Peter Rudd AIRPM: 80 Years Or Less On Your Lease? Then You Must Read This!
Leasehold Life is very proud to introduce new company, under80. who specialise in providing a tailored and bespoke service to leaseholders who have 80 years or less on their leases. Founded by Managing Director Colin Horton BSc (Hons), Head of Operations and co-founder Peter Rudd AIRPM, this article breaks down what happens when this crucial point is reached.
This a very significant point in a number of ways not least because the majority of leaseholders' anticipate the value of their asset to grow in line with the market. The reality though is that as the lease term depreciates, the market value will follow in a similar pattern. Once a lease is under 80 years the property begins to lose its value at a steady rate and will continue to do so until the lease is renewed. A large number of developments in the 80s were sold on leases of 99 years and this trend is becoming more and more common; so much so that it is now unusual to see new leases with anything in excess of 125 years. This movement means that during your leasehold ownership it is quite possible your term will expire to under 80 years; you may even have a short lease right now and not be aware of it.
A short lease can also cause a major problems in the saleability of the property. Extending your lease before a sale will bring the market value back up to its maximum potential but this can be a complicated matter to deal with, and when coupled with the possible loss of a sale this becomes even more so. Quite often the buyer, seller and estate agents are only made aware of the lease length when the solicitors are exchanging information, midway through the buying process. This can leave all parties in a fairly tricky situation as the property immediately becomes a security risk to the majority of mortgage providers. Although mortgage providers differ in their lending strategies there is one thing you can be certain of, a short lease will either prevent a buyer from securing a competitive mortgage or prevent the property from achieving financing at all.
When extending your lease you will almost always be doing so with a freeholder who is experienced in achieving the highest possible value from the arrangement. It is not uncommon for leaseholders to begin negotiations that end up being costly, time consuming and sometimes result in a lease that does not get extended at all! Leaseholders will often pay thousands of pounds more than they should do, either due to inexperience in the matter, or the lack of professional representation and available advice. It is essential to ensure you have a lease extension tailored to your needs so there are various different approaches you can take when starting the process. Some may be more suitable depending on whether you are selling, and others when you are remortgaging or simply looking to maintain the value in your leasehold property.
At under80 we deal with these scenarios on a daily basis and we're fully equipped to give you the assistance you need in getting the most out of your deal. Our unique approach is specifically tailored to your requirements, our team are experts in the field and they have spent many years negotiating on behalf of both leaseholders and freeholders. This puts us in an exceptional position to give you advice on a freeholders expectations in comparison to what you should actually be paying. Our extensive experience allows us to guide your lease extension in a direction that suits you. We can provide professional advice on the short lease valuation vs the long lease valuation, a realistic price range and what approach to take to minimise the possible loss of the sale.
Whether you're looking for guidance or full representation we are on hand to provide a bespoke and passionate service. Our goal is to ensure you get the lease extension that is right for you and to give you the peace of mind that the only thing being inflated is the length of your lease.


Top Stories: As evacuees from Sandy continue to be shuffled around, advocates for the homeless say that the storm "exposed and worsened the city's acute lack of affordable housing options."
World: Though there was talk that a cease-fire between Israel and Hamas might come, the fighting continued.
U.S.: In Maine, Massachusetts, and Rhode Island, so-called blue laws prevent retailers from opening on Thanksgivings.
New York: Antron McCray, one of the young men wrongly convicted in the Central Park jogger case, discusses his need to leave New York and seek anonymity.
Business: With the holiday rush hitting airports, it's worth noting that in recent years more flights are departing and landing on time—83 percent within 15 minutes of schedule this year.
Sports: For Belgium's national soccer team it's "a fact of life" that players do not speak the same language with the country divided between French and Flemish.
Opinion: Maureen Dowd on the Petraeus scandal and Gloria Allred, with some Jane Austen thrown in.
Art & Design: An expert on Edward Hopper is questioning how the Rev. Arthayer R. Sanborn, a Hopper family friend, came into possession of his collection of Hopper works.
Music: Jon Caramanica on Rihanna's new album, which features a collaboration with Chris Brown that "is, as it's called online, pure trolling: a straight-faced provocation that's really a big wink."
Dining & Wine: Ian Fisher on the deliciousness, and the difficulty, of pasta carbonara, a dish Calvin Trillin suggested should be swapped for Turkey on Thanksgiving.


Circle W Sports - The NEW name in the game for High School Sports!
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"One of the biggest things provided by Circle W Sports is the stats. It's not just this year's stats, it's also past year's stats. It's common that we aren't finding out about career milestones for athletes until right as they are happening, and in some cases after they happen. With the stats Circle W Sports keeps on their websites, that's not an issue."
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Rock 'n' Metal Tour News & Gig Reviews
TOUR NEWS ARCHIVE
TOUR NEWS ARCHIVE March 25, 2019
Possessed Announce London Headline Show
Hailed as the godfathers of the death metal genre, Possessed have announced a London headline show for June. Possessed have announced their return to UK shores this summer, playing a one off show at London's Underworld…
TOUR NEWS ARCHIVE March 6, 2019
Stone Temple Pilots Announce UK Tour Dates
Stone Temple Pilots have announced UK tour dates for this summer in support of their self-titled seventh album. Stone Temple Pilots have announced live dates in the UK and Europe which will take place around their…
TOUR NEWS ARCHIVE November 26, 2018
Papa Roach UK Tour Dates Announced
Californian rockers Papa Roach have announced an extensive "Who Do You Trust?" UK Tour for April 2019. Papa Roach have announced their longest UK tour to date in support of their 10th studio album "Who Do…
TOUR NEWS ARCHIVE October 30, 2018
KISS Announce 'End Of The Road' UK Tour Dates
American heavy rock legends KISS have announced details of the UK leg of their final ever world tour. KISS have announced they will embark on the aptly named 'End of the Road' global farewell tour in…
Bon Jovi Announce Summer 2019 UK Tour Dates
As part of a wider European tour, Bon Jovi will head out across the UK in the summer of 2019 with the Manic Street Preachers in support. Bon Jovi have announced a European tour in May,…
TOUR NEWS ARCHIVE September 24, 2018
Metallica Announce 2019 UK Stadium Tour Dates
Fresh off the back of a tour last year, Metallica have announced a European tour and a return to the UK in June next year. Metallica have taken the rock and metal world by surprise by…
TOUR NEWS ARCHIVE August 3, 2018
Behemoth Announce February 2019 UK Tour
Behemoth have announced a UK and European tour which will take place in early 2019. Polish blackened death metal outfit Behemoth have finally announced that they'll be making their return with the news of their eleventh…
TOUR NEWS ARCHIVE July 25, 2018
Blue Oyster Cult Announce 2019 UK Tour Dates
Iconic New York hard rockers Blue Öyster Cult have announced a UK tour for February 2019 with special guests The Temperance Movement. Over their four-decade career, Blue Öyster Cult have established themselves as one of the…
Uli Jon Roth Announces 50th Anniversary UK Tour Dates
Former Scorpions guitarist Uli Jon Roth has announced November and December UK tour dates to celebrate his 50th anniversary on stage. Former Scorpions guitarist Uli Jon Roth is widely regarded as one of the greatest guitar…
TOUR NEWS ARCHIVE July 6, 2018
Overkill Announce Killfest UK Tour Dates
New Jersey Thrash legends Overkill will tour the UK in March 2019 with Destruction, Flotsam and Jetsam and Meshiaak. Overkill have announced a 2019 European tour that will take in dates across the UK. They'll play…
TOUR NEWS ARCHIVE June 18, 2018
Soulfly Announce UK Tour Dates
Max Cavalera's Metal icons Soulfly have announced a clutch of UK dates this August around their festival appearance at Boomtown Fair. After a successful 18 months touring their 'Return to Roots' project together with his brother…
Black Stone Cherry Announce December Arena Tour Dates
Hot on the heels of their special guest slot to Guns n' Roses at Download Festival, Black Stone Cherry are excited to announce a UK headline tour for this December. Black Stone Cherry's current sixth studio…
Copyright © 2018. Hit The Lights. All rights reserved.

