turn, owned and operated most of Russia's Pizza Huts and KFCs. Another U.S. corporation ("Minority") held the remaining Target shares.
In order to sell the company, Taxpayer planned to buy out Minority's Target shares, and then transfer all the Target shares – including those just purchased – to the buyer, a European corporation ("Buyer") that owned KFCs, Pizza Huts, and other fast-food restaurants throughout Europe.
In May of the year in question, Taxpayer agreed to "purchase", for his "own account", Minority's stake in Target. At closing, Minority was to transfer its Target shares to Taxpayer and then, in the following month, Taxpayer would make a "deferred" payment of the purchase price to Minority.
"You better cut the pizza in four pieces because I'm not hungry enough to eat six." – Yogi Berra
Taxpayer also entered into a Merger Agreement with Target and Buyer. Under the terms of this Agreement: (1) Taxpayer would ensure, at the closing, that he was the "record" owner of 100% of the Target stock, "free and clear of any restrictions"; (2) Taxpayer would transfer 100% of Target's shares to Buyer; and (3) Buyer would transfer cash and Buyer stock to Taxpayer as consideration. The transaction was intended to qualify as a partially "tax-free" reorganization within the meaning of the Code.[2] [IRC Sec. 368, 367]
The two transactions went through as planned. In June of the year in question, Minority transferred its Target stock to Taxpayer. On July 2, the Target-Buyer merger closed, and Taxpayer transferred all the Target stock to Buyer. On July 3, Buyer paid Taxpayer over $23 million in cash and transferred over $30 million worth of Buyer stock, a total of nearly $54 million for all Target's shares. Then on July 5, Taxpayer paid Minority $14 million for its stake in Target.
In two tax filings for the year in question, Taxpayer took two different approaches to the transaction. In his original return, Taxpayer reported tax liability of almost $3.8 million, and paid that amount to the IRS. Taxpayer subsequently amended his return, reported a lower tax liability, and requested a refund.
"Finger Lickin' Good" – Not for the Taxpayer
The IRS audited Taxpayer, found that the originally-filed return was correct, and denied Taxpayer's request for a refund. Taxpayer then petitioned the U.S. Tax Court for a redetermination. The Tax Court held for the IRS, and Taxpayer then appealed to the Third Circuit Court of Appeals.
Taxpayer Never Owned It?
Taxpayer challenged the IRS's determination that he had to pay tax on the $14 million that he received from Buyer and immediately remitted to Minority. The question was whether the form of the transaction made Taxpayer liable for the gain on the Target stock that had been held by Minority.
The Court began by describing the so-called "Danielson rule":
[W]hile a taxpayer is free to organize his affairs as he chooses, . . . once having done so, he must accept the tax consequences of his choice, whether contemplated or not, and may not enjoy the benefit of some other route he might have chosen to follow but did not.
A taxpayer who falls within the scope of this rule, the Court stated, is generally stuck with the form of his business transaction, and can make an argument that substance should prevail over that form only if a limited class of exceptions applies.
Taxpayer argued that he was never the substantive owner of the Minority block of stock and, therefore, should not be taxed on the $14 million portion of Buyer's payment that Taxpayer passed to Minority.
However, according to the Court, none of the Danielson exceptions applied – Taxpayer was not defrauded into the transaction, for example – and the contracts signed by the parties explicitly stated that Taxpayer acquired ownership of Minority's stock: he purchase it for his "own account" prior to selling it to Buyer; and even though the shares were in his hands for only a brief period of time, he was the "record" owner, "free and clear of any restrictions."
Thus, under Danielson, Taxpayer had to bear the tax liability for owning all the Target shares. He could have hypothetically structured the deal so that he never acquired formal ownership of Minority's shares, but he did not, and could not benefit from an alternative route now.
"Danielson" Policy Wasn't Implicated?
Taxpayer argued that the Danielson rule should not apply because its policies were not implicated. According to Taxpayer, the purpose of the Danielson rule was "to prevent a taxpayer from having her cake and eating it too." Taxpayer claimed that he realized no benefit from serving as Minority's and Buyer's go-between.
The Court countered that Taxpayer likely did benefit: by structuring the transaction so that he purchased Minority's stock for his own account prior to the sale to Buyer, Taxpayer made the overall transaction simpler by ensuring that Buyer would deal with only one party, which likely reduced the deal's transaction costs and litigation risk, increased the likelihood of the deal actually closing, and perhaps caused Buyer to pay a higher price than it otherwise may have.
In any case, the Court stated, the point of a bright-line rule like Danielson's requires that judges enforce it without wading into policy analysis, ensuring that the rule's application will be easy and predictable.
Agency?
Taxpayer claimed that he was nothing more than Minority's agent in selling Minority's block of stock, and agents are not liable for the tax burden of their principals.
In responding to this claim, the Court explained that an agency relationship is created through "manifestation by the principal to the agent that the agent may act on his account" and the agent's "consent" to the undertaking. The problem with this argument, the Court noted, is that the written agreement between Minority and Taxpayer stated in straightforward terms that Taxpayer purchased Minority's shares for his own account; it did not mention an agency relationship, and none of the terms suggested that Taxpayer ever had an obligation to sell his newly-acquired shares to Buyer or anyone else; Taxpayer could have kept the stock for as long as he wanted, as long as he paid Minority its $14 million. That Taxpayer did encumber himself with an obligation to sell the Minority shares to Buyer arose out of the separate Merger Agreement to which Minority was not a party.
