text:
Transportation Crisis Hits Cuba
Fernando Ravsberg
Yamile Gonzalez, who works in a hospital nine miles from her home, said that because of poor public transportation it takes her two hours to get to work. Photo: Raquel Perez
HAVANA TIMES, April 5 — "The guaguas (buses) are really bad. You can spend two hours waiting at a bus stop for a ride that only takes fifteen minutes," explained medical student Roberto Diaz, while Jorge Avila added, "Plus, by the time they get to you, they're already packed."
Yamile Gonzalez works as an administrator at a hospital located nine miles from her house. Nevertheless, she needs to leave home by 6 a.m. to get there by 8:00 a.m. "We go through a lot of trouble getting to work. The buses never show up or when they do, they're full," she complained.
"People are going through this because there aren't enough vehicles on the road. More than half of the buses are out of service due to a lack of spare parts to repair them," said Luis H. Blanco, a public transportation inspector.
To learn the reasons that have produced the latest national crisis in this area, we interviewed the deputy minister of Transportation, Eduardo Rodriguez, who admits that about "30 percent of our buses are out of service for various reasons."
Chinese buses with American hearts
Deputy Minister Rodriguez said the Ministry of Transportation is being reorganized for greater efficiency. Photo: Raquel Perez
Deputy Minister Rodriguez explained, "We're facing serious financial difficulties and over the last three years these have played a significant role, because when you don't have the money, it's much more complicated to make a decision about purchasing."
Nevertheless other difficulties were created because of the Ministry of Transportation (Mitrans) having bought Chinese and Russian buses with American engines, depite the US trade embargo making it difficult and expensive to get spare parts for those vehicles.
Unofficial sources say the Cuban government had obtained assurances concerning subsequent sales of parts and components, but later the suppliers didn't comply. The deputy minister acknowledges that "the US blockade isn't some myth" and says that in the future "it's something that must be kept in mind."
Public transportation isn't the only place where US vehicles are paralyzed due to the lack of spare parts. This occurs in various industries and even in the public health care system, though no one can explain why they keep buying equipment from that country.
The slow pace of bureaucracy
The other factor in the crisis is that the Cuban import company working with Mitrans takes months to decide on buying the parts that the ministry requests, time during which the buses sit idle and passengers agonizing at the bus stops.
Thirty percent of the buses in the capital are paralyzed and rusting away in depots for lack of spare parts. Photo: Raquel Perez
Rodriguez assured us that "all of this is undergoing reform right now to create a purchasing company with a different management, one that's more oriented to satisfying our customers."
Up until now, the process is as follows: When a vehicle breaks down, a request is issued for the needed parts. A study of purchasing options is then conducted over several months until the OK is given to buy the part from one of these. However, the ministry still has to wait for the procurement process to be completed and the parts to actually be delivered – an overall process that can take up to a year.
In the meantime, while they carry out their reorganization, people continue to suffer at bus stops and vehicles continue to circulate overloaded. At the same time, it becomes more difficult to put the mothballed buses back into service "because the off-lined vehicles continue to deteriorate," explained the deputy minister.
The costs and organization of transportation
Eduardo Rodriguez noted that there's a financial component that cannot be ignored. "In the transportation of passengers, the subsidy levels are very large, because the population receives a service that is almost totally subsidized."
He adds that "the per-person cost of a one kilometer route of urban public transportation costs almost the same anywhere in the world, nearly $1 (USD)." However the fare for a Cuban citizen is less than a sixtieth of that – about 1.6¢ (USD).
The stops are once again full of people anxiously waiting for buses that either never show up or are packed with people when they do. Photo: Raquel Perez
In any case, even beyond the financial concerns, there remain unanswered questions such as why in Havana there are less than 1,000 public buses and over 3,000 in the hands of state-run companies.
The deputy minister told us that most of the company-owned vehicles are so old that they wouldn't stand up to more than a couple of trips daily. Nevertheless, the fact is that many of these buses pass through the city empty, and on weekends they make unofficial trips to tourist sites fairly distant from the capital.
Nor is it clear why Mitrans does not organize the thousands of private (truck and collective taxi) carriers of passengers by routes to establish a network that benefits the users, covering the whole city and not only those points that are the most profitable.
Rodriguez assured us that "we're working on many new things," yet he declined to disclose anything because "people don't deserve to hear announcements that for one reason or another don't materialize later."
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4 thoughts on "Transportation Crisis Hits Cuba"
Grady Ross Daugherty
The Cuban state might look at the Bologna, Italy experiences of contracting with worker-owned cooperatives for some public services, and then perhaps help similar coops develop metropolitan bus lines.
The state could help capitalize the lines and retain partial, silent ownership shares, and receive dividends quarterly when the bus line coop owners distribute dividends to themselves.
Oh, wait . . . I forgot . . . According to the Marxian dogma, if the workers own the means of production directly, not under the leadership of a wise bureaucracy, this is capitalism.
New York City transit "pretty good"? Obviously you have not ridden the AA train downtown from the Upper West Side at rush hour.
Paul Maurer
What logic!
Public transportation is pretty bad in Havana, no matter what your 'compensation' is for using it;
public transportation in New York City is pretty good, no matter what your 'compensation is for using it
(and my name isn't Blooberg).
Have you been on the a New York subway lately? The Metro in D.C.? Or the "L" in Chicago? Havana's public transit problems are no worse than most other major urban citites in the world. The difference is that in these other cities there are compensating balances to offset the misery associated with bad public transit. In New York, you can justify a crowded subway ride to work because you are earning the highest salary in the world for similar work. In D.C. late trains are frustrating, but you always have to choice to look for another job closer to home. Chicago trains and buses are no picnic either but you accept the hassle because it truly is the fastest way to get around when you consider traffic delays due to winter weather. Life in Cuba has always had its plusses and minuses. More and more each day, the pluses like the health care, education and public transit systems are losing ground to the littany of minuses.


text:
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redpajama_set_name: RedPajamaWikipedia


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oklahoma red dirt artists
Red dirt music stems from Texas and Oklahoma, originating in the Stillwater, OK sound exemplified by bands like Cross Canadian Ragweed and Jason Boland.Part of the wider alt-country genre, the term "red dirt" encompasses a wide variety of bands and styles, from southern rock-influenced bands like Reckless Kelly to the honky-tonk of Cooder Graw to Nashville successes like the Eli Young Band. a collection of murals around our Great State of Oklahoma ... Palmer Studios has done over 3500 murals and the book narrows the list down to a little over 500 works of art. Information about the gallery. *Total Monthly Listener count taken on 11/15/2017 . Don performs his own music and also plays bass with Red Dirt artists such as the Red Dirt Rangers, Tom Skinner, Brandon Jenkins, and The Farm Couple. Here are the Top 16 most Streamed Texas and Red Dirt Artists on Spotify In order to qualify, at least 30% of their currently listed shows had to be in Texas or Oklahoma ***It has come to our attention that some artists for some reason have two Spotify accounts. For nearly two decades, the Red Dirt Rangers have criss-crossed the nation (and Europe) bringing their unique sound to the people. Flatland Cavalry Bob Childers's influence on Oklahoma music and musicians cannot be overestimated. The band helped create what is now called "Red Dirt Music", that elusive blend of country, rock and roll, blues and bluegrass along with a big helping of Oklahoma soul. Here are the Top 40 Most Streamed Texas and Red Dirt Artists on Spotify 20-1 In order to qualify, the majority of their currently listed shows had to be in Texas or Oklahoma and at least 51% of the their top 5 markets on Spotify were in Texas or Oklahoma. Along with Green's shows in the late 1990s, these artists began to increase with incredible popularity on college campuses in Texas and Oklahoma including Texas Tech, (Green's alma mater), Texas A&M, Oklahoma State University (home of the red dirt music scene) and the University of Texas. The artist list is a who's who of Red Dirt, including Jimmy LaFave, No Justice, Steve Ripley, Mike McClure, Brandon Jenkins, Greg Jacobs, Tom Skinner, and Cross Canadian Ragweed. Our mission is to promote the rich traditions of American Indian arts and cultures through education, a premier festival, a museum and fine art markets. Retail is $40, $50 if we need to ship. 20. Checks can be mailed to: Bob Palmer. Bethany Oklahoma. 73008. Painting Oklahoma Red Dirt Gallery. Red Earth, Inc. is a non-profit 501(c)3 organization. A gallery known for showing work by nationally known artists has exhibits by four "Red Dirt Oklahoma Artists" this month. We adjusted the numbers to reflect the monthly listeners of both of their accounts.
Tom and Wendy Zimmer got into chainsaw carving in New York. The couple hopes their "Fairy's Tree House" will mean a lot to an entire Oklahoma community.
The shows by artists Rea Baldridge, Joseph Mills, Jack Fowler, and Romy Owens, are at JRB Art at The Elms, 2810 N Walker Ave. Baldridge's oil paintings and Mills' black-and-white photos both have witty, waggish titles, that only indirectly relate to their content. JRB Art at The Elms presents a diverse roster of emerging, established, and internationally exhibited artists who create in a wide range of media, including paintings, drawings, sculpture, ceramics, glass, fine crafts, functional objects, fiber art and photographs. However, one of the things that makes him such a central figure in today's Oklahoma Red Dirt scene is the fact that he has played with everyone in Okie Red Dirt for the past two decades.
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redpajama_set_name: RedPajamaCommonCrawl