redpajama_set_name: RedPajamaCommonCrawl


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Scholar recollects Lincoln's words in call for unity
By Pat Gee
President Abraham Lincoln's words in 1865 have reached across time to counsel a country that is angry and deeply divided today across religious and political lines, says national best-selling author Ron C. White Jr.
The noted Lincoln scholar spoke on the need for conciliation between the political right and left Sunday at the Interfaith Alliance Hawaii's annual dinner. About 200 attendees at the Honpa Hongwanji Hawaii Betsuin closely followed White's discourse on Lincoln's famous speech, which urged "malice toward none" during the Civil War.
White's remarks on Lincoln's wisdom and compassion were based on one of his books, "Abraham Lincoln's Greatest Speech: The Second Inaugural," published in 2002.
"It was the most profound speech combining politics and religion ever delivered to the American public," he said. In it, Lincoln used inclusive language to remind them of what they had in common: "Both (the North and South) read the same Bible, and pray to the same God; and each invokes his aid against the other."
He said Lincoln attributed the best possible motives to both sides, "which is totally lacking in today's politics. He didn't demonize the enemies."
Instead of casting judgment and blame as politicians do today, White asked, "Is it possible in this atmosphere, can we people of religion, of faith, call for compassion, forgiveness, understanding, respect and appreciation?"
White quoted the last paragraph in Lincoln's address: "With malice toward none; with charity for all; with firmness in the right, as God gives us to see the right, let us strive on to finish the work we are in; to bind up the nation's wounds … to do all which may achieve and cherish a just, and a lasting peace, among ourselves, and with all nations."
President Barack Obama, who has often referred to Lincoln as his role model, has been roundly criticized by progressives for continuing to talk of conciliation and bipartisanship between Democrats and Republicans, even after the Democratic Party's drubbing in the recent election, White told the Star-Advertiser. But Obama reiterated the need to work together for the sake of the nation, and as he advocated in his 2008 election victory speech, White added.
The alliance also presented its 2010 Flame of Hope Award to Bishop Yoshiaki Fujitani of the Hawaii Kyodan and director of the Buddhist Study Center in Honolulu. He was commended for his involvement in interfaith activities, advocacy of social justice and for "touching countless lives through his Buddhist ministry."
Mary Adamski, former Honolulu Star-Bulletin religion writer, was presented with the first Special Recognition and Appreciation Award "especially for her long-standing, honest, unbiased reporting."
Other awards included:
» Healing Role in Hawaii Award — the American Friends Services Chapter Hawaii Region for grass-roots nonviolent civic participation.
» Encouraging Non-Violent Civic Participation Award — Nakem Youth.
» Facilitating Community Activism Award — Faith Action for Community Equity, which aids in resolving issues of safety in the workplace and neighborhood, housing and labor in the community.
» Challenging Religious or Political Extremism Award — The Parish of St. Clement, Episcopal.
'Centering prayer' retunes thoughts to inner harmony
Religion briefs


The park begin in Ourense and when it crosses the line separating it from Portugal, it becomes the Parque Peneda-Gerés... Here the forests know no borders.
Maybe that's why these are the lands of the Couto Mixto, a territory that never belonged either to Spain or to Portugal, and whose inhabitants chose their nationality they wanted on their wedding day.
A world of big trees, wolves, roe deer and wild horses that 2,000 years ago was already crossed over from north to south along the Via Nova built by the Romans to link Astorga and Braga.
The legions no longer pass through here but, instead, you can find lovely scenery in the towns and roads of the park. Wonders such as the A Fecha waterfalls, or amazing villages such as Casola, built on land with a 20% slope. And, also, unexpected findings such as "Cachena" cows, a small breed with huge horns.
The Limia is a unique river. It has excavated a natural corridor along which history has left its human traces. The river gathers up a mass of water which leaps down in waterfalls and cascades, rests in successive dams, crosses a border and finally gives up its waters to the Atlantic. In this way the largest Natural Park in our region is united with the most important Park in Portugal, the Peneda-Gerês National Park.
This is the "raia seca", for the border layout is not located around the rivers but high up in the mountains: O Laboreiro, Queguas and Quinxo in the north; Santa Eufemia, O Xurés and O Pisco, in the south. The highest peaks are 1,500 metres high and combine the smooth forms of the old Galician mountains with the most rugged peaks. Needles and bolos (granite stones), which time has balanced in complicated equilibrium, are one of the distinguishing marks of the area.
Here we will find megalithic monuments, legends of gold and evidence of the passing of the Roman soldiers along the XVIII or Vía Nova road. Still standing are the milestones that were left on the road that joined the Roman capitals of Braga and Astorga through the only natural way through these mountains, the mythical Portela do Home, border access point to Portuguese territory.
The traditional constructions like mills, walled beehives (alvarizas), shepherds' cabins (chivanas), raised granaries (hórreos), ovens, roads and walls reveal the most creative soul of its inhabitants. A heritage from the traditions still kept alive in the dozen villages which until the present day have kept agriculture and fishing alive in the Park. Villages like those of O Couto Mixto, the territory which, until 1868, had a statute of privilege independent of Spain and Portugal.
Before entering the Park, the OU-540 main access road provides visitors with the opportunity to stop and look at the historical heritage of the area.
Aquis Querquernnis is a Roman site made up of a camp and a mansio viaria located on the banks of the As Conchas, reservoir in the village of Bande. Close by we find the modern Interpretation Centre Aquae Querquennae - Via Nova. The pre-Romanesque church of Santa Comba de Bande is also in this area. Its nave and wallpaintings are a must for visitors.
In the Park there are routes by car which join the natural lookout points and important places, a route for horse riders and many rambling options, some quite demanding, over all of the mountains that make up the raia. Lobios, on the left side and Entrimo on the right, are the Park's main towns. The offices of the Interpretation Centre are located in the spa town of Lobios, with its thermal waters from the river Caldo.
In the same town and just a few metres away from the spa are located the Roman remains of the mansio Aquis Originis, which is open to visitors. Along the stretch of highway from Lobios to the border pass of Portela do Home the A Fecha waterfall, the highest in Galicia in the rainy season, can be seen in the distance, as well as many of the Roman road milestones.
From A Terrachá, the municipal capital of Entrimo, which has an interesting church with a baroque facade, there are turnoffs to the Queguas and O Quinxo mountains, such as the one to the village of Olelas, one of the best places to see cachena cows. This is native to the area, small with large horns and well adapted to the harsh mountain climate, and which in recent years has been rescued from the danger of extinction.