"The food in Europe is pretty disappointing. I like fried chicken. But other than that Europe is great." – Donnie Wahlberg
"Make it Great" – Not for the Taxpayer
The Court concluded that Taxpayer owned 100% of Target's stock when he transferred Target to Buyer for a total consideration of $54 million, comprised of Buyer stock and cash, and he had to bear the tax burden for the entire payment, even the portion associated with the $14 million he remitted to Minority.
Taxpayer argued that if he must be taxed on the full $54 million from Buyer, he should be permitted to subtract from the gain on his original shares the amount that he "lost" on the sale of the Minority shares.
The Code provides that no gain or loss shall be recognized by a shareholder of a corporation if the shareholder's stock in the corporation is exchanged, pursuant to a "plan of reorganization," solely for stock in another corporation that is a party to the reorganization. [IRC Sec. 354]
Thus, a target corporation shareholder who receives only shares of stock in the buyer corporation in exchange for his shares of the target corporation stock, as part of a stock-for-stock merger transaction, does not recognize any of the gain or loss realized in the exchange.
This general rule has an exception for instances when a corporate reorganization involves a transfer of target stock in exchange for both stock of the acquiring corporation and other property or money ("boot"). In those transactions, gain must be recognized by the target shareholder to the extent of the boot received, but any losses realized by the target shareholder still fall within the scope of the general rule – they may not be recognized notwithstanding the receipt of boot by the target's shareholder. [IRC Sec. 356]
Blocks of Target Stock
The Court explained that, in order to give content to the above recognition / nonrecognition rules, the IRS and the courts historically have analyzed multifaceted transactions according to their "separate units" of stock, so as to prevent a taxpayer from making an end-run around the non-recognition-of-loss rule by tucking his unit's statutorily unrecognizable loss under the transaction's broader recognizable gain; thus when an exchange transaction pursuant to a reorganization involves "separate units" of stock, each unit must be analyzed separately.
Taxpayer asked the Court to treat the two blocks of target stock – his block and Minority's – as one unit, sold in one exchange. By doing so, Taxpayer hoped to subtract the loss realized on the Minority shares from the gain on his original shares (as he could have done if the transaction had not been structured as a partially tax-free reorganization). The Court rejected this request, finding that Taxpayer's Target stock holdings were composed of two units: Taxpayer acquired one block of Target stock years before acquiring the second block, and he had a vastly different cost basis in the two blocks. Given that the blocks were separate, the Code's reorganization provisions prohibited recognition of any loss realized by taxpayer in the Minority block.
Plop, Plop, Fizz, Fizz
Fried chicken and pizza aren't the only things that can give a taxpayer heartburn. Unexpected tax liabilities are just as, if not more, likely to do so. Moreover, tax liabilities cannot be relieved by a simple antacid.
This part of almost every post on this blog must sound like the proverbial broken record. I apologize, but it cannot be said often enough. Before a taxpayer enters into a transaction, he has to be as certain as reasonably possible under the circumstances – risk can never be eliminated – that the transaction will accomplish the taxpayer's desired business goal. Assuming that is the case, the taxpayer next has to analyze and quantify the tax cost associated with the transaction. This cost has to be added to the other deal costs, and weighed against the expected economic benefits. Depending upon the results of this analysis, the taxpayer may want to reconsider some of the proposed deal terms.
"Eschew obfuscation," one of my high school physics teachers used to say. I have my own ironic saying: "avoid surprises." Business owners should consult their tax advisers well before executing a letter of intent for a transaction – the foregoing analysis should not to be deferred until late in the game, because doing so could prove to be an expensive mistake.
[1] I have to confess that when I came across this decision, I had already started writing a post on why some LLCs make S-corporation elections. For those of you who know me, as soon as I saw the references to Pizza Hut and KFC, I completely forgot about the LLC.
[2] As we shall see, this reorganization treatment was at the crux of the Taxpayer's position (see infra).
Tags: boot, Danielson rule, Form over substance, fried chicken, Gain recognition, pizza, substance over form, Tax-free reorganization
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There is a lot of uncertainty these days, especially for international students who are planning to come to the United States. It is very easy for them to see news reports and think that Americans are suddenly not welcoming to international students and non-Americans in general.
This is simply not true. As an Intensive English Program, we welcome people from all countries, no matter who you are, what you believe, or what language you speak. If you want to come study in the US, whether for English or any other subject, you are welcome at Upper Iowa University.