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Internal Revenue Bulletin: 2010-14
The IRS Mission
Actions Relating to Decisions of the Tax Court
Part I. Rulings and Decisions Under the Internal Revenue Codeof 1986
Rev. Rul. 2010-11
Part III. Administrative, Procedural, and Miscellaneous
Notice 2010-17
Rev. Proc. 2010-20
Part IV. Items of General Interest
Announcement 2010-19
Definition of Terms and Abbreviations
Numerical Finding List
Effect of Current Actions on Previously Published Items
Finding List of Current Actions on Previously Published Items
How to get the Internal Revenue Bulletin
INTERNAL REVENUE BULLETIN
CUMULATIVE BULLETINS
ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET
INTERNAL REVENUE BULLETINS ON CD-ROM
We Welcome Comments About the Internal Revenue Bulletin
These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.
Rev. Rul. 2010-11 Rev. Rul. 2010-11
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for April 2010.
Notice 2010-17 Notice 2010-17
This notice provides the face amount of qualified school construction bonds (QSCBs) allocated by the Department of the Treasury to each state and large local education agency for 2010 under section 54F(d) of the Code. This notice does not contain any other guidance. Notice 2009-35 supplemented.
This notice provides guidance to assist state housing credit agencies in determining how to reduce the state housing credit ceiling under section 42(h)(3) of the Code when credits are exchanged for funds under section 1602 of the American Recovery and Reinvestment Tax Act of 2009, including guidance concerning the effect of section 1602 funds on building basis and taxpayer income.
This notice provides taxpayers with interim guidance on measurement of continuity of interest of reorganizations during the period between expiration of the current temporary regulations and the issuance of new regulations.
Chile earthquake in 2010. This notice designates the Chile earthquake occurring in February 2010 as a qualified disaster for purposes of section 139 of the Code.
Announcement 2010-19 Announcement 2010-19
This announcement provides procedures that a charitable trust may use to request a ruling that it was and continues to be a Type III supporting organization described in section 509(a)(3) of the Code and to obtain a refund of any section 4940 tax paid with respect to its 2008 taxable year.
Rev. Proc. 2010-20 Rev. Proc. 2010-20
Nonshareholder contribution to capital under section 118(a). This procedure provides that the Service will not challenge a corporation's treatment of a Smart Grid Investment Grant made by the Department of Energy to the corporation as a nonshareholder contribution to the capital of the corporation under section 118(a) of the Code if the corporation properly reduces the basis of its property under section 362(c)(2) and the regulations thereunder.
Provide America's taxpayers top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all.
The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury's Office of the Assistant Secretary (Enforcement).
Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.
It is the policy of the Internal Revenue Service to announce at an early date whether it will follow the holdings in certain cases. An Action on Decision is the document making such an announcement. An Action on Decision will be issued at the discretion of the Service only on unappealed issues decided adverse to the government. Generally, an Action on Decision is issued where its guidance would be helpful to Service personnel working with the same or similar issues. Unlike a Treasury Regulation or a Revenue Ruling, an Action on Decision is not an affirmative statement of Service position. It is not intended to serve as public guidance and may not be cited as precedent.
Actions on Decisions shall be relied upon within the Service only as conclusions applying the law to the facts in the particular case at the time the Action on Decision was issued. Caution should be exercised in extending the recommendation of the Action on Decision to similar cases where the facts are different. Moreover, the recommendation in the Action on Decision may be superseded by new legislation, regulations, rulings, cases, or Actions on Decisions.
Prior to 1991, the Service published acquiescence or nonacquiescence only in certain regular Tax Court opinions. The Service has expanded its acquiescence program to include other civil tax cases where guidance is determined to be helpful. Accordingly, the Service now may acquiesce or nonacquiesce in the holdings of memorandum Tax Court opinions, as well as those of the United States District Courts, Claims Court, and Circuit Courts of Appeal. Regardless of the court deciding the case, the recommendation of any Action on Decision will be published in the Internal Revenue Bulletin.
The recommendation in every Action on Decision will be summarized as acquiescence, acquiescence in result only, or nonacquiescence. Both "acquiescence" and "acquiescence in result only" mean that the Service accepts the holding of the court in a case and that the Service will follow it in disposing of cases with the same controlling facts. However, "acquiescence" indicates neither approval nor disapproval of the reasons assigned by the court for its conclusions; whereas, "acquiescence in result only" indicates disagreement or concern with some or all of those reasons. "Nonacquiescence" signifies that, although no further review was sought, the Service does not agree with the holding of the court and, generally, will not follow the decision in disposing of cases involving other taxpayers. In reference to an opinion of a circuit court of appeals, a "nonacquiescence" indicates that the Service will not follow the holding on a nationwide basis. However, the Service will recognize the precedential impact of the opinion on cases arising within the venue of the deciding circuit.
The Actions on Decisions published in the weekly Internal Revenue Bulletin are consolidated semiannually and appear in the first Bulletin for July and the Cumulative Bulletin for the first half of the year. A semiannual consolidation also appears in the first Bulletin for the following January and in the Cumulative Bulletin for the last half of the year.
The Commissioner ACQUIECES in result only in the following decision:
James R. Thompson v.
United States,[1]
87 Fed. Cl. 728 (Fed. Cl. 2009)
[1] Acquiesces in result only relating to whether an interest in a limited liability company (LLC) is a limited partnership interest as defined under section 1.469-5T(e)(3).
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
This revenue ruling provides various prescribed rates for federal income tax purposes for April 2010 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(1) for buildings placed in service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%. Finally, Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520.
REV. RUL. 2010-11 TABLE 1
Applicable Federal Rates (AFR) for April 2010
Period for Compounding
AFR .67% .67% .67% .67%
110% AFR .74% .74% .74% .74%
AFR 2.70% 2.68% 2.67% 2.67%
110% AFR 2.97% 2.95% 2.94% 2.93%
Adjusted AFR for April 2010
Short-term adjusted AFR .53% .53% .53% .53%
Mid-term adjusted AFR 1.68% 1.67% 1.67% 1.66%
Long-term adjusted AFR 3.95% 3.91% 3.89% 3.88%
Rates Under Section 382 for April 2010
Adjusted federal long-term rate for the current month 3.95%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 4.03%
Appropriate Percentages Under Section 42(b)(1) for April 2010
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit 7.82%
Rate Under Section 7520 for April 2010
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 3.2%
Qualified School Construction Bond Allocations for 2010
SECTION 1. PURPOSE
This notice sets forth the maximum face amount of qualified school construction bonds ("QSCBs") allocated by the Department of the Treasury (Treasury) to each State and large local educational agency for 2010 under § 54F(d) of the Internal Revenue Code (Code). For this purpose, § 54A(e)(3) provides that the term "State" includes the District of Columbia and any possession of the United States. This notice supplements Notice 2009-35, 2009-17 I.R.B. 876 (April 27, 2009).
SECTION 2. BACKGROUND
.01 INTRODUCTION
Section 1521(a) of Title I of Division B of the American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, 123 Stat. 115 (2009) ("Act") added new § 54F to the Code, setting forth program provisions for QSCBs.
Section 54F(a) defines a "qualified school construction bond" to mean any bond issued as part of an issue if —
(1) 100 percent of the available project proceeds of such issue are to be used for the construction, rehabilitation, or repair of a public school facility or for the acquisition of land on which such a facility is to be constructed with part of the proceeds of such issue,
(2) the bond is issued by a State or local government within the jurisdiction of which such school is located, and
(3) the issuer designates such bond for purposes of this section.
Section 54F(c) provides a national bond limitation authorization for QSCBs of $11 billion for 2009 and $11 billion for 2010 (each, a "calendar year volume cap" and together "volume cap"). Section 54F(c)(3) provides that except for carryforwards provided for in § 54F(e), there is no calendar year volume cap for calendar years after 2010.
Section 54F(b) provides that the maximum aggregate face amount of bonds issued during any calendar year that may be designated under § 54F(a) by any issuer shall not exceed the portion of the calendar year volume cap allocated to such issuer for the calendar year under § 54F(d).
Section 54F(d)(1) provides that, except as provided in § 54F(d)(2)(C), the calendar year volume cap shall be allocated by the Treasury among the States in proportion to the respective amounts each State is eligible to receive under § 1124 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 6333) (the "Education Act") for the most recent fiscal year ending before the calendar year. Section 54F(d)(1) further provides that the calendar year volume cap amount allocated to each State is to be further allocated by the State to issuers within the State.
Section 54F(d)(2)(A) provides that 40 percent of the calendar year volume cap for any calendar year is to be allocated under § 54F(d)(2)(B) by the Treasury among local educational agencies that are large local agencies for the calendar year. Section 54F(d)(2)(B) provides that 40 percent of the calendar year volume cap is to be allocated among large local educational agencies in proportion to the respective amounts each such agency received under § 1124 of the Education Act for the most recent fiscal year ending before the calendar year.
Section 54F(d)(2)(C) provides that the allocation of calendar year volume cap to any State under § 54F(d)(1) is reduced by the aggregate amount of allocations under § 54F(d)(2) to large local educational agencies within the State.
Section 54F(d)(2)(E) defines a large local educational agency as any local educational agency if such agency is: (1) among the one hundred local educational agencies with the largest number of children aged 5 through 17 from families living below the poverty level, as determined by the Treasury using the most recent data available from the Department of Commerce that are satisfactory to the Treasury; or (2) one of not more than twenty-five additional local educational agencies that the Secretary of Education determines (based on the most recent data available satisfactory to the Treasury) are in particular need of assistance, based on a low level of resources for school construction, a high level of enrollment growth, or such other factors as the Treasury deems appropriate.