O Xurés has a wide range of scenery and life.
It is a transitional area between the Eurosiberian flora (Atlantic) and that of the Mediterranean, combined with altitude factors and the direction of the valleys; scrub on the peaks and forests of oak and other species in the valley, with important riverside forest.
Here, there are packs of wolves and their prey, also mountain goats and the Galician pony or garrano, reintroduced into the region under a programme of recuperation and reintroduction of native species.
Southwest of the province of Ourense, bordering Portugal. In the municipalities of Entrimo, Lobios and Muíños. The SCI also carries on into the municipalities of Padrenda, Quintela de Leirado, Verea, Bande, Calvos de Randín and Lobeira.
29,762 hectares. SCI: 34,248.13 hectares.
From Ourense, in the direction of Celanova and Portugal, on the OU-540. From Xinzo de Limia on the local OU-301 road to Bande.
Park headquarters, in Lobios. Tel. 988 448 048 and 988 448 181.
Interpretation Centre of the Natural Park, in Lobios. Tel. 988 448 048 and 988 448 181.
Aquae Querquennae- Via Nova Interpretation Centre, in Porto Quintela (Bande). Tel. 988 444 401.


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Bord na Móna believes strongly in supporting the communities we operate in – we have a rich heritage of community involvement
A significant aspect of the company's current community support is the Community Gain Funds. These schemes were established in collaboration with adjacent communities to our business developments, such as the Drehid Waste Management facility, and the Mountlucas and Bruckana wind farms.
The funds provide support to local clubs and societies, and could not have been established without the help and cooperation of the community around the developments. Local clubs, associations and other community groups apply for funding to help with various community based initiatives and improvement projects.
Drehid Community Gain Fund
The Drehid Community Gain Fund arose from the development of the Drehid Waste Management Facility by Bord na Móna in 2008. The purpose of the fund, and the associated grant scheme, is to identify and contribute towards the cost of the provision of appropriate environmental improvement and recreational or community amenities, facilities and projects in the locality which will mitigate the impact of the landfill facility on the local community in accordance with Government policy.
Since 2009, over 300 grants with a total value of approximately two million euro have been awarded to a variety of applicants in the general vicinity of the facility, including community groups, residents associations, youth and scout groups, sporting organisations, charities, tidy town committees, schools, environmental and heritage groups, etc.
The grant scheme is administered by Kildare County Council, and a community liaison committee assess the grant applications and makes recommendations in respect of funding. The committee comprises equal representation from the local elected representatives, the local authority, Bord na Móna and the local community.
Mountlucas and Bruckana Community Gain Funds
Bord na Móna set up two wind farm related community gain schemes in 2014 thanks to the help and cooperation of the communities local to its Mountlucas and Bruckana wind farms.
An annual fund, based on the installed capacity of each wind farm, is established and applications are sought from clubs, associations, and other such groups in the locality for support for various community-based initiatives and improvement projects. The combined funds amount to €125,000 per annum.
Bord na Móna administers each scheme and an awards committee is drawn from the local communities. This committee decides which projects are granted financial support. The funding has benefited schools, sports clubs, general amenity, social initiatives, as well as community facilities. Specific examples include Mount Lucas Community Development Group and the hand-ball alley in Walsh Island.
Community Gain at Daingean
Surrounded by the Bog of Allen, Daingean has a long association with Bord na Móna. Today, it is just one of many towns to benefit from Bord na Móna's Mountlucas Community Gain Scheme.
Bord na Móna's support has seen a significant improvement in the road infrastructure through the Co. Offaly town. "Our flagship projects are the Community Centre, the Town Hall, and part of the GAA facilities," said community activist Deloreen Brereton. Work is being done on the courthouse which is attached to the Town Hall. "There is a lot of history associated with this as it was designed by James Gandon, who also designed the Four Courts in Dublin," said Deloreen.
Other examples include fixed windows in the town's old school, assistance towards an astro turf covering in the playschool's playground, a subsidised music programme in the primary school, funding for the local women's group, a grant to buy a timing clock for the senior athletics club, and a grant towards the purchase of indoor bikes for the cycling club.
Wind Farms Community Gain Scheme Charter
Learn more about our Community Gain Scheme Charter here.


filmandtvstuff | Disney | Disney Figurines | Beauty and the Beast Lumiere Figurine "Ooh La La"
Celebrating the 25th anniversary of the Disney animated classic Beauty and the Beast, Jim Shore brings his signature artistic touch to this charming portrait of the ever elegant, always hospitable Lumiere. Made from resin. Unique variations should be expected as this product is hand painted. Packed in a branded gift box. Not a toy or children's product. Intended for adults only.


After a swift deliberation of less than 24 hours, the nine-person San Jose jury awarded Apple more than $1 billion dollars in it's lawsuit against Samsung, and awarded nothing to Samsung in their counter-suit.
Among the counts awarded are Samsung's willful infringement of 5 of 6 Apple patents, due in no small part to a multitude of documents from Samsung executives that clearly indicated their desire to copy certain design elements of the iPhone when the initial work was being done on their highly popular Galaxy-series of smartphones. Some documents even contained slides where prototypes were put side by side and contained suggestions on how to make the Galaxy more like the iPhone.
For Apple, the verdict was not about the money. It was about the pride and respect of it's products, it's innovation, the hard work of it's designers and employees, and it's core values as a company.
What remains to be seen is if Samsung acts quickly to change the design of Galaxy, even amidst it's inevitable fight to overturn the decision. Samsung believes that if this decision stands, it will mean fewer choices for the consumer, and stifled innovation by companies who may be afraid to also get sued by Apple.


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What Motions Are Available In Criminal Cases?
Motions to suppress illegally obtained confessions or items (like drugs, etc).
Florida Rule of Criminal Procedure 3.190 covers most of the common motions and their requirements, and additional authority for motions is found in Rules 3.131 and 3.132 (pretrial release and detention) and Rule 3.220 (discovery).
Note that not every case is factually driven such that a motion to suppress, or any other motion for that matter, can be filed. However, a creative attorney can find issues that merit motion practice. At Bodiford Law, P.A., we have the experience and expertise to determine what motions may be possible in a given case.
If you have a pending criminal matter, contact Bodiford Law, P.A., to discuss what motions may be available to help you in your case. Call our Tallahassee firm at 850-222-4529 (for existing clients) and 850-583-7381 (for new clients) or contact us online to schedule a free consultation with a lawyer.


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Bank of California v. Richardson
Tax Commission v. Balto. Nat. Bank
But this seems to be no more than the exemption applicable to federal agencies generally under the decision…
Fid. Guar. Fire Corp. v. Tax Commn
Mercantile Nat. Bank v. New York, 121 U.S. 138, 151, 7 S.Ct. 826, 30 L.Ed. 895, 900. In the Schuylkill case…
Full title:BANK OF CALIFORNIA, NATIONAL ASSOCIATION, v . RICHARDSON, TREASURER OF THE…
Court:U.S.
39 S. Ct. 165
ERROR TO THE SUPREME COURT OF THE STATE OF CALIFORNIA.
Submitted October 14, 1918. Decided January 27, 1919.