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Liberty Equality Solidarity! – SUWN goes to Aberdeen
August 18, 2019 suwn
The Indy marches and rallies achieve three things. They rally campaigners with a shared, uplifting, and enjoyable day out; they ensure the Indy cause remains firmly and visibly on the map; and they provide an opportunity for the grassroots Indy movement to make clear that Indy must be more than a change of flag. Yesterday's speakers all talked about the opportunity to create a better, fairer Scotland – including a powerful anti-establishment speech from Veterans for Scottish Independence. There were speakers from CND, Extinction Rebellion, and Catalonia. Sarah gave a message of international solidarity, and Duncan gave his first public speech for the SUWN, which you can watch below (introduced by Tony who was compering the rally).
We took through a minibus of marchers aged under 6 to over 60, and we handed out 500 leaflets with our message for radical change and solidarity. For those who didn't get one, this is what they said:
The SUWN has supported independence since before the 2014 referendum. We have always argued for the need to look after our own affairs through a totally independent Scottish parliament; but this is only part of the story. We also have to make sure that our independent Scotland is run by and for ALL its people, and isn't just a smaller echo of the elite politics that we are escaping from. We don't want Edinburgh aspiring to compete with the City of London, while a whole section of the population is priced out of a decent life. We don't want an economy that sacrifices the common good and the future of our planet for the sake of private profit.
We know that most people who support independence do want to see an independent Scotland that creates a fairer society, and we call on everyone to make this demand central to the independence campaign. It is no use claiming that we can think about what sort of Scotland we want later. History is full of examples of movements that have put aside demands for wider social change till after independence, only to find themselves dismissed and side-lined once independence was won.
We don't just want a change of flag. We want to make a better society – where there is no need for an unemployed workers' network.
We are also very aware that winning a majority for independence will only be part of the independence process. There are a lot of powerful institutions that don't want this to succeed – we were only 'allowed' a referendum last time because they were sure we wouldn't vote yes. We hope the Scottish solution is constitutional and peaceful, but we have seen how painful independence struggles can be.
As supporters of independence and the right to self determination we want to express our solidarity with others who have campaigned for the right to run their own lives and enjoy their own culture, only to be met with brutal suppression by bigger nations who deny them their separate identity and exploit their resources.
Palestinian flags have long been welcome on Indy marches. This last fortnight, the world became more aware of the situation of the people of Kashmir, as India formalised decades of violent repression by unilaterally ending Kashmir's constitutional autonomy, arresting politicians and human rights activists, and cutting off all forms of communication. In the SUWN we have been active in supporting the Kurds, who have combined their struggle to express their cultural identity, with the struggle for a better form of society.
In Northern Syria, the Kurds used the political vacuum created by the civil war to establish an autonomous region based on a bottom-up democracy, which emphasises women's rights and a multicultural society. Its grassroots politics and community values provide a model for everyone looking for an alternative to our greed-based system. Almost as soon as they had begun to get this established, they were attacked by ISIS. Now that they have successfully fought back, and liberated large areas of Syria at the expense of thousands of young lives, they are being threatened by the full force of the Turkish army, the second biggest army in NATO. Their fate depends on the political machinations of Turkey, the US, Russia and Iran – all of them in Syria for their own selfish interests.
By making more people aware of the Kurds' position we can try and make it a little bit harder for these new imperialists to wipe the Kurds from the map.
You can check out what is happening on anfenglishmobile.com
Use www.writetothem.com to ask your MP to raise the issue of the Turkish threat in parliament, and to demand the Kurds be given a say in their own future.
And find out what is happening in Scotland on
www.sskonline.org.uk and www.facebook.com/ScottishSolidaritywithKurdistan
← It's a Dug's life
A wasted opportunity – with big knock-on costs →