Section 54F(d)(3) provides that the amount allocated under § 54F(d)(1) to any United States possession other than Puerto Rico is an amount that would have been allocated to such possession if all allocations under § 54F(d)(1) were made on the basis of respective populations of individuals below the poverty line (as defined by the Office of Management and Budget). Section 54F(d)(3) further provides that in making the other allocations, the amount to be allocated under § 54F(d)(1) to the States is reduced by the aggregate amount allocated under § 54F(d)(3) to the United States possessions.
Section 54F(d)(4) provides for additional calendar year volume cap amounts of $200 million for calendar year 2009 and $200 million for calendar year 2010 (each an "Indian tribal government calendar year volume cap" and together the "Indian tribal government volume cap") to be allocated by the Secretary of Interior for purposes of the construction, rehabilitation, and repair of schools funded by the Bureau of Indian Affairs. This $200 million Indian tribal government calendar year volume cap allocated to the Indian tribal governments does not reduce the $11 billion calendar year volume cap allocated to the States and the large local educational agencies. Section 54F(d)(4) further provides that, for amounts of Indian tribal government volume cap allocated, Indian tribal governments (as defined in § 7701(a)(40)) are to be treated as qualified issuers.
SECTION 3. 2010 ALLOCATIONS OF NATIONAL BOND VOLUME CAP FOR QSCBs
The 2010 national bond volume cap for QSCBs is $11 billion. This amount is allocated among the States and large local educational agencies as set forth in this notice. The 2010 allocations to 103 large local educational agencies reflects the determination by the Secretary of Education to select 3 additional large local educational agencies under § 54F(d)(2)(E)(ii) for such year. The first chart below allocates $6.6 billion of the $11 billion 2010 calendar year volume cap for QSCBs to States to be issued by such State or further allocated to the issuers within such State. The second chart below allocates $4.4 billion of the $11 billion 2010 calendar year volume cap for QSCBs to large local educational agencies.
2010 Allocations to States of Volume Cap for Qualified School Construction Bonds (Net of Allocations to Large Local Educational Agencies)
Total Allocation by State/ Territory
Alabama 140,453,000
Alaska 28,163,000
Arizona 171,115,000
Arkansas 124,197,000
California 720,058,000
Colorado 95,686,000
Connecticut 98,431,000
Delaware 29,797,000
Florida 81,038,000
Georgia 234,431,000
Idaho 39,379,000
Illinois 251,167,000
Indiana 182,583,000
Iowa 66,422,000
Kansas 82,984,000
Kentucky 138,870,000
Louisiana 140,525,000
Maine 41,368,000
Maryland 45,190,000
Massachusetts 157,361,000
Michigan 297,611,000
Minnesota 80,649,000
Mississippi 134,610,000
Missouri 146,348,000
Montana 31,838,000
Nebraska 35,294,000
Nevada 5,157,000
New Hampshire 29,797,000
New Jersey 215,904,000
New Mexico 62,037,000
New York 178,782,000
North Carolina 188,591,000
North Dakota 25,974,000
Ohio 293,763,000
Oklahoma 91,217,000
Oregon 109,096,000
Pennsylvania 286,677,000
Rhode Island 41,296,000
South Carolina 129,456,000
South Dakota 29,797,000
Tennessee 119,131,000
Texas 547,674,000
Utah 55,599,000
Vermont 24,236,000
Virginia 172,249,000
Washington 162,837,000
West Virginia 72,262,000
Wisconsin 100,459,000
Wyoming 24,589,000
American Samoa 10,614,000
Guam 10,838,000
Northern Marianas 6,824,000
Virgin Islands 9,576,000
Total 6,600,000,000
2010 Allocations to Large Local Educational Agencies of Volume Cap for Qualified School Construction Bonds
Large Local Educational Agency
Alabama Birmingham City School District 14,274,000
Alabama Mobile County School District 25,419,000
Arizona Mesa Unified District 19,466,000
Arizona Phoenix Union High School District 12,514,000
Arizona Tucson Unified District 20,018,000
California Bakersfield City Elementary 15,102,000
California Compton Unified 16,893,000
California Fresno Unified 39,773,000
California Long Beach Unified 34,501,000
California Los Angeles Unified 290,180,000
California Oakland Unified 23,960,000
California Sacramento City Unified 19,342,000
California San Bernardino City Unified 25,294,000
California San Diego City Unified 36,093,000
California San Francisco Unified 12,957,000
California Santa Ana Unified 17,539,000
California Stockton City Unified 14,934,000
Colorado Denver County 1 29,262,000
District of Columbia District of Columbia Public Schools 32,947,000
Florida Brevard County School District 12,271,000
Florida Broward County School District 51,646,000
Florida Dade County School District 95,438,000
Florida Duval County School District 33,074,000
Florida Hillsborough County School District 37,935,000
Florida Lee County School District 14,308,000
Florida Marion County School District 11,253,000
Florida Orange County School District 36,229,000
Florida Palm Beach County School District 34,023,000
Florida Pasco County School District 13,627,000
Florida Pinellas County School District 23,529,000
Florida Polk County School District 21,223,000
Florida Volusia County School District 17,796,000
Georgia Atlanta City School District 34,526,000
Georgia Clayton County School District 15,166,000
Georgia De Kalb County School District 29,940,000
Georgia Fulton County School District 17,917,000
Georgia Gwinnett County School District 19,640,000
Georgia Richmond County School District 15,979,000
Hawaii Hawaii Department of Education 29,797,000
Illinois City of Chicago School District 299 257,127,000
Indiana Indianapolis Public Schools 31,534,000
Kentucky Jefferson County School District 30,352,000
Louisiana Caddo Parish School Board 20,707,000
Louisiana East Baton Rouge Parish School Board 21,675,000
Louisiana Jefferson Parish School Board 21,891,000
Louisiana Orleans Parish School Board 40,055,000
Maryland Baltimore City Public School System 53,530,000
Maryland Baltimore County Public Schools 19,952,000
Maryland Prince George's County Public Schools 25,803,000
Massachusetts Boston 41,474,000
Michigan Detroit City School District 127,644,000
Minnesota Minneapolis 19,787,000
Minnesota St. Paul 18,253,000
Mississippi Jackson Public School District 15,429,000
Missouri Kansas City School District 16,274,000
Missouri St. Louis City 28,481,000
Nebraska Omaha Public Schools 18,922,000
Nevada Clark County School District 58,833,000
New Jersey Newark City 25,753,000
New Mexico Albuquerque Public Schools 25,025,000
New York Buffalo City School District 33,025,000
New York New York City 664,010,000
New York Rochester City School District 28,376,000
North Carolina Charlotte-Mecklenburg Schools 25,051,000
North Carolina Cumberland County Schools 14,805,000
North Carolina Forsyth County Schools 14,162,000
North Carolina Guilford County Schools 16,843,000
North Carolina Wake County Schools 17,606,000
Ohio Cincinnati City School District 25,922,000
Ohio Cleveland Municipal School District 51,058,000
Ohio Columbus City School District 39,266,000
Ohio Toledo City School District 20,962,000
Oklahoma Oklahoma City 18,167,000
Oklahoma Tulsa 15,625,000
Pennsylvania Philadelphia City School District 145,352,000
Pennsylvania Pittsburgh School District 19,520,000
Puerto Rico Puerto Rico Department of Education 380,394,000
South Carolina Charleston County School District 15,076,000
South Carolina Greenville County School District 14,302,000
Tennessee Knox County School District 11,979,000
Tennessee Memphis City School District 49,710,000
Tennessee Nashville-Davidson County School District 24,016,000
Texas Aldine Independent School District 19,022,000
Texas Alief Independent School District 16,483,000
Texas Arlington Independent School District 13,656,000
Texas Austin Independent School District 24,078,000
Texas Brownsville Independent School District 25,901,000
Texas Dallas Independent School District 69,599,000
Texas Edinburg Consolidated Independent School District 13,967,000
Texas El Paso Independent School District 29,140,000
Texas Fort Worth Independent School District 28,764,000
Texas Garland Independent School District 12,488,000
Texas Houston Independent School District 95,370,000
Texas La Joya Independent School District 13,544,000
Texas Laredo Independent School District 14,165,000
Texas Northside Independent School District 14,641,000
Texas Pasadena Independent School District 14,609,000
Texas Pharr-San Juan-Alamo Independent School District 13,453,000
Texas San Antonio Independent School District 30,730,000
Texas Ysleta Independent School District 17,869,000
Virginia Norfolk City Public Schools 15,092,000
Virginia Richmond City Public Schools 14,983,000
Wisconsin Milwaukee 72,933,000
SECTION 4. EFFECTIVE DATE OF 2010 ALLOCATIONS OF NATIONAL BOND VOLUME CAP
The allocations of the national bond volume cap for QSCBs in Section 3 are effective for QSCBs issued, pursuant to an allocation of 2010 calendar year volume cap, after March 16, 2010.
SECTION 5. ALLOCATION OF THE INDIAN TRIBAL GOVERNMENT VOLUME CAP
The Department of the Interior is exclusively responsible for making the allocations of the Indian tribal government volume cap and published a notice in the Federal Register, 74 F.R. 56211-02 (October 30, 2009), soliciting applications for allocations of such volume cap. Interested parties may also contact John Rever, Director, Office of Facilities, Environment and Cultural Resources, Bureau of Indian Affairs, at (703) 390-6314 or John.Rever@bia.gov.
SECTION 6. DRAFTING INFORMATION
The principal authors of this notice are Aviva M. Roth and Johanna Som de Cerff of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regarding this notice, contact Johanna Som de Cerff at (202) 622-3980 (not a toll-free call).
American Recovery and Reinvestment Tax Act of 2009 Clarifications
This notice clarifies certain issues under sections 1404 and 1602 of the American Recovery and Reinvestment Tax Act of 2009 (Pub. L. 111-5) (the Act). Specifically, this notice provides guidance on how to take into account the amount of a grant under section 1602 of the Act in reducing the amount of a state's housing credit ceiling, on the exclusion of the amount of grants from the recipients' gross income, and on the effect of such grants on the depreciable or eligible basis of property.
Section 42 of the Internal Revenue Code allows a 10-year tax credit for investment in qualified low-income buildings placed in service after December 31, 1986. Section 42(h)(1) provides, generally, that the amount of credit under § 42 for any taxable year for any building shall not exceed the housing credit dollar amount allocated to the building. Section 42(h)(3)(A) provides, in part, that the aggregate housing credit dollar amount that a State housing credit agency may allocate for any calendar year is limited to that year's State housing credit ceiling (Ceiling).
Section 42(h)(3)(C) of the Code provides, in part, that the Ceiling applicable to any State for any calendar year is an amount equal to—
(i) the unused Ceiling, if any, of the State for the preceding calendar year;