The extent to which the States may tax the property or the shares of national banks is determined exclusively by § 5219 of the Revised Statutes. P. 482. The object of the section is to avoid withdrawing the financial resources of national banks from the reach of state taxation, and at the same time to protect the banks as federal agencies from state interference. It therefore, with certain restrictions, permits the shares of the bank to be taxed to the shareholders, and, in that aspect treats the ultimate beneficial interest of the bank and the shareholders as one, subject to but one taxation and by that method only. P. 483. It follows, (1) that the interest represented by shares of a state bank, when held by a national bank, can be reached only by a tax upon the shares of the latter, and is not taxable to the national bank itself, and (2) that shares of a national bank, when held by another national bank, are taxable only to the latter as shareholder, and are not to be included in valuing the shares of the latter when taxing its shareholders. Pp. 484, 486. 175 Cal. 813, reversed.
THE case is stated in the opinion.
Mr. E.S. Pillsbury, Mr. F.D. Madison, Mr. Alfred Sutro and Mr. Oscar Sutro for plaintiff in error. Mr. A.D. Plaw was also on the brief.
The right to tax to the Bank of California the Mission State Bank shares is implied by the California Supreme Court solely upon the ground that its existence is essential to an exertion of the power to tax the Mills National Bank shares. The court does not deny that the shares of the state bank are personal property; nor does it find any express authority in the federal statute permitting the State to tax them to the Bank of California. But because shares in one national bank in the hands of another national bank may be taxed to the latter, Bank of Redemption v. Boston, 125 U.S. 60, the court below concludes that no different rule could be applied to the taxation of shares in a state bank owned by a national bank without violating the provision of § 5219 requiring other moneyed capital to be assessed at a rate equal to that imposed upon shares in national banks. But such an implication cannot be indulged, because the effect of § 5219, in limiting the power of the States to the right to tax the real property of national banks and their shares, is to prohibit the taxation of the property of those banks in any other manner. Raleigh Gaston R.R. Co. v. Reid, 13 Wall. 269, 270. The statute being unambiguous in its limitation, Owensboro National Bank v. Owensboro, 173 U.S. 664, 669, a power to tax the Bank of California for the state bank shares could only be implied if absolutely essential to the exercise of the right to tax it upon the shares of the Mills National Bank. Belmont Bridge v. Wheeling Bridge, 138 U.S. 287, 292; Austin v. The Aldermen, 7 Wall. 694, 699; Newton v. Commissioners, 100 U.S. 548, 561. But such an implied power is unnecessary. The value represented by the state bank shares might be taxed by the State, under the power conferred by § 5219, either by taxing the capital of the Mission Bank directly to the latter, ( Crocker v. Scott, 149 Cal. 575,) which the present state constitution expressly forbids; or by including the value of those shares in the assessment of the assets of the Bank of California, and taxing the value of those assets to the latter's shareholders, as is provided by the terms of the state constitution and statute, and as was done in the present case. But the State is without the power, under the federal statute, to tax their value directly to the Bank of California.
As the attempt to do this must fail, and as the state law does not permit any other taxation of their value except by including that value in the assets of the Bank of California, which is assessed to the latter's shareholders, the effect of that law is to tax the value of the shares of the Mission Bank, owned by the Bank of California, but once, while taxing the value of the Mills National Bank shares twice, once directly to the Bank of California, as a shareholder, and again by including their value in the assets of the Bank of California, upon which a tax is assessed against the latter's shareholders.
This method of taxation is in violation of the express provision of § 5219, forbidding discrimination against national bank shares. Mercantile Bank v. New York, 121 U.S. 138, 157.
Mr. U.S. Webb, Attorney General of the State of California, and Mr. Raymond Benjamin, Chief Deputy Attorney General of the State of California, for defendant in error:
It being conceded that the stock of all of these banks is primarily taxable to the shareholders, there can be no question of double taxation in the case. The plaintiff in its capacity as a stockholder is liable for the tax upon the Mills and Mission shares, which are held in its treasury in lieu of a certain amount of its capital, surplus or undivided profit. The stockholders of plaintiff, as such, have no right or title to any portion of this stock, their status being entirely distinct from the status of the corporation itself as stockholder. The tax paid by the plaintiff as a stockholder in no way concerns or affects the tax upon the value of the stock held by the plaintiff's stockholders.
The tax on the Mission Bank shares did not violate Rev. Stats., § 5219. In Bank of Redemption v. Boston, 125 U.S. 60, the decision did not turn solely upon the ground that the shares taxed were shares of a national bank. The statute intends not only to permit a State to tax all the shares of a national bank, but also to compel it to tax all shares of its own banks, without regard to ownership, for this is one of the mandates of the law which must be first obeyed to enable the State to tax the shares of national banks at all. The fundamental purpose was the protection of national banks in the matter of state taxation, and to compel the administration of even-handed justice. People v. Weaver, 100 U.S. 539-543; Mercantile Bank v. New York, 121 U.S. 154. The State must tax the moneyed capital in its state banks to the same extent as it taxes the shares of stock in national associations, and, in the enactment of the constitutional provision of California, a specific and uniform rule, applicable to both state and national bank stock, has been enacted.
If the shares of the Mission Bank owned by plaintiff are exempt from taxation, because they are personal property owned by a national bank, then, inasmuch as the moneyed capital of the Mission Bank cannot be taxed at the same rate as the tax levied upon the moneyed capital in national banks, it follows that the taxation of the shares of national banks, under the constitution of California, will be at a greater rate than is assessed upon other moneyed capital in the hands of individual citizens, in violation of the federal act.
Whether a State has or has not complied with the requirement of Congress in this particular is not to be determined from the face of the statute, but from its practical application and the results thereof. Davenport Bank v. Davenport, 123 U.S. 23.
Crocker v. Scott, 149 Cal. 575, cited by opposing counsel, dealt with a scheme of taxation which was superseded by the present state constitution.
MR. CHIEF JUSTICE WHITE delivered the opinion of the court.
Except as to real estate, which is taxed directly in the name of the owner, all the available resources of banks for the purposes of taxation are reached under the law of California, not by an immediate levy on the banks as the owner, but by annual assessment and tax thereon made by the State Board of Equalization against the stockholders of banks. The state law places the duty upon the banks to pay the tax assessed against their stockholders, with the obligation on the stockholders to repay, sanctioned by a right conferred upon the banks to sell the stock of any stockholder failing to refund.
The Bank of California, organized under the National Banking Law and established in San Francisco, commenced this suit to recover the amount of a tax, levied against its stockholders in 1915 under the law previously stated, which it had paid under protest claiming that the tax was not only unlawful under the state law but illegal under the law of the United States governing the right of a State to tax national banks and their stockholders. The case is here to review a judgment denying the right to recover, on the ground that the tax had been lawfully exacted under both the law of the State and that of the United States.
The decision below, in so far as it rested upon the state law, is binding and we put that subject out of view. To understand the contentions as to the law of the United States requires a brief statement of the tax levied and the particulars in which it is complained of. The capital of the bank was $8,500,000, evidenced by 85,000 shares of the par value of $100 each. D.O. Mills Company was a national bank established at Sacramento and the California Bank was a stockholder in that bank to the extent of 2,501 shares. The California Bank was also the owner of 1,001 shares of stock in the Mission Bank, a banking corporation organized under the state law and doing business in San Francisco. The Board of Equalization in 1915 fixed the value of all the assets of the California Bank at the sum of $15,775,252.67. The Board included in the assets making up this amount the stock standing in the name of the California Bank, both in the D.O. Mills National Bank and in the Mission State Bank; the first, the Mills National Bank stock, being computed as worth $625,546.30, and the second, the Mission State Bank stock, as worth $121,916.52.