The Advisors at Compass Point Retirement Planning believe an important key to investing is helping our clients clearly understand the risk level of their portfolio. Knowing your risk tolerance is a great "speedometer" for investing. Just like the gauge in your car, the speedometer helps you stay in the range of speed that is best for where you are in your journey.
you invest in areas to work toward your retirement savings and income goals.
SCHEDULE A RISK TOLERANCE — You do not want to make the mistake of going too fast where you shouldn't with your investments, but you also don't want to be too conservative when the market is growing. Take a few minutes and contact our office to see if your risk tolerance and investments are in sync!


Cyberschool supports a higher level of learning with modern technology!
Pre-Uni New College Final Intensive Trial Test (FITT) will be the last programme for its Year 6 students who will sit this year's selective high school placement test on 15th March. By sitting the FITT, students will be able to systematically revise the entire course work under strict exam conditions and confidently prepare for the exam. Students will also learn various exam techniques including time management during their test reviews.
Due to the limited capacity of the testing centre, late booking after 3rd March will not be accepted. Please book early.
There will be NO Year 6 class on the Final Intensive Trial Test day - 10th March 2018.
COPYRIGHT © 2019 CYBERSCHOOL ALL RIGHT RESERVED.


You have a dream. You might or might now know what it is, but there is something that you deep down want to do.
This cube deals with starting out on a path to achieve your dream, or getting things done (GTD). No matter if it is skysurfing, building a company, making a podcast or other art.
It takes the short Ted Talk by Matt Cutts (you can view below) and part of the book Linchpin by Seth Godin. Seth presents a plan, Matt does too, but you might see then after the same general steps, or you might not. That's for you to decide.
Does Matt Cutts follow the steps that Seth Godin spelled out? Do you?
How do you find a balance between starting & finishing (the two sides people have the most issue with)?
This cube features the book Linchpin by Seth Godin.
What does it take for a group of people to succeed at a task or causing change in the world? There is a choice of direction, two paths that have worked at causing major change. Now in this Cube Seth looks at an option that has been less popular in the last 100 years.
How is your group different from the competition?
What happens when the wind shifts on your organization?