(ii) the greater of (I) $1.75 multiplied by the State population, or (II) $2,000,000;
(iii) the amount of Ceiling returned in the calendar year, and;
(iv) the amount, if any, allocated to the State by the Secretary under § 42(h)(3)(D) from a national pool (National Pool) of unused credit.
Section 42(h)(3)(H) of the Code provides that for calendar years after 2002, the $2,000,000 and $1.75 amounts in § 42(h)(3)(C)(ii) shall be increased by a cost-of-living adjustment (COLA). Section 42(h)(3)(I) increases the Ceiling for 2009 by adding (i) $0.20 for the dollar amount in effect under § 42(h)(3)(C)(ii)(I) after application of the § 42(h)(3)(H) COLA, and (ii) an amount equal to 10 percent for the dollar amount in effect under § 42(h)(3)(C)(ii)(II) (rounded to the next lowest multiple of $5,000) after application of the § 42(h)(3)(H) COLA. For the 2009 Ceiling, the § 42(h)(3)(C)(ii)(I) and (II) amounts are $2.30 and $2,665,000, respectively. See Section 3.07 of Rev. Proc. 2008-66, 2008-45 I.R.B. 1107, 1111.
Section 42(i)(9)(A) of the Code, as added by section 1404 of the Act, provides that the amounts described in § 42(h)(3)(C)(i) through (iv) with respect to any State for 2009 shall each be reduced by so much of the amount as is taken into account in determining the amount of any grant to the State under section 1602 of the Act. Section 1602(a) of the Act provides that the Department of the Treasury shall make a grant to the housing credit agency of each State in an amount equal to the State's low-income housing grant election amount. Section 1602(b) of the Act provides that the term "low-income housing grant election amount" means, for any State, the amount as the State may elect that does not exceed 85 percent of—
(1) the sum of—
(A) 100 percent of the State's 2009 Ceiling that is attributable to amounts described in § 42(h)(3)(C)(i) and (iii) of the Code, and
(B) 40 percent of the State's 2009 Ceiling that is attributable to amounts described in § 42(h)(3)(C)(ii) and (iv), multiplied by
(2) 10.
On May 4, 2009, the Department of the Treasury released guidance in the form of an application (Application) and grantee terms and conditions (Terms and Conditions) informing designated State housing credit agencies (Designated Agencies) how to exchange low-income housing tax credits for amounts under section 1602 of the Act. This guidance may be accessed electronically at: http://www.treas.gov/recovery/docs/LIH_application-package.pdf
A list of the Designated Agencies is provided, and background information to the Application states, on page 3, that a Designated Agency is one that files Form 8610, "Annual Low-Income Housing Credit Agencies Report," for all agencies within the State. Paragraph 2.a. of the Terms and Conditions provides that the grantee is the housing credit agency that files Form 8610. Paragraph 7.a. of the Terms and Conditions provides that the grantee shall track (1) the credit equivalent of all grant election amounts to ensure that the 2009 Ceiling is appropriately reduced as required by § 42(i)(9)(A) of the Code and (2) total grant election amounts to ensure that these amounts do not exceed the amount authorized by section 1602(b) of the Act. Paragraph 7.b. provides that the grantee shall track the total of credits allocated under § 42(h)(1). Paragraph 7.c. provides that the grantee shall ensure that the credit equivalent of all elected grant amounts through 2010, plus the credits allocated under § 42(h)(1) during 2009, do not exceed the 2009 Ceiling. The Terms and Conditions do not explain how the credit equivalent of a grant election amount is determined.
Section 42(d)(1) of the Code provides that the eligible basis of a new building is its adjusted basis as of the close of the first tax year of the credit period. Section 42(d)(4)(A) provides that, except as provided in § 42(d)(4)(B) and (C), the adjusted basis of any building is determined without regard to the adjusted basis of any property that is not residential rental property. Section 42(d)(4)(B) provides that the adjusted basis of any building includes the adjusted basis of property of a character subject to the allowance for depreciation used in common areas or provided as comparable amenities to all residential rental units in the building. Section 42(d)(5)(A) provides that the eligible basis of a building shall not include any costs financed with the proceeds of a federally funded grant. Section 42(i)(9)(B), as added by section 1404 of the Act, provides that the basis of a qualified building shall not be reduced by the amount of any grant described in § 42(i)(9)(A). The legislative history to the Act provides that grants received under this provision (i.e., cash assistance received under section 1602 of the Act) do not reduce [the] tax basis of a qualified low-income building. The legislative history to the Act further provides that grants under this provision are not taxable income to recipients. See H.R. Conf. Rep. No. 16, 111th Cong., 1st Sess. 532, 533 (2009).
1. Credit Equivalent of Cash Assistance and Tracking under § 42(i)(9)(A)
Section 42(i)(9)(A) of the Code, as added by section 1404 of the Act, requires that the amounts in § 42(h)(3)(C)(i) through (iv) shall each be reduced by so much of such amount as is taken into account in determining the amount of any grant (cash assistance) under section 1602 of the Act. Thus, similar to the way the Designated Agency tracks allocations of credit during the course of a calendar year to ensure that total credits allocated do not exceed the Ceiling for that year, § 42(i)(9)(A) implies a duty (and paragraph 7 of the grant application Terms and Conditions imposes a duty) by the Designated Agency to track credits allocated and the credit equivalent of cash assistance amounts to ensure that total credits allocated from the 2009 Ceiling and the credit equivalent of total cash assistance amounts do not exceed the 2009 Ceiling. A Designated Agency may determine the credit equivalent of a cash assistance amount by dividing the cash assistance amount by 8.5 and rounding the result up to the nearest dollar.
For example, in computing the reduction with respect to the § 42(h)(3)(C)(ii) component of the Ceiling (and using an actual figure published by the Department of the Treasury in the List of Designated Agencies attached to the Application), assume that the maximum cash assistance amount permissible from the 2009 Ceiling for State X with respect to that component is $9,061,000. State X is a state whose population qualifies for $2,665,000 in credits under § 42(h)(3)(C)(ii)(II), as adjusted for inflation under § 42(h)(3)(H). The Department of the Treasury determined the maximum cash assistance amount of $9,061,000 available to State X by multiplying total available credits of $2,665,000 under § 42(h)(3)(C)(ii)(II) by the formula prescribed by section 1602(b) of the Act for credits under § 42(h)(3)(C)(ii)(II) (i.e., 0.85 x ([$2,665,000 x 0.4] x 10)). Of this amount, assume the Designated Agency of State X elects under section 1602(b) of the Act a cash assistance amount of $5 million. The credit equivalent of $5 million is $588,236 (i.e., $5 million/8.5 = $588,235.29, rounded up to the nearest dollar). For purposes of making the reduction required by § 42(i)(9)(A) to State X's 2009 Ceiling, the $2,665,000 in credits under § 42(h)(3)(C)(ii) must be reduced by $588,236, the credit equivalent of the $5 million cash assistance amount, not by the $5 million cash assistance amount. The $2,076,764 (i.e., $2,665,000 - $588,236) remaining in credit under § 42(h)(3)(C)(ii) is available for use in making credit allocations by the Designated Agency. However, for purposes of making any future cash assistance election under section 1602 of the Act from the § 42(h)(3)(C)(ii) portion of State X's 2009 Ceiling, the $9,061,000 maximum cash assistance amount is reduced by $5 million to $4,061,000.
The Department of the Treasury may not, in view of the taxpayer privacy and disclosure rules under § 6103 of the Code, publish the maximum cash assistance amounts from the other components of a State's 2009 Ceiling (unlike credits under § 42(h)(3)(C)(ii)). To ensure that credits allocated and the credit equivalent of cash assistance amounts from any of these components of the 2009 Ceiling do not exceed credits available from those components, a Designated Agency should multiply the credit amount used to elect a cash assistance amount by the percentage applicable to that credit amount under section 1602(b)(1) of the Act, and then reduce the 2009 Ceiling accordingly.
For example, in computing the reduction with respect to the § 42(h)(3)(C)(iv) component of the Ceiling, assume that the credit amount of that component from State X's 2009 Ceiling is $1 million. Assume further that in computing the reduction with respect to the § 42(h)(3)(C)(iii) component, the credit amount of that component from State X's 2009 Ceiling is $2 million. Of the $1 million in credits under § 42(h)(3)(C)(iv), the Designated Agency of State X elects under section 1602 of the Act to use $800,000 for a cash assistance amount. Of the $2 million in credits under § 42(h)(3)(C)(iii), the Designated Agency elects under section 1602 of the Act to use $1.5 million for a cash assistance amount.
Under section 1602(b)(1)(B) of the Act, the percentage applicable to credit amounts under § 42(h)(3)(C)(iv) is 40 percent. The product of $800,000 and 40 percent is $320,000. As required by § 42(i)(9)(A), the $1 million of credits under § 42(h)(3)(C)(iv) is reduced by $320,000, not $800,000. The remaining $680,000 in credits (i.e., $1 million - $320,000) under § 42(h)(3)(C)(iv) is available for use in making credit allocations by the Designated Agency. However, the $1 million of credit under § 42(h)(3)(C)(iv) is reduced by $800,000 for purposes of making any future elections for cash assistance under section 1602 of the Act.
Under section 1602(b)(1)(A) of the Act, the percentage applicable to credit amounts under § 42(h)(3)(C)(iii) is 100 percent. The product of $1.5 million and 100 percent is $1.5 million. As required by § 42(i)(9)(A), the $2 million of credits under § 42(h)(3)(C)(iii) is reduced by $1.5 million, the actual credit amount elected by the Designated Agency to make a cash assistance election under section 1602 of the Act. The remaining $500,000 in credits (i.e., $2 million - $1.5 million) under § 42(h)(3)(C)(iii) is available for use in making credit allocations by the Designated Agency. Similarly, the $2 million in credits under § 42(h)(3)(C)(iii) is reduced by $1.5 million for purposes of making any future elections for cash assistance under section 1602 of the Act.
2. Income Tax Treatment of Subawards
Based on the legislative history of the Act, subawards made pursuant to section 1602(c) of the Act are excluded from the gross income of recipients and are exempt from taxation.
3. Basis Treatment of Subawards
Section 42(i)(9)(B) of the Code, as added by section 1404 of the Act, provides that the basis of a qualified building shall not be reduced by the amount of any grant described in § 42(i)(9)(A). The legislative history to the Act provides that grants received under this provision (i.e., cash assistance received under section 1602 of the Act) do not reduce the tax basis of a qualified low-income building. By extension, subawards under section 1602(c) of the Act derived from cash assistance under that section that are used in a qualified low-income building are not federal grants for purposes of § 42(d)(5)(A) and do not otherwise reduce the depreciable or eligible basis of the building.