Upon these valuations, the Board assessed the California Bank as a stockholder in the D.O. Mills National Bank and as a stockholder in the Mission State Bank for the shares of stock which it held in those banks, valuing each at the sum previously stated. Besides, the stockholders of the California National were assessed for the value of the assets of that bank, including in the amount the full value of the shares of stock owned by the bank in the Mills National and Mission State Banks.
The controversy grows out of the asserted illegality of the two-fold tax levied on the assessments of the California Bank as a stockholder in the Mills National Bank and in the Mission State Bank. Its solution depends upon the effect of Rev. Stats., § 5219, the text of which is in the margin.
"Nothing herein shall prevent all the shares in any association from being included in the valuation of the personal property of the owner or holder of such shares, in assessing taxes imposed by authority of the State within which the association is located; but the legislature of each State may determine and direct the manner and place of taxing all the shares of national banking associations located within the State, subject only to the two restrictions, that the taxation shall not be at a greater rate than is assessed upon other moneyed capital in the hands of individual citizens of such State, and that the shares of any national banking association owned by non-residents of any State shall be taxed in the city or town where the bank is located, and not elsewhere. Nothing herein shall be construed to exempt the real property of associations from either State, county, or municipal taxes, to the same extent, according to its value, as other real property is taxed."
Without considering some modifications made by the Act of February 10, 1868, c. 7, 15 Stat. 34, which are negligible for the purposes of the questions before us, the section is but the reproduction of a provision of § 41 of the Act of June 3, 1864, dealing with the organization of national banks. ( 13 Stat. 99, 112.) The forms of expression used in the section make it certain that in adopting it the legislative mind had in view the subject of how far the banking associations created were or should be made subject to state taxation, which presumably it was deemed necessary to deal with in view of the controversies growing out of the creation of the Bank of the United States and dealt with by decisions of this court. McCulloch v. Maryland, 4 Wheat. 316, 436; Osborn v. United States Bank, 9 Wheat. 738, 867; Weston v. Charleston, 2 Pet. 449.
There is also no doubt from the section that it was intended to comprehensively control the subject with which it dealt and thus to furnish the exclusive rule governing state taxation as to the federal agencies created as provided in the section. All possibility of dispute to the contrary is foreclosed by the decisions of this court. People v. Weaver, 100 U.S. 539; Mercantile Bank v. New York, 121 U.S. 138, 154; Owensboro National Bank v. Owensboro, 173 U.S. 664; Covington v. First National Bank, 198 U.S. 100.
Two provisions in apparent conflict were adopted. First, the absolute exclusion of power in the States to tax the banks, the national agencies created, so as to prevent all interference with their operations, the integrity of their assets, or the administrative governmental control over their affairs. Second, preservation of the taxing power of the several States so as to prevent any impairment thereof from arising from the existence of the national agencies created, to the end that the financial resources engaged in their development might not be withdrawn from the reach of state taxation, but on the contrary that every resource possessed by the banks as national agencies might in substance and effect remain liable to state taxation.
The first aim was attained by the non-recognition of any power whatever in the States to tax the federal agencies, the banks, except as to real estate specially provided for, and, therefore, the exclusion of all such powers. The second was reached by a recognition of the fact that, considered from the point of view of ultimate and beneficial interest, every available asset possessed or enjoyed by the banks would be owned by their stockholders and would be, therefore, reached by taxation of the stockholders as such. Full and express power on that subject was given, accompanied with a limitation preventing its exercise in a discriminatory manner, a power which again from its very limitation was exclusive of other methods of taxation and left, therefore, no room for taxation of the federal agency or its instrumentalities or essential accessories, except as recognized by the provision in question.
Let us come to consider whether the taxation in question was sanctioned by the act of Congress as thus understood. We do so, first, from the point of view of the twofold tax which was based on the ownership by the California Bank of stock in the D.O. Mills National Bank, and, second, as to the taxes which resulted from the ownership by the California Bank of stock in the Mission State Bank.
In Bank of Redemption v. Boston, 125 U.S. 60, it was determined that the stock held by one national bank in another is governed by the power to tax stockholders given by the statute. Hence, the circumstance of the ownership of the stock by the California Bank in the D.O. Mills National Bank in no way deflects the operation of the statute. This being the case, as the taxation of the California Bank as a stockholder in the Mills Bank conformed to the grant of power to tax stockholders of national banks, it results that the assessment for taxation made upon that basis was within the state authority and was rightly decided so to be.
But the principle upon which this rests inevitably leads to the further conclusion, that the inclusion of the stock ownership of the California Bank in the Mills Bank as an asset of the California Bank for the purpose of taxing the stockholders of the latter bank was a disregard of the provision as to taxing stockholders fixed by the statute.
Indeed, it is apparent that the use of the power conferred by the statute to tax the California Bank as a stockholders in the Mills National Bank, and in addition to avail of such stock ownership for the purpose of taxing the shareholders of the California Bank, was but to accept the statute on the one hand, and to exert on the other a power which could have no existence consistently with the statute. To say that the two taxes, the one levied on the bank as a stockholder in the Mills National Bank, and the other levied on the stockholders of the California Bank, were valid because a taxation of different persons, the California Bank on the one hand and the stockholders of the California Bank on the other, serves only to emphasize the plain disregard of the statute which would result from the enforcement of the taxes in question.
It is undoubted that the statute from the purely legal point of view, with the object of protecting the federal corporate agencies which it created from state burdens and securing the continued existence of such agencies despite the changing incidents of stock ownership, treated the banking corporations and their stockholders as different. But it is also undoubted that the statute for the purpose of preserving the state power of taxation, considering the subject from the point of view of ultimate beneficial interest, treated the stock interest, that is, the stockholder, and the bank as one and subject to one taxation by the methods which it provided.
Again, when the purposes of the statute are taken into view, the conclusion cannot be escaped that the transmutation of the stock interest of the California in the Mills Bank, into an asset of the California Bank subject to be taxed for the purpose of reaching its stockholders, is to overthrow the very fundamental ground upon which the taxation of stockholders must rest.
We do not stop to point out the double burden resulting from the taxation of the same value twice which the assessment manifested, as to do so could add no cogency to the violation of the one power to tax by the one prescribed method conferred by the statute and which was the sole measure of the state authority.
Coming to consider the tax on the California National Bank as a stockholder in the Mission State Bank, different considerations are controlling, since the provisions of the statute and the ruling in the Bank of Redemption Case, supra, both in letter and spirit apply only to stock ownership by a national bank in another national bank. It therefore follows that as the California National Bank was subject to state taxation as a federal agency only to the extent authorized by the statute, the taxation of that bank as a stockholder in the Mission State Bank was without the scope of the statute and beyond the power which it conferred.