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Engaging Baby Boomers – Pioneers in the Green Movement
By Julie Honeywell
Baby Boomers came of age at a time when the relationships between the environment and human activity were reconsidered in powerful ways. They are the first green generation — the pioneers.
They awakened us to the importance of preserving the environment. Born between 1946 and 1964 and 76.4 million strong, Boomers planted the seeds of the modern day green movement as the idealistic "flower children" of the 1960s.
Fifty years later, as they prepare to exit the workforce, they are anxious and willing to leave a lasting legacy if only their companies will tap into their experience, sense of social conscientiousness and love of the environment. They can be powerful levers of change and assume roles of leadership in their organization's sustainability initiatives.
Look at what Boomers have already achieved. They helped to organize and then gathered to celebrate the first Earth Day, in 1970, followed by the first Solar Day in 1971.
Their peaceful demonstrations of concern gave rise to the National Environmental Policy Act of 1969, the founding of the US Environmental Protection Agency in 1970, the Clean Air act in 1970 and the Clean Water Act in 1972, and the Endangered Species Act of 1973.
Their environmental issues were visible and tangible, with air and water pollution, and they instituted rapid progress towards environmental goals with measurable results.
So who are these Boomers who have grown up in an era of increasing climate change?
Profile of a Boomer
The first Boomers, born right after World War II, grew up with a picture perfect family: mom, dad, a few brothers and sisters, a dog and grandparents who lived in the 'country.' Thanks to a G.I. Bill that subsidized low-cost mortgages for returning soldiers, it was often cheaper to buy a house in the suburbs than to rent an apartment in the city.
These houses had informal family rooms, open floor plans and backyards in subdivisions that had quirky little names like The Rabbit Hutch or Lyon Estates.
Boomers were full of confidence that their lives could be better than their parents. They believed they had a right to a college education and believed in American ideals.
Consumer goods companies helped this along by catering to the biggest generation the country had seen – developing ready-to-go baby food (Gerber), inventing a variety of toys and creating TV shows like the Little Rascals and the Lone Ranger.
Boomers were raised with the idea if you worked hard you got what you wanted. They worked their way up the ladder at their companies, believing the harder you worked the more you were rewarded. Boomers were our first workaholics.
They Expected a Better World
As a group, they were the wealthiest, most active, and most physically fit generation up to that time, and among the first to grow up genuinely expecting the world to improve with time.
This generation was the first to engage in peaceful civic disobedience to rally for peace, equal rights, civil rights, women rights and environmental concerns.
The deaths of President Kennedy, Bobby Kennedy and Dr. Martin Luther King; the Vietnam War; and Watergate defined their political coming of age. The Summer of Love and Woodstock defined their social coming of age.
Many Boomers, due to the recent economic crisis, are delaying retirement. Some claim they will never retire, as they believe work defines who they are.
Boomers believe in large causes and are convinced they can change the world. They are open to new ideas.Sustainability leaders need to leverage these experienced Boomers before they exit the workforce.
They are skilled in organizing large groups of people around a mission, and then creating a strategic plan to make it happen. They aren't afraid of hard work and are tireless in pursuit of their goals. They are unique in their ability to balance profit and prosperity motive with a social one.
Many have achieved senior positions in their organizations, so they have the clout to make change happen.
Engaging Boomers
Boomers are born leaders, idealistic and love to win – mainly because everything they tried to achieve, they did!
You can engage Boomers by appealing to their need to leave a legacy for future generations. Sustainability initiatives and programs align to their social values.
Many are looking for 'encore' career opportunities, but want to do something great for a second curtain call. Leadership roles within sustainability initiatives may be a perfect fit.
They know how 'things work around here' and get done. They can accelerate your progress in sustainability while building new leaders.
Engage them in rallying multiple stakeholders to achieve large organizational goals. Use their idealism to drive change. Their enthusiasm and energy will help to rally others around sustainability to achieve measurable results that benefit your company and the planet.
Julie Honeywell is Vice President of Talent Management at Paladino and Company.
Category: Change Management | Employee Engagement | Green Buildings | Leadership
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See the calendar for already available dates and times. Can be also organized for other dates upon request.
Please email us at safaris@extremehuskies.com for more information.
The guide will lead you through the kennel to meet the eager and lovable sled dogs. While you meet and take pictures with the Huskies, the guide will explain about the breed and the life with the dogs. You will then be seated on a wagon and the dogs lead you into a forest. The guide will make sure to stop in the midpoint for you to take some pictures in the forest with the dogs. After the wagon ride, the guide will lead you into a Lappish style hut where hot drinks are served, and the guide will answer your questions! Before leaving, you get to give the dogs the last hugs and take pictures with them.
Scroll down for a Wagon Ride video!
Read the detailed safari description and book your safari by clicking the "Book Now" -button.
Only groups of 4 or more!
Get to know the musher lifestyle and meet the amazing sled dogs!
The guide will lead you through the kennel to meet the eager and lovable sled dogs. While you meet and take pictures with the Huskies, the guide will explain about the breed and the life with the dogs. You will get to see the equipment used for training and the sleds used during the winter. The guide will then lead you into a Lappish style hut where hot drinks are served, and the guide will answer your questions! Before leaving, you get to give dogs the last hugs and take pictures with them.
The guide will lead you through the kennel to meet the eager and lovable sled dogs. While you meet and take pictures with the Huskies, the guide will explain about the breed and the life with the dogs. You will get to see the equipment used for training, after which you will help with harnessing the dogs in front of an ATV. Before the take-off, you will get to witness the dog's extreme enthusiasm to run as the dog's howl and jump with excitement. The highlight of the tour is to see the dog's sprint forward and get to do what they were born to do. The guide will then lead you into a Lappish style hut and serves you hot drinks and Finnish style pie made out of local berries. While enjoying the drinks and the pie, the guide will answer your questions about mushing and the dogs. Soon after, the dogs return back to the kennel, are unharnessed and get to run free for a while. Before leaving, you get to give the dogs last hugs and take pictures with them.
Husky wagon rides available in late autumn!