DRAFTING INFORMATION
The principal author of this notice is Christopher J. Wilson, Office of the Associate Chief Counsel (Passthroughs and Special Industries). For further information concerning this notice, contact Mr. Wilson at (202) 622-3040 (not a toll-free call).
INTERIM GUIDANCE ON MEASUREMENT OF CONTINUITY OF INTEREST IN REORGANIZATIONS
This notice pertains to the continuity of interest test generally applicable to reorganizations described in section 368 of the Internal Revenue Code.
Under section 7805(e)(2) of the Internal Revenue Code, temporary regulations expire three years after issuance, if not earlier withdrawn. Section 1.368-1T(e)(2) of the Income Tax Regulations will accordingly expire on March 19, 2010. The purpose of this notice is to provide taxpayers with interim guidance applicable to the period between the expiration of the temporary regulations and the issuance of replacement guidance.
II. BACKGROUND AND INTERIM GUIDANCE
The Internal Revenue Code of 1986 (Code) generally provides nonrecognition treatment for reorganizations described in section 368 of the Code. Besides satisfying the statutory and other requirements, in order to qualify as a reorganization, a transaction generally must satisfy the continuity of interest (COI) requirement. COI requires that, in substance, a substantial part of the value of the proprietary interests in the target corporation be preserved in the reorganization.
On March 20, 2007, the Internal Revenue Service (Service) and the Treasury Department (Treasury) published temporary regulations § 1.368-1T(e)(2) (T.D. 9316, 2007-1 C.B. 962) and proposed regulations (REG-146247-06, 2007-1 C.B. 977) in the Federal Register (72 FR 12974 and 72 FR 13058, respectively). The text of the temporary regulations and the proposed regulations is the same. The Service and the Treasury intend to issue final regulations, but do not expect to issue such regulations prior to the expiration of the temporary regulations. The purpose of this notice is to provide taxpayers with interim guidance applicable to the period between the expiration of the temporary regulations and the issuance of new regulations.
After expiration of the temporary regulations and prior to the issuance of new regulations, taxpayers may apply the rules set forth in the proposed regulations notwithstanding that the temporary regulations have expired. However, the target corporation, the issuing corporation, the controlling corporation of the acquiring corporation if stock thereof is provided as consideration in the transaction, and any direct or indirect transferee of transferred basis property from any of the foregoing, may not apply the provisions of the proposed regulations unless all such taxpayers elect to apply the provisions of such regulations. This requirement will be satisfied if none of the specified parties adopts treatment inconsistent with this election.
The principal author of this notice is Richard Starke of the Office of Associate Chief Counsel (Corporate). For further information regarding this notice, please contact Richard Starke at (202) 622-7790 (not a toll-free call).
Chile Earthquake Occurring in February 2010 Designated as a Qualified Disaster Under § 139 of the Internal Revenue Code
This notice designates the Chile earthquake occurring in February 2010 as a qualified disaster for purposes of § 139 of the Internal Revenue Code in the affected areas of Chile.
EARTHQUAKE DISASTER
On February 27, 2010, a magnitude 8.8 earthquake with numerous significant aftershocks and a tsunami affected southern and central Chile ("Chile earthquake"). The earthquake and resulting aftershocks affected approximately 2 million individuals, displaced thousands of individuals from damaged and destroyed houses, and resulted in 795 deaths. The earthquake also caused major damage to buildings and infrastructure near the epicenter, and disrupted communications, electricity, water, and gas services in the affected areas. In addition, a tsunami caused significant damage along parts of coastal Chile. USAID Chile — Earthquake Fact Sheet No. 1 (March 1, 2010) and No. 2 (March 2, 2010).
This notice enables employer-sponsored private foundations to assist certain victims in areas affected by the Chile earthquake and enables recipients to exclude qualified disaster relief payments from gross income.
QUALIFIED DISASTER RELIEF PAYMENTS EXCLUDED FROM RECIPIENT'S GROSS INCOME
Section 139(a) provides that gross income shall not include any amount received by an individual as a qualified disaster relief payment.
Section 139(b) provides that a qualified disaster relief payment includes any amount paid to or for the benefit of an individual—
(1) to reimburse or pay reasonable and necessary personal, family, living, or funeral expenses (not otherwise compensated for by insurance or otherwise) incurred as a result of a qualified disaster, or
(2) to reimburse or pay reasonable and necessary expenses (not otherwise compensated for by insurance or otherwise) incurred for the repair or rehabilitation of a personal residence or repair or replacement of its contents to the extent that the need for such repair, rehabilitation, or replacement is attributable to a qualified disaster.
Under § 139(c)(3) the term "qualified disaster" includes a disaster resulting from an event that is determined by the Secretary to be of a catastrophic nature.
DESIGNATION AS QUALIFIED DISASTER
The Commissioner of Internal Revenue, pursuant to delegation by the Secretary, has determined that the Chile earthquake occurring in February 2010 is an event of a catastrophic nature under § 139(c)(3). Therefore, the Chile earthquake is designated as a qualified disaster under § 139 in the affected areas of Chile.
SECTION 501(c)(3) ORGANIZATIONS
Employer-sponsored private foundations may choose to provide disaster relief to employee victims of the Chile earthquake. Like all organizations described in § 501(c)(3), private foundations should exercise due diligence when providing disaster relief as set forth in Publication 3833, Disaster Relief: Providing Assistance Through Charitable Organizations.
The principal author of this notice is Sheldon Iskow of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information regarding this notice, contact Mr. Iskow at (202) 622-4920 (not a toll-free call).
This revenue procedure provides a safe harbor under section 118(a) of the Internal Revenue Code for the treatment of a Smart Grid Investment Grant (SGIG) under 42 U.S.C. 17386 made by the United States Department of Energy (DOE) to a corporation for qualifying investments under the Smart Grid Investment Matching Grant Program as authorized by section 1306 of the Energy Independence and Security Act of 2007 (Pub. L. 110-140), as amended by section 405, Division A of the American Recovery and Reinvestment Act of 2009 (Pub. L. 111-5).
Section 118(a) of the Code provides that in the case of a corporation, gross income does not include a contribution to the capital of the taxpayer.
Section 1.118-1 of the Income Tax Regulations provides that section 118 applies to contributions to capital made by a person other than a shareholder, for example, property contributed to a corporation by a governmental unit for the purpose of enabling the corporation to expand its operating facilities.
Section 362(c)(2) of the Code requires a basis reduction in a corporation's property when the corporation receives money from a nonshareholder as a contribution to its capital.
42 U.S.C. 17386 provides that DOE shall establish a Smart Grid Investment Matching Grant Program to make grants for qualifying investments. Under 42 U.S.C. 17386, an SGIG may not be used for ongoing or routine operating and maintenance expenditures.
SECTION 3. SCOPE
This revenue procedure applies to corporate taxpayers that receive an SGIG under 42 U.S.C. 17386 from DOE. This revenue procedure does not apply to noncorporate taxpayers, or to grants under 42 U.S.C. 17384 (Smart Grid technology research, development, and demonstration).
SECTION 4. PROCEDURE
The Internal Revenue Service will not challenge a corporation's treatment of an SGIG made by DOE to the corporation as a nonshareholder contribution to the capital of the corporation under section 118(a) of the Code if the corporation properly reduces the basis of its property under section 362(c)(2) and the regulations thereunder.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective March 10, 2010.
The principal author of this revenue procedure is David McDonnell of the Office of Associate Chief Counsel (Passthroughs & Special Industries). For further information regarding this revenue procedure, contact Mr. McDonnell at (202) 622-3040 (not a toll-free call).
PROCEDURES FOR CERTAIN TRUSTS THAT QUALIFY AS TYPE III SUPPORTING ORGANIZATIONS
This announcement applies to any trust that met the requirements to be classified as a Type III supporting organization through the end of the 2008 taxable year (including by meeting the significant voice responsiveness test for periods after August 16, 2007), but erroneously filed Form 990-PF and paid section 4940 tax for the 2008 taxable year. It provides procedures that such a trust may use to request a ruling that it was and continues to be a Type III supporting organization described in section 509(a)(3) and to obtain a refund of any section 4940 tax paid with respect to its 2008 taxable year.
This announcement also describes procedures for charitable trusts that became private foundations after August 16, 2007, and wish to terminate their private foundation status under section 507(b)(1)(B) by operating as Type III supporting organizations.
Treas. Reg. § 1.509(a)-4(i) sets forth the requirements for an organization to qualify as a section 509(a)(3) supporting organization that is "operated in connection with" one or more publicly supported organizations (i.e., a "Type III supporting organization"). Type III supporting organizations are required to meet a "responsiveness test" and an "integral part test." See Treas. Reg. § 1.509(a)-4(i)(1)(i), (i)(2).
Prior to passage of the Pension Protection Act of 2006, Pub. L. No. 109-280, 120 Stat. 780 (2006) ("PPA"), there were two alternative ways for a Type III supporting organization to meet the responsiveness test.
The significant voice test. Treas. Reg. § 1.509(a)-4(i)(2)(ii) provides that an organization meets the responsiveness test if, by virtue of certain governance relationships between the supporting organization and the supported organization, or a close and continuous working relationship between the supporting organization and supported organization, the officers, directors, or trustees of the publicly supported organization have a significant voice in the investment policies of the supporting organization, the timing of grants, the manner of making them, and the selection of recipients of such supporting organization, and in otherwise directing the use of the income or assets of the supporting organization.
The charitable trust test. Treas. Reg. § 1.509(a)-4(i)(2)(iii) provides that an organization meets the responsiveness test if it is a charitable trust under state law, each publicly supported organization is a named beneficiary under the trust's governing instrument, and each beneficiary organization has the power to enforce the trust and compel an accounting under state law.