But while this is true, it also follows that as the stock in the Mission Bank belonged to the California Bank and was part of its general assets embraced by the comprehensive power conferred to tax such assets in the absence of some provision of the statute to the contrary, which, as we have seen, was the case with regard to the stock held in the D.O. Mills National Bank, the assessment of the stock in the Mission Bank as an asset of the California Bank against its stockholders was within the scope of the grant given by the statute and was, therefore, valid.
From what we have said, it follows that the court below erred in refusing to order the refunding of the sum paid for the taxes levied on the assessment made against the stockholders of the California Bank for the value of the stock held by that bank in the D.O. Mills National Bank, and which had been assessed against the California Bank as a stockholder in the Mills Bank; and further erred in so far as it refused to decree a refund of the amount paid for the tax levied on the California Bank as the result of the assessment on that bank as a stockholder in the Mission State Bank. In these particulars, therefore, its decree must be, and is reversed. Our order, therefore, is
Reverse and remand for further proceedings not inconsistent with this opinion.
MR. JUSTICE PITNEY, dissenting.
Pursuant to the constitution and laws of California, the plaintiff in error, a national banking association located in that State, was required to pay the following three taxes for the year 1915:
(a) A tax upon the valuation of the shares of its own stock, assessed against the bank at its own request instead of being assessed in the names of its individual stockholders. Its shares are 85,000 in number, of the par value of $100 each ($8,500,000 in all), and were valued for taxation at the sum of $15,775,252.67; a valuation which took into account all the assets of plaintiff in error except the assessed value of its real estate (excluded pursuant to the provisions of the state constitution). Included in the estimate were the sum of $625,546.30, the valuation of 2,501 shares of stock of the Mills National Bank held by plaintiff in error, and the sum of $121,916.52, for the value of 1,001 shares of the Mission Bank (a state bank), likewise held by plaintiff in error. It appears that the Bank of California prior to February 5, 1910, was a state bank, and on that date was converted into a national association; and, being at that time a stockholder of the two other banks, was permitted, under § 5154, Rev. Stats., as it then stood, to continue to be such stockholder after becoming a national bank.
(b) A tax assessed directly against plaintiff in error as a stockholder of the Mills National, based upon the valuation already mentioned of 2,501 shares.
(c) A tax assessed directly against plaintiff in error as a stockholder in the Mission (state) Bank, based upon the above mentioned valuation of its 1,001 shares in that bank.
In an action brought by the California National against Richardson as state treasurer to recover a part of the taxes thus paid, the Supreme Court of the State, following its previous decision in Bank of California v. Roberts, 173 Cal. 398, denied recovery, and the case is brought here upon the ground that the state constitution and laws, in conformity to which the taxes were assessed, are repugnant to § 5219 of the Revised Statutes of the United States.
Sec. 5219. Nothing herein shall prevent all the shares in any association from being included in the valuation of the personal property of the owner or holder of such shares, in assessing taxes imposed by authority of the State within which the association is located; but the legislature of each State may determine and direct the manner and place of taxing all the shares of national banking associations located within the State, subject only to the two restrictions, that the taxation shall not be at a greater rate than is assessed upon other moneyed capital in the hands of individual citizens of such State, and that the shares of any national banking association owned by non-residents of any State shall be taxed in the city or town where the bank is located, and not elsewhere. Nothing herein shall be construed to exempt the real property of associations from either State, county, or municipal taxes, to the same extent, according to its value, as other real property is taxed.
This court now holds that while the California National was taxable as a stockholder in the Mills National Bank ( Bank of Redemption v. Boston, 125 U.S. 60), the other taxes imposed against plaintiff in error were repugnant to § 5219 in two respects: (1) In that the valuation of the Mills National shares ought to have been deducted from the estimate of the valuation of the California National shares in making an assessment against the stockholders of the latter bank; and (2) in that plaintiff in error, as a national bank, was not taxable at all as a stockholder in the state bank, and that the tax last mentioned above was altogether erroneous.
Upon the last point I understand the case to be controlled by the decision of this court in Owensboro National Bank v. Owensboro, 173 U.S. 664, where it was held that § 5219 had the effect of exempting not only the operations and franchises but the property of the national banks from state taxation, except as to their real estate. There are weighty considerations to the contrary, which seem not to have been called to the attention of the court in that case — certainly are not adverted to in the opinion — but it would serve no useful purpose to bring them into the present discussion. Therefore I take it to be settled that under § 5219 a national bank may not be taxed by a State with respect to its ownership of shares in another corporation except shares in another national bank.
The Supreme Court of California, in the Roberts Case, 173 Cal. 398, 405, held that since it was decided by this court in the case of Bank of Redemption v. Boston that § 5219 permits the taxation of the shares of a national bank in the hands of another national bank, a different rule could not be applied to the taxation of shares in a state bank owned by a national bank without violating that provision of § 5219 which prohibits the taxation of national bank shares at a greater rate than is assessed upon other moneyed capital. But this view seems to me untenable; it mistakes an exemption accorded to a particular holder of other moneyed capital for a restriction upon the rate of taxation that may be assessed upon other moneyed capital as a class of property. As we held in Amoskeag Savings Bank v. Purdy, 231 U.S. 373, 393, the language of § 5219 "prohibits discrimination against shareholders in national banks and in favor of the shareholders of competing institutions, but it does not require that the scheme of taxation shall be so arranged that the burden shall fall upon each and every shareholder alike, without distinction arising from circumstances personal to the individual." The nontaxability of state bank shares in the hands of a national bank is attributable to the character of the national bank as a taxpayer, not to the quality of the state bank shares as an object of taxation.
And of course I agree that the California National was taxable as a stockholder in the Mills National; it having been determined in Bank of Redemption v. Boston, 125 U.S. 60, 70, that § 5219 permits the taxation of a national bank owning shares of the capital stock of another national bank, by reason of that ownership, on the same footing with all other shareholders.
This brings us to the point of divergence.
I dissent from the conclusion that the taxation imposed directly upon the California National by reason of its ownership of Mills National shares entitled the stockholders of the former bank to have the estimated value of the Mills shares deducted from the estimate of their California shares.
I find no suggestion of a right to such deduction in the language of § 5219. It permits the inclusion of "all the shares . . . in the valuation of the personal property of the owner or holder of such shares," and leaves it to the legislature of each State to determine the manner and place of taxing them, "subject only to the two restrictions" which are particularly mentioned; and therefore, by necessary implication, free from all other restrictions.
The opinion seems to adopt the view that to treat the Mills National shares as assets of the California National Bank amounts to imposing a "twofold tax," a "double burden" or "two taxes" upon a single property interest. But if there are two taxes it is only because there are two banks, the stock in each of which is valued separately because the ownership is separate and distinct.
It is said that § 5219 regards the ultimate beneficial interest and treats the interest of the stockholder and that of the bank as one. I cannot accept this view, for several reasons in addition to the implied exclusion of restrictions other than those expressly mentioned in the section.
In the first place, the stockholder and the bank are entirely different entities, not merely in form but in substance; and this ought to be sufficient to rebut any inference that would rest upon an assumed identity in order to raise a limitation upon the already moderate scope of the scheme of taxation expressly prescribed.