text:
Verizon Launches LTE-Only Flip Phone
By Adnan Farooqui, on 06/18/2017 04:24 PDT
Verizon is now offering a new device for its customers that's going to be a good option for those who require a mobile phone but have no use for a smartphone phone. It's called the LG Exalt LTE and it's an LTE-only flip phone. That's right, the handset only connects to Verizon's 4G LTE network which means that there's no 3G network option for phone calls.
The LG Exalt LTE is a pretty basic phone in that it has a 3 inch LCD display with a 400×240 pixel resolution. The handset has a 5 megapixel rear camera, no front camera, 8GB of onboard storage, and a 1,470mAh battery. It also has support for Wi-Fi calling.
The battery promises 10 days of standby time as well as up to 6 hours of usage time. The design itself is a combination of practicality and looks. It has big, tactile buttons which make it easy to use and dial.
The LG Exalt LTE has an integrated text-to-speech function which can read out text messages. The feature comes in handy when the user has to keep their hands free or when it's difficult for them to see the display.
Verizon's first 4G LTE basic handset can be purchased $168 at full retail price or for $0 down and $7 per month for 24 months. Customers will also have to pay a one-time activation fee of $30.
Filed in Cellphones. Read more about 4g Lte and Verizon. Source: verizonwireless
Audi's 2024 Cars Will Come With 5G Connectivity
Verizon's Unlimited Customers Will Have Permanent Access To Apple Arcade And Google Play Pass
Motorola And Verizon Create A Neckband To Make VR Headsets Easier To Wear
TCL 30 V 5G and TCL 30 XE 5G Budget Phones Released at CES
Verizon And Bang & Olufsen Debut Soundbar With Android TV
Verizon Is Giving Away An iPhone 12 Mini If You Get A New Unlimited Line


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Mike Keiller joins The Last Drop Distillers
Mike Keiller is to join the board of directors at The Last Drop Distillers. Starting his role this month, Mike will oversee the financial and corporate strategy of the growing spirits business, including all financial planning.
Mike brings with him a wealth of industry experience, joining The Last Drop Distillers from Morrison Bowmore Distillers, where he spent 14 years as CEO, managing its development from a bulk whisky supply and services operation to a leading single malt producer with brands including Auchentoshan, Bowmore, Glen Garioch and McClelland's. Prior to this, Mike held the role of director of Financial Planning and Control at BT UK, following a 14-year stint at Guinness (now part of Diageo).
Mike's appointment demonstrates The Last Drop's ambition to continue and accelerate its expansion as a global luxury spirits brand. The company was founded in 2008 by three spirits industry pioneers, who had between them previously created some of the world's best-known spirits, including Johnnie Walker Blue Label, Chivas Regal 18 Year Old, Malibu and Baileys Irish Cream. Over seven years they have created an exclusive and limited edition collection of the rarest and oldest spirits in the world. The Last Drop Distillers seeks out and bottles rare casks of exceptional spirits to ensure they can be enjoyed 'before there is no more'.
James Espey, founder and chairman at The Last Drop, says: "Like all of The Last Drop Distillers team, Mike has a fantastic breadth of drinks industry experience, showing what he's capable of during 14 successful years as CEO of Morrison Bowmore Distillers. His record of delivering strong business and financial results makes us confident that his knowledge and vision will play an integral role in driving the company forward as we look to expand through 2016 and beyond."
Mike Keiller, board director at The Last Drop Distillers, adds: "The Last Drop is finding and creating an exceptional collection of spirits, whilst also proving itself as a strong business model that's entrenched in exclusivity, craft and excellence. I'm relishing the opportunity to lead on the company's corporate strategy and development at this stage of its growth and am thoroughly looking forward to being part of its passionate and tight-knit team of true spirits pioneers."
2 February 2016 - Rebecca Sterritt Paragraph Publishing, content manager
Absinthe Aperitif Armagnac Baijiu Brandy - Other Brown Cachaca Calvados Cognac Digestif Drinks Producer Eau de Vie Europe Gin Grappa Independent Bottlers Liqueur Mescal People People Pisco Production Services Rice Spirit Rum Shochu Spirits Tequila United Kingdom Vodka Whiskey - American Whiskey - Irish Whisky - Canadian Whisky - Japanese Whisky - Other Whisky - Scotch Worldwide
Dan Jago appointed chairman of WSTA
Trends and solutions at Packaging Innovations
Javier Ferrán joins the board at Diageo
CEO of Ferrari Winery becomes IWSC president
Kevin Baker joins Marie Brizard