Section 1241(c) of the PPA eliminated the charitable trust test, effective August 17, 2007. Consequently, as of August 17, 2007, a charitable trust can no longer qualify as a Type III supporting organization unless it meets the significant voice test.
Notice 2008-6, 2008-1 C.B. 275, provided that any charitable trust that became a private foundation because of the PPA's elimination of the charitable trust test would not be required to file an information return on Form 990-PF or pay excise taxes on investment income under section 4940 until its first taxable year beginning on or after January 1, 2008.
On August 2, 2007, the Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") published an advance notice of proposed rulemaking ("ANPRM") describing the rules Treasury and the IRS anticipated proposing regarding Type III supporting organizations. The ANPRM states that Treasury and the IRS expect that all Type III supporting organizations will be required to meet the significant voice responsiveness test under Treas. Reg. § 1.509(a)-4(i)(2)(ii).
On September 24, 2009, Treasury and the IRS published a notice of proposed rulemaking in the Federal Register (74 Fed. Reg. 48,672) addressing Type III supporting organizations ("proposed regulations"). The proposed regulations require that all Type III supporting organizations meet the significant voice responsiveness test, and provide two new examples illustrating the application of the significant voice test to charitable trusts.
A trust may request a ruling stating that it is a Type III supporting organization and obtain a refund of any tax paid under section 4940 by following the procedures set forth in this Announcement if it is either:
A charitable trust that:
received a determination recognizing its tax-exempt status under section 501(c)(3);
was classified as a Type III supporting organization prior to enactment of the PPA;
continued to meet the requirements to be classified as a Type III supporting organization through the end of its 2008 taxable year (including by meeting the significant voice responsiveness test for periods after August 16, 2007); and
erroneously filed Form 990-PF for the 2008 taxable year and paid section 4940 tax for the 2008 taxable year;
A non-exempt charitable trust described in section 4947(a)(1) that:
is treated for certain purposes as an organization described in section 501(c)(3);
erroneously filed Form 990-PF for the 2008 taxable year and paid section 4940 tax for the 2008 taxable year.
A. Ruling that trust qualifies as Type III supporting organization for taxable years beginning on or after January 1, 2008
A trust may request a ruling that it qualified and continues to qualify as a Type III supporting organization for taxable years beginning on or after January 1, 2008, by submitting a written request for a ruling pursuant to Revenue Procedure 2010-4, 2010-1 I.R.B. 122.
The request for ruling should generally follow the format specified in Revenue Procedure 2010-4 and must include the following:
A subject line or other indicator on the first page of the request in bold, underlined, or all capitals font indicating "REQUEST FOR RULING — TYPE III SUPPORTING ORGANIZATION STATUS OF TRUST."
An explanation of how the trust satisfied the requirements to be classified as a Type III supporting organization through the end of its 2008 taxable year (including by meeting the significant voice responsiveness test for periods after August 16, 2007), and how it expects to continue to satisfy such requirements for subsequent years. For this purpose, the trust may rely on the proposed regulations.
With respect to the significant voice test, documentation that establishes that the trust satisfied the requirements of the test. For example, such documentation may include minutes or other documentation of meetings, telephone calls, conversations, e-mail exchanges, and policies that demonstrate a close and continuous working relationship between the supported organization(s) and the supporting organization based upon which the supported organization(s) has a significant voice.
Like all requests for a ruling, the request must be signed under penalties of perjury by the trust's officer, director, trustee, or other authorized official. The complete request should be mailed to:
Attention: EO Letter Rulings
McPherson Station
There is no user fee for this ruling request. No deletions statement is required because determinations regarding foundation status are public pursuant to section 6104. The Checklist in Appendix B of Revenue Procedure 2010-4 is not required.
B. Claims for refunds of tax paid under section 4940 for taxable years beginning on or after January 1, 2008
A trust may request a refund of tax paid under section 4940 for its first taxable year beginning on or after January 1, 2008, by filing a Form 843 that meets the following requirements:
The Form 843 must be accompanied by a copy of the ruling received from the IRS under the procedures set forth in this announcement.
The Form 843 must be submitted by mail or delivered to:
Internal Revenue Service Center
MS: 6710
Ogden, Utah 84409-0074
The Form 843 must be completed as follows:
Write "Announcement 2010-19 status change" at the top of Form 843,
On line 6, check the box for "990-PF," and
On line 7, write "Announcement 2010-19 status change by Type III supporting organization."
C. 2008 Form 990
Any trust that receives a ruling that it is a Type III supporting organization under the procedures set forth in this announcement must file a Form 990 for its first taxable year beginning on or after January 1, 2008, within 120 days of the date of the ruling letter. The top of page 1 of the Form 990 should bear the following legend in bold, underlined, or all capitals font: "ANNOUNCEMENT 2010-19."
D. Section 507 terminations of private foundation status
Charitable trusts that became private foundations after August 16, 2007, may terminate their private foundation status under section 507(b)(1)(B) by operating as Type III supporting organizations. Under existing law and procedures, a private foundation may terminate its private foundation status under section 507(b)(1)(B) by: (1) operating as an organization described in paragraph (1), (2), or (3) of section 509(a) for a continuous period of at least 60 calendar months beginning with the first day of any taxable year that begins after December 31, 1969; (2) notifying the Secretary before the commencement of the 60-month period that it is terminating its private foundation status; and (3) establishing that it in fact operated as an organization described in section 509(a)(1), (2), or (3) to the satisfaction of the Secretary immediately after the expiration of the 60-month period.
Notifications of termination should be labeled "TERMINATION NOTIFICATION" at the top of the first page of the cover letter, and should be submitted to the Determinations office in Cincinnati. The letter and accompanying documentation should be mailed to—
For further information regarding this announcement, contact Mike Repass of the Exempt Organizations, Tax Exempt and Government Entities Division at (202) 283-8924 (not a toll-free call).
Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below).
Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed.
Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them.
Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted.
Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling.
Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded.
Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series.
Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.
Revenue rulings and revenue procedures (hereinafter referred to as "rulings") that have an effect on previous rulings use the following defined terms to describe the effect:
The following abbreviations in current use and formerly used will appear in material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel's Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D. —Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2009-27 through 2009-52 is in Internal Revenue Bulletin 2009-52, dated December 28, 2009.
Bulletins 2010-1 through 2010-14
2010-1 2010-4 I.R.B. 2010-4 333
2010-10 2010-7 I.R.B. 2010-7 410
2010-11 2010-10 I.R.B. 2010-10 438
2010-19 2010-14 I.R.B. 2010-14
132232-08 2010-6 I.R.B. 2010-6 401
117501-09 2010-11 I.R.B. 2010-11 442
Revenue Procedures
2010-1 2010-1 I.R.B. 2010-1 1
2010-2 2010-1 I.R.B. 2010-1 90
Revenue Rulings
2010-8 2010-10 I.R.B. 2010-10 432
Treasury Decisions
9474 2010-4 I.R.B. 2010-4 322
9480 2010-11 I.R.B. 2010-11 439
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2009-27 through 2009-52 is in Internal Revenue Bulletin 2009-52, dated December 28, 2009.
Old Article
2009-51 Supplemented and superseded by Ann. 2010-16 2010-11 I.R.B. 2010-11 450
2010-4 Corrected by Ann. 2010-10 2010-7 I.R.B. 2010-7 410
2005-88 Superseded by Notice 2010-13 2010-4 I.R.B. 2010-4 327
2008-41 Modified by Notice 2010-7 2010-3 I.R.B. 2010-3 296
2008-113 Modified by Notice 2010-6 2010-3 I.R.B. 2010-3 275
2009-11 Amplified by Notice 2010-9 2010-3 I.R.B. 2010-3 298
2009-13 Obsoleted by T.D. 9478 2010-4 I.R.B. 2010-4 315
2009-13 Obsoleted by REG-131028-09 2010-4 I.R.B. 2010-4 332
2009-35 Supplemented by Notice 2010-17 2010-14 I.R.B. 2010-14
2009-38 Amplified and superseded by Notice 2010-2 2010-2 I.R.B. 2010-2 251
2009-62 Modified and supplemented by Notice 2010-23 2010-11 I.R.B. 2010-11 441
127270-06 Hearing scheduled by Ann. 2010-6 2010-6 I.R.B. 2010-6 402
80-59 Modified and superseded by Rev. Proc. 2010-11 2010-2 I.R.B. 2010-2 269
87-35 Obsoleted by Rev. Proc. 2010-3 2010-1 I.R.B. 2010-1 110
2008-14 Updated by Rev. Proc. 2010-15 2010-7 I.R.B. 2010-7 404
2009-1 Superseded by Rev. Proc. 2010-1 2010-1 I.R.B. 2010-1 1
2009-2 Superseded by Rev. Proc. 2010-2 2010-1 I.R.B. 2010-1 90
2009-3 Superseded by Rev. Proc. 2010-3 2010-1 I.R.B. 2010-1 110
2009-15 Amplified and superseded by Rev. Proc. 2010-12 2010-3 I.R.B. 2010-3 302
2009-17 Superseded by Rev. Proc. 2010-21 2010-13 I.R.B. 2010-13 473
2009-25 Superseded by Rev. Proc. 2010-3 2010-1 I.R.B. 2010-1 110
2009-55 Corrected by Ann. 2010-11 2010-10 I.R.B. 2010-10 438
2010-1 Corrected by Ann. 2010-5 2010-6 I.R.B. 2010-6 402
67-436 Obsoleted by REG-101896-09 2010-5 I.R.B. 2010-5 347
92-19 Supplemented in part by Rev. Rul. 2010-7 2010-8 I.R.B. 2010-8 417
2008-52 Supplemented and superseded by Rev. Rul. 2010-2 2010-3 I.R.B. 2010-3 272
9424 Corrected by Ann. 2010-18 2010-12 I.R.B. 2010-12 460
9443 Corrected by Ann. 2010-8 2010-7 I.R.B. 2010-7 408
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed.
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents.
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Businesses. Under Businesses Topics, select More Topics. Then select Internal Revenue Bulletins.
Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD-ROM). The CD-ROM can be purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders) or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the
P.O. Box 371954, Pittsburgh PA, 15250-7954.
Please allow two to six weeks, plus mailing time, for delivery.
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the
IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224.