In the second place, the property interest of the stockholder is, in a most substantial sense, different from that of the bank. The bank, if taxable with respect to its property, would be taxable upon all of its assets, saving any that might be expressly exempted. But the stockholders are in no proper sense the owners of the entire assets of the bank. Their interest, so far as they have any interest in the assets as such, is only in the residue that remains after payment of all outstanding liabilities. This is capable of enjoyment in possession only in the rare event of a winding-up and liquidation of the bank's affairs. Short of this, and as is true in the particular case of the California Bank, the interest of the stockholders is almost the opposite of a property interest in the assets themselves; it being confined to a right to have those assets employed in the current operations of a going concern of which they are only part proprietors, with the right to participate at proper intervals in the gains derived therefrom. Hence, while "book-value" — that is, the excess of assets over outstanding liabilities — may be laid hold of, as it appears to have been laid hold of in this case, as a convenient mode of estimating the value of the stock interest, not only is it a matter of familiar knowledge that such an estimate is a mere approximation, but it is entirely clear that both in law and in the common experience of mankind the beneficial interest of the stockholder in the concerns of the bank is very substantially different from the beneficial interest of the bank in its assets.
Thirdly, the distinction has been constantly recognized in the decisions of this court ever since the earliest establishment of the national banks. The court having in the year 1862 decided that a state tax, imposed upon a bank according to the valuation of its capital and surplus as upon the property of individual citizens, was invalid in so far as it was based upon an investment in the stocks, bonds, and securities of the United States themselves exempt from taxation by the State ( Bank of Commerce v. New York City, 2 Black, 620); and having held two years later that the same rule must be applied to a state tax imposed against a bank under another statute which made banks liable to "taxation on a valuation equal to the amount of their capital stock paid in or secured to be paid in, and their surplus earnings," etc., ( Bank Tax Case, 2 Wall. 200); the question was raised in the year 1865, in Van Allen v. The Assessors, 3 Wall. 573, 584, etc., whether under § 41 of the National Bank Act of June 3, 1864, c. 106, 13 Stat. 99, 112, from which the present § 5219, Rev. Stats., is derived, a State possessed the power to authorize the taxation of shares of national banks in the hands of stockholders where the capital was wholly invested in stock and bonds of the United States. Bank of Commerce v. New York City, 2 Black, 620, and Bank Tax Case, 2 Wall. 200, were referred to as calling for a negative answer; but the court sustained the tax upon the ground of the very distinction between the stockholders and the bank that is now under consideration, the language of the opinion being (pp. 583, 584): "The tax on the shares is not a tax on the capital of the bank. The corporation is the legal owner of all the property of the bank, real and personal; and within the powers conferred upon it by the charter, and for the purposes for which it was created, can deal with the corporate property as absolutely as a private individual can deal with his own. This is familiar law, and will be found in every work that may be opened on the subject of corporations. . . . The interest of the shareholder entitles him to participate in the net profits earned by the bank in the employment of its capital, during the existence of its charter, in proportion to the number of his shares; and, upon its dissolution or termination, to his proportion of the property that may remain of the corporation after the payment of its debts. This is a distinct independent interest or property, held by the shareholder like any other property that may belong to him. Now, it is this interest which the act of Congress has left subject to taxation by the States, under the limitations prescribed."
In the same case, the court found in the context of the National Bank Act most cogent reasons for holding that Congress intended to permit the States to tax the entire interest of the stockholder, without regard to the character of the investments held by the bank. After referring to certain of the provisions of the act respecting the amount of the capital stock, its division into shares, and the responsibility of the shareholders for the debts of the bank, the opinion proceeds as follows (pp. 587-588): "In view of these several provisions, in which the term shares, and shareholders, are mentioned, and the clear and obvious meaning of the term in the connection in which it is found, namely, the whole of the interest in the shares and of the shareholders; when the statute provides, that nothing in this act shall be construed to prevent all the shares in any of the said associations, c., from being included in the valuation of the personal property of any person or corporation in the assessment of taxes imposed by state authority, c., can there be a doubt but that the term `shares,' as used in this connection, means the same interest as when used in the other portions of the act? Take, for examples, the use of the term in the certificate of the numbers of shares in the articles of association, in the division of the capital stock into shares of one hundred dollars each; in the personal liability clause, which subjects the shareholder to an amount, and, in addition, to the amount invested in such shares; in the election of directors, and in deciding all questions at meetings of the stockholders, each share is entitled to one vote; in regulations of the payments of the shares subscribed; and, finally, in the list of shares kept for the inspection of the State assessors. In all these instances, it is manifest that the term as used means the entire interest of the shareholder; and it would be singular, if in the use of the term in the connection of State taxation, Congress intended a totally different meaning, without any indication of such intent. This is an answer to the argument that the term, as used here, means only the interest of the shareholder as representing the portion of the capital, if any, not invested in the bonds of the government, and that the State assessors must institute an inquiry into the investment of the capital of the bank, and ascertain what portion is invested in these bonds, and make a discrimination in the assessment of the shares. If Congress had intended any such discrimination, it would have been an easy matter to have said so. Certainly, so grave and important a change in the use of this term, if so intended, would not have been left to judicial construction. Upon the whole, after the maturest consideration which we have been able to give to this case, we are satisfied that the States possess the power to tax the whole of the interest of the shareholder in the shares held by him in these associations, within the limit prescribed by the act authorizing their organization."
This distinction between bank and shareholder has been recognized consistently in the decisions of this court from that time until the present. It will not be necessary to analyze the cases, since the principal ones ( People v. Commissioners, 4 Wall. 244, 258; National Bank v. Commonwealth, 9 Wall. 353, 359; Farrington v. Tennessee, 95 U.S. 679, 687; Tennessee v. Whitworth, 117 U.S. 129, 136; Bank of Commerce v. Tennessee, 161 U.S. 134, 146; New Orleans v. Citizens' Bank, 167 U.S. 371, 402;) were summarized and quoted from in the opinion of the court in Owensboro National Bank v. Owensboro, 173 U.S. 664, 677-682, where the distinction was employed to demonstrate the substantial want of equivalency either in law or in fact between a tax on the franchise or property of the bank, such as had been imposed by the State in that case, and a tax upon the shares of stock in the names of the shareholders, permitted by § 5219, Rev. Stats.
The solid basis of the distinction may be further emphasized by considering the practical effect of according to the stockholders of the California Bank, in the estimation of the value of their shares for the purpose of taxation, a deduction of the entire value of the stock held by this bank in the Mills National. This value, according to the admitted facts, is $625,546.30, which is about 4 per cent. of $15,775,252.67, the entire estimated value of the 85,000 shares of California National stock (excluding real estate from the computation). It is incorrect to take the latter sum as the value of all the assets of the California National. There is nothing in the record to show the value of its entire assets; but as the case comes before us as on a demurrer to plaintiff in error's own pleading, and since the $15,775,252.67 represents but the excess of its assets over its outstanding liabilities, it is reasonable to assume that the entire assets are much greater; it being evident that there must be assets to counterbalance all outstanding liabilities, including especially the amounts due to depositors. Let us take, for illustration, the very moderate assumption that plaintiff in error's total assets were four times as much as its capital and surplus or, say, $63,000,000. Of this amount, the valuation of the Mills National stock is less than one per cent. In other words, applying the theory of the prevailing opinion, the fact that one per cent. of its total assets is in the form of shares in another national bank entitles its own stockholders to an abatement amounting to four times that percentage, or about 4 per cent., from the valuation of their stockholding interest in the plaintiff in error's bank. And it is easy to see that, upon the same theory, if the shares held by one national bank in another were equal in value to the aggregate of its own shares, although constituting but a small fraction of its entire assets, its shareholders would escape taxation altogether, although participating in the profits of two banking institutions.