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Campus tour guides share Cornell's story
Rubi Araiza Camba can often be found pointing out little known facts about Cornell College to visiting students and families as a campus tour guide.
The senior has been giving tours since her first year on campus.
"I have loved being a tour guide because I've gotten to learn so many facts about the school–sometimes things that not even current students know," Araiza Camba said. "I also enjoy meeting families from all over the place and being able to show them so many aspects of Cornell that make it such a great school."
2019-20 Tour Guides
The engineering major from Basalt, Colorado, is one of 30 campus tour guides. First-year students through seniors are welcome to apply for the job.
"I believe that being a tour guide is one of the most important and valuable work-study positions on campus," said Senior Admissions Representative Phil Welsh, who manages the program. "Serving in this role fosters growth in their problem-solving, time management, and communication skills. Our supervisors make sure our tour guides receive extensive education in all things Cornell, and we arrange meetings every block with different departments on campus to always stay informed on the latest changes."
While there's always something new to talk about, many families want to know more about something that's been around for 40 years, the block plan. Araiza Camba says many families and students ask about how she handles the workload during the hour-long tours.
"While other students on the semester plan are focusing on four to six different courses, we are only focused on one," she tells families. "We have so many resources that help us succeed if we ever feel like we are struggling. Cornell students are known to be super involved. So even being in hard classes, they can still join in on sports and various clubs and organizations."
Connor Duffus, a politics and history major from Grinnell, Iowa, is also a tour guide. He tailors his tours to the student's interests and always enjoys showing off the Thomas Commons–the hub for many activities on campus.
"I think it provides the best opportunity for prospective students and their families to really see what Cornell is all about–getting involved in clubs and organizations, using resources like the Berry Career Institute, and relaxing on the Orange Carpet during Pet Therapy Day. There's so much in the Commons that represents us," Duffus said.
Araiza Camba enjoys showing families smaller classrooms that demonstrate the close relationships students form with their professors. It's not unusual for her to come across a professor she's had in class during a campus tour.
"They will sometimes stop to talk to the prospective student and tell them about the class they teach or about Cornell in general," she said. "This just shows how personalized our campus is and how professors focus on each individual in and outside the classroom."
The Cornell visit team works around the clock to match prospective students with tour guides who share similar hometowns, interest, or majors. Welsh enjoys seeing the student tour guide learn about Cornell, meet new people, and grow professionally, as they take on this job.
"I have seen so many of our tour guides become confident in their ability to work with people of all backgrounds, handle unexpected events, think on their feet, speak on student panels in front of more than 100 people, and answer difficult questions," Welsh said. "There is no shortage of valuable skills one can gain from this experience, and the best tour guides take pride in continuing to find ways to challenge themselves."
So, while these students enjoy pointing out all the little known facts about campus, it's a pretty well-known fact that the tour guides really help make the Hilltop a great place to visit.
If students are interested in applying to become a campus tour guide, they can contact Welsh at pwelsh@cornellcollege.edu. The position pays $10 an hour and schedules are based on student availability. Hiring typically takes place during Block 4, but students can apply year-round.


text:
Il existe deux types de Source de plasma:
 Sources naturelles:
Les sources naturelles de plasmas sont nombreuses : ionosphère, magnétosphère terrestre, plasma de la couronne solaire, foudre, ...

 Sources artificielles:
 source produite par laser
 source micro-onde
 source par décharge

Voir aussi
 Physique des plasmas

Plasma

redpajama_set_name: RedPajamaWikipedia