These 2 best selling books are used in super good conditions . 2 books for the price of $20. All pages have NO writings or markings. NO torn pages.
Brand New Book (hard copy). Condition: Perfect. Latest Edition. Kinokuniya sells this book at $142.26.
Great content with step by step guide on designing a awesome service or product.


text:
Q: Run an action after end animation is it possible to run a function after end this animation?
Thank you for you help
animation = CurvedAnimation(
       parent: controller,
       curve: Curves.linear,
      ).drive(Tween(begin: 0.0, end: 1));

A: You can call
animation.addStatusListener((status) {
   if (status == AnimationStatus.completed) {
      // do your logic
   }
});

Look at the docs

A: you have an isCompleted property on the AnimationController.
You can probably listen for this value?
See https://stackoverflow.com/a/45331922/11550065

redpajama_set_name: RedPajamaStackExchange


Wow, our biggest soap yet weighing in over 7.5/8 oz.
Amber scent is warm, musky, rich and honey-like, and also somewhat earthy.
We added to that sweet tobacco leaf fragrance, that does not smell like pipes or cigars. Tobacco leaf has aromatic spice notes that create a mood, more than anything else. Together, the two scents complement each other into a very lovely aroma!


It takes an enormous amount of energy to live in an alcoholic family in denial. "Loose lips sink ships," my father said and our family currency became half-truths and lies. My dad wasn't a drunk. He liked to drink. He wasn't an alcoholic because he didn't go to AA. Even thirty days in rehab didn't stop the denial. We unknowingly snuck him out one night when he begged us to visit and then told us we could take him into town for an outing. I knew it wasn't because he missed us, but because he missed the liquor store.
See, no matter how many drunken speeches an alcoholic makes about how he loves his family, he loves the alcohol more. Deep down, his family knows this. We did. We heard it in the next-day apologies for his drunken behavior. We saw it in the glaze of his eyes. It reverberated in the clink of empty bottles.
As I grew older, it became harder and harder to convince myself that I was content in a relationship where I came in second to a bottle of booze. Eventually, he succeeded in pushing me away and I let him. For that, I am grateful.
Growing up with an alcoholic taught me to be careful and cautious and scared. It made me evaluate every drink I take. It forces me to analyze every slurred word or stumble I make when I'm drinking. All of my interactions with alcohol are judged on a strict scale because, due to my family history, I'm only a few drinks away from being an alcoholic. I carry that burden with every drink I take.
Maybe that's where I break the cycle. I love my kids more than I'll ever love booze.
Yes, alcoholism is a disease. Yes, some of us are genetically predisposed. And it might be unfair, and un-politically correct, but on some level I still believe that if my father had loved us enough, he would have given up alcohol and I guess I'll never forgive him for that decision.
All I can do is not make the same mistake he did.
This entry was posted in relationships and tagged Alcohol, Alcoholics Anonymous, Alcoholism, Drink, Family, Health.


Itch! on Bank Street List!
Itch! by Anita Sanchez and illustrated by me, was selected for the Bank Street Best Books of 2019 List for the 9-12 year olds in science. The list of Itch! and other books can be found here!
Kirkus gave upcoming book ITCH! a starred review. The book is out in March of next year.


Matrix Design Studio has years of experience applying for Coastal Development Permits with the California Coastal Commission. Our firm works with recognized geotechnical and civil engineering experts that specialize in the Southern California region to develop coastal planning and development permitting strategies. Matrix Design Studio has completed high-profile public and private projects in the La Jolla, Del Mar, Solana Beach, Encinitas and Laguna Beach coastal zones.
Our breadth of experience can inform the design of a project so that it does not automatically trigger the Coastal Development Permitting process unless appropriate. We coordinate with the California Coastal Commission to ensure the permitting process is as smooth as possible, thorough and professional. We understand the ever changing challenges of the California coastal bluff set backs.
Our familiarity with the Coastal Permitting Process ensures the design intent of the project aligns with the California Coastal Commission's environmental concerns prior to commencing the permitting process, reducing the likelihood of costly redesigns. We work with the California Coastal Commission to protect the design intent of the project while addressing the project's coastal and environmental impacts, ensuring the city's vision for development aligns with the project goals. Our firm navigates the challenges of the permitting process by using our depth of knowledge of the intricacies of the California Coastal laws, regulations, procedures and policies.


City Hall should provide more leadership in helping our school students and teachers. I would like to see thousands more of our kids do well in school, graduate, go to college, and go on to fulfilling, prosperous and enjoyable lives. I would like teachers to be able to afford homes near the schools they teach in.
We have a school system that used to be, and could once again be, an envy of the nation. Schools represent our future, our soul, our economic health. We can do a lot better.
I have been involved in our public schools for 7 years. After visiting Minneapolis and learning about how their city aided their schools, I wrote '80% in 4 years' to show how our City Council could help to increase our graduation rates. Stuart's recent involvement with Schools.
LHS: Lincoln Foundation - 2010 - 12For further information on my school experience, please click here.
Cutting dovetails in 1972. Woodworking was a big part of my high school life. I have a personal connection to CTE.


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Our firm is a team of architects, interior designers, real estate development professionals, and property managers.
Providing meals, entertainment, house keeping & laundry services to privately managed seniors housing.
© 2012 - 2018 Jones Corporate Group. The information contained in this website is for general information purposes only. The information is provided by Jones Corporate Group and while we endeavour to keep the information up to date and correct, we do not make any warranties about the completeness, reliability and accuracy of this information. Any reliance you place on such information is therefore strictly at your own risk.


The key to great off-duty style is to keep things as comfortable as possible while still looking put together. You never want to forget important factors like fit and quality, but come the weekend, you needn't be so buttoned up. Layer up instead with a military-style tee under a denim shirt, finished with a leather jacket. Complete the look with a pair of soft washed jeans and some comfortable boots, and you're set no matter where the weekend takes you.
This feature is brought to you by Timberland.


Epixode drops first official song to kick off the new year 2018. Titled "Single", the song revolves around guys and ladies who are single while warning married couples to stay off the singles. Quite a controversial topic presented by Epixode in an urban Afrobeats production with well written lyrics to complement his delivery. This song is the first song off his upcoming album due for relese in March this year. Listen, download & enjoy.


text:
NJIT President Recognized with Technology Award for Boosting Innovation by TechUnited
Published: Thursday, December 10, 2020
TechUnited collaborated with NJIT's Makerspace to manufacture the award.
In a virtual ceremony Dec. 9, NJIT President Joel S. Bloom was presented with the Martinson-Ballen Technology Supporter award by TechUnited. This award recognizes individuals who have demonstrated a significant impact and a long-standing contribution to New Jersey's technology and innovation industries.
TechUnited is a non-profit, membership-based organization that empowers entrepreneurs and innovators who are propelling the future for New Jersey and beyond. TechUnited helps turn ideas into action through its robust resource pool: access to thought leaders and their expertise, funding opportunities, networking and mentorship/internship programs, digital content and marketing assistance and other opportunities to its members.
"I can't think of a more deserving individual to win the 2020 Martinson-Ballen Technology Supporter Award," said Aaron Price, CEO of TechUnited. "For many years, Joel has been a demonstrable advocate of business and entrepreneurship opportunities through the advancement and application of new technologies. He leads a team at NJIT that showcase what New Jersey higher education can offer students, businesses and entrepreneurs."
"I am honored, and NJIT is proud to be part of this vibrant technology and innovation community," said President Bloom. "This award is a testament to our commitment to the advancement of new technologies and partnerships that spark innovation and economic development throughout New Jersey, the country and globally."
NJIT has deep roots in the innovation and startup sectors, namely through VentureLink@NJIT, New Jersey's largest and oldest business incubator, as well as technological and intellectual resources through New Jersey Innovation Institute, an NJIT corporation.
For more information on TechUnited, visit https://techunited.co/, and watch the video below to meet some of the other TechUnited winners.
WATCH: 2022 NJIT Accomplishments
NJIT Faculty Achievement Celebration Highlights Impactful Researchers, Gifted Instructors


text:
Хай ібн Якзан (   Живий, син Недре́много,  — «Філософ-самоучка», ) — перший арабський і перший філософський роман, написаний мавританським філософом і лікарем Ібн Туфайлем на початку XII століття в ісламській Іспанії. Роман написаний на честь самого раннього алегоричного оповідання і філософського роману під такою самою назвою, написаного Авіценной (Ібн Сіна) в XI столітті, хоча вони оповідали про різні історії.

Філософсько-містичний зміст відображений в назві роману — «Хай ібн Якзана» в перекладі з арабського означає «Живий, син Недре́много». Герой роману — Хай ібн Якзана — починає своє життя на безлюдному острові. Згідно з однією версій — він з числа тих, «хто народжується без батька і матері». За іншою — мати Хая, таємно народила його від якогось Якзана, кинула своє немовля в море, яке винесло його на берег безлюдного острова.

Немовля, що вигодуване газеллю й виросло серед диких звірів, намагається осмислити навколишній світ, спостерігаючи за природою. Він силою свого розуму поступово осягає основи світобудови і життєві закони. Далі він відправляється до інших людей, щоб роз'яснити істину. Однак люди не вникають в повчання Хая. Пізнавши людське суспільство з його хибними взаємовідносинами і помилковими уявленнями, Хай впадає у відчай в справі виправлення людей і повертається на свій відокремлений острів.

Роман «Хай ібн Якзана» справив значний вплив на арабську, перську та європейську літературу, після того, як був перекладений в 1671 році на латинську, а потім і на інші європейські мови. Ця робота також справила «величезний вплив» на класичну ісламську і на сучасну західну філософію, і стала однією з найважливіших книг, яка «сповістила про наукову революцію» і європейське просвітництво. Цей роман також вважається попередником європейського жанру роману виховання.

Література

Див. також

 Ібн Туфайль
 Ар-рису аль-Камілія фі-с-сира ан-надбав (Theologus Autodidactus)
 Ісламська література

Посилання

Примітки

Робінзонади
Філософські романи
Вікіпедія:Статті з іншим значенням на Вікіданих


The MV214 range of vertical machining centres with a 1524 x 700 x 610mm travels offers high speed, high power machining and a rigid cast iron frame with large X & Y travels on a compact footprint. A 2000Kg table load with choices of spindle options including 9,000 and 12,000 belt-drive along with 15,000rpm coupled spindles. Fanuc or Heidenhain CNC control options.


Our M&ITA Department consists of experts proficient in large scale project management, metering, data networks, databases and software.
As a Systems Integrator, we have completed projects in which we have integrated thousands of meters in central AMR/MDM Systems. With combined experience in the fields of Smart Metering, Smart Grids, Telecoms, IT and Security, we cover the most critical areas responsible for the integrity, reliability, efficiency and cost-effective operation of Telemetering and Data Management systems.
Both productive and test systems are based on ZFA Fröschl AMR/MDM software which is an open, scalable application that currently supports more than 250 different meter types.
We are an IBM Partner implementing MAXIMO asset management tools and solutions to assist clients with asset management tasks and operations, help them optimize their processes and maximize their ROI.
For Smart Metering projects, asset management provides the foundation for the initiation, planning, scheduling, execution and closing of construction works in Transmission and Ditsribution Networks.
We can provide tailor-made training courses covering all aspects and components of specific systems. Training can be provided at either the client's premises or in our training facilities.


text:
Q: How to test run an UPDATE statement in PostgreSQL? How can I test an UPDATE statement for example to see if it would work, for example if it would actually update rows etc?
Is there a way to simulate it easily?

A: You could always build up a sample database on SQL Fiddle and try out your update statements there.
Full disclosure: I am the author of sqlfiddle.com

A: Wrap it in a transaction, test the results with a SELECT and rollback at the end.
BEGIN;

UPDATE ...;

SELECT ...;

ROLLBACK;

A: Prepend your SQL UPDATE command with EXPLAIN [ref], and it will tell you how many lines will be affected by your command. And it will not perform the actual update.
This is much simpler than wrapping your command in a transaction. E.g.:
EXPLAIN UPDATE accounts SET balance = balance + 100.00 WHERE name = 'Alice';

A: Use a transaction to wrap your update statement and a select query (to test the update) and then always roll it back.
Example:
BEGIN;

UPDATE accounts SET balance = balance - 100.00
    WHERE name = 'Alice';

SELECT balance FROM accounts WHERE name = 'Alice';

ROLLBACK; -- << Important! Un-does your UPDATE statement above!

A transaction typically ends with a commit but since you're just testing and do not want the changes to be permanent you will just roll back.

A: With Postgres you can use the UPDATE clause RETURNING to show which rows have been modificated.
-- example data
CREATE TABLE data(id int, text text);
INSERT INTO DATA VALUES(1,'aaa'),(2,'bbb'),(3,'ccc'),(4,'ddd');

-- original data
SELECT * from data;

-- dry-run update
BEGIN;

UPDATE
  data
SET
  text = 'modified'
WHERE
  id > 2
RETURNING
  id, text;

ROLLBACK;

-- data after dry-run update
SELECT * from data;

A: Run the same check with a SELECT statement first: the rows returned by SELECT will be the rows modified by UPDATE

A: Given this simple update:
UPDATE Products
   SET price_including_vat = price * 1.05
 WHERE product_type = 'Food';

I would test it using something like this:
 SELECT price_including_vat AS price_including_vat__before,
        price * 1.05 AS price_including_vat__after,
        *
   FROM Products
 WHERE product_type = 'Food';

Actually, I'd proably engage brain and do analysis more like this:
WITH updated AS
   (
    SELECT price_including_vat AS price_including_vat__before,
           price * 1.05 AS price_including_vat__after,
           *
      FROM Products
    WHERE product_type = 'Food'
   )
SELECT *
  FROM updated
 WHERE price_including_vat__before = price_including_vat__after;


Mothers do influence their sons and daughters!
One of life's greatest blessings is to have a godly mother.
One of the greatest gifts you can give your children is to be a godly mother.
The bible tells us how Timothy was influenced by his mother and grandmother.
Who knows what lifelong influence Lois and Eunice had on the young man as he grew up?
Help us to be a good influence on our children. May they see our faith and, encouraged by it, learn to trust in you for themselves. We surrender their lives to your loving care, knowing that you have destined them for great things. Bring healing to every area of their lives, emotional or physical, and help them to see themselves as dearly loved and called to great works in your kingdom.
Quote | This entry was posted in Parenting, prayer, scriptures, Scriptures, Soul Meal - Bread of Life and tagged hope, parenting, prayer, scriptures, spiritual help, word of God. Bookmark the permalink.