According to its Report of Resources and Liabilities at close of business September 2, 1915, plaintiff in error had total resources of $67,396,982. Report of Comptroller of Currency, 1915, vol. 2, p. 585.
As we have seen, the decisions of this court establish that under § 5219 the holder of shares in a national bank is not entitled to have the estimate of their taxable value reduced by reason of the fact that the capital and surplus of the bank are invested in securities that are exempted from state taxation. It also is clear that while the section in terms permits the real property of the bank to be taxed against it, this does not entitle the shareholder to an allowance from the assessed value of his shares by reason of the fact that the bank is thus taxed. It is true that many of the States, when authorizing the taxation of real estate against the bank, make an allowance for this by deducting the value thus taxed when computing the amount at which the shares shall be taxed; but this is not because of any requirement in the federal statute. In Commercial Bank v. Chambers, 182 U.S. 556, 561, this court expressly so held with respect to a claim for a deduction from the value of national bank shares because of real estate owned by the bank situate outside of the taxing State. In People's National Bank v. Marye, 107 F. 570, 579, it was held that § 5219 contemplates that the tax on real estate may be imposed independently of the tax upon the share of the stockholder (affirmed upon another ground, 191 U.S. 272). And in Amoskeag Savings Bank v. Purdy, 231 U.S. 373, we sustained a tax imposed upon a shareholder under a statute that, while not exempting the real estate of the bank situate in the same State, allowed no deduction of its value in the computation of the taxable value of the shares.
It seems to me that to allow a deduction from the taxable value of national bank shares because the bank happens to hold stock in another national bank is not only contrary to the clear intent of § 5219, but is inconsistent with all previous decisions of this court bearing upon the point, especially those that have denied a similar deduction because of tax-exempt securities held by the bank, or because of real estate taxed against it.
MR. JUSTICE BRANDEIS and MR. JUSTICE CLARKE concur in this dissent.


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Growth-factor antibody may treat chronic lung disease affecting premature infants
WEBWIRE – Thursday, April 5, 2007
Researchers from Massachusetts General Hospital, in collaboration with scientists from the Genzyme Corporation, have identified a potential treatment for a chronic lung disease affecting premature infants. In a study to appear in the American Journal of Physiology - Lung Cellular and Molecular Physiology, which has received early online release, the scientists find that the activity of transforming growth factor-beta (TGF-beta, a protein that controls many essential cellular functions) is elevated in the lungs of an animal model of bronchopulmonary dysplasia and that treatment with an antibody to TGF-beta both decreased the growth factor's activity and improved lung development.
"Our findings show for the first time that TGF-beta is a major player in causing bronchopulmonary dysplasia and that inhibiting its activity in the injured newborn lung may decrease the severity or incidence of this disease," says Jesse Roberts Jr., MD, of the MGH departments of Anesthesia and Pediatrics and the Cardiovascular Research Center, the paper's senior author. "Since bronchopulmonary dysplasia is the most significant lung disease of premature infants, these results are very exciting."
Bronchopulmonary dysplasia (BPD) affects about 15 percent of premature infants, resulting in chronic lung disease in 10,000 to 20,000 infants in the U.S. each year, and is often caused by the mechanical ventilation and oxygen therapy required for their survival. Since BPD is more common in the most premature infants - affecting nearly 65 percent of those with a birth weight less than 1 pound, 10 ounces - its incidence has increased as more of the tiniest infants are surviving. The lung damage produced by BPD is usually chronic, requiring long-term treatment and frequently affecting growth and neurological development. BPD is second only to asthma as the most costly disease of children in the U.S., and infants with BPD who survive can have lung disease into adulthood.
Previous studies have shown that TGF-beta helps regulate early fetal lung development, but its direct role in the maturation of pulmonary structures disrupted by BPD has not been known. Since research at other centers has suggested that elevated TGF-beta levels might interfere with later lung development, the MGH-led team investigated that possibility and its potential relationship to BPD. A group of pregnant mice received injections of either an antibody against TGF-beta or a control substance a few days before giving birth. Their offspring were housed in either normal air or 85 percent oxygen, a concentration known to cause BPD in mice, for 10 days after birth.
The newborn mice exposed to high oxygen levels without the neutralizing antibody treatment were found to have elevated TGF-beta activity in the peripheral regions of their lungs. Those mice also had incomplete development of the lung structures called alveoli and the tiny pulmonary blood vessels where gases are exchanged between the airway and the bloodstream, a deficit typically seen in BPD. The mice that also received the TGF-beta neutralizing antibody had significantly lower levels of growth factor activity and much more normal lung development. Moreover, the improved lung development of the mice exposed to high levels of oxygen and treated with the neutralizing antibody was also associated with improved body growth. Those mice grew at a rate virtually identical to that of the animals that breathed normal air. Mice not treated with the antibody and exposed to elevated oxygen weighed 30 percent less than the air-breathing control group did at 10 days old.
"These findings need to be confirmed in other models of this disease, and the treatment's safety needs to be evaluated before we can plan a clinical trial, but it's quite possible that this therapy will help us treat these very sick babies," Roberts says. "It also is not far-fetched that TGF-beta-neutralizing therapies might have therapeutic potential in other human diseases. Studies are underway right now at our center and several others to evaluate that possibility." Roberts is an associate professor of Anaesthesia (Pediatrics) at Harvard Medical School and a neonatologist and pediatric anesthesiologist at the MassGeneral Hospital for Children.
The use of TGF-beta antibody to treat BPD was co-invented by Roberts and study co-author James Streisand, MD, an MGH anesthesiologist and clinical scientist at Genzyme Corporation; and the invention has been patented by the MGH and Genzyme. Additional co-authors of the study are first authors Hidekiko Nakanishi, MD, and Takahiro Sigiura, MD, PhD, of MGH Anesthesia and the CVRC, and Scott Lonning, PhD, of Genzyme. The study was supported by a Genzyme - Partners HealthCare Award for Translational Research.
Massachusetts General Hospital, established in 1811, is the original and largest teaching hospital of Harvard Medical School. The MGH conducts the largest hospital-based research program in the United States, with an annual research budget of nearly $500 million and major research centers in AIDS, cardiovascular research, cancer, computational and integrative biology, cutaneous biology, human genetics, medical imaging, neurodegenerative disorders, regenerative medicine, transplantation biology and photomedicine. MGH and Brigham and Women's Hospital are founding members of Partners HealthCare HealthCare System, a Boston-based integrated health care delivery system.
Supplementary Medicine / Nutrition
Youth / Children


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Wave of self-reliance sweeps the world but misses me
Nury Vittachi
This columnist once watched a 60-minute BBC TV documentary on the railways of Lahore simply because the remote control was on another chair. Heartless...
This columnist once watched a 60-minute BBC TV documentary on the railways of Lahore simply because the remote control was on another chair. Heartless people call this "laziness", but I prefer "terminal indolence", which sounds more medical.
In a bid to encourage this writer to be more active, colleagues pointed out that a noble, dramatic wave of self-reliance is sweeping the world at the moment.
It started with a video report from China a few days ago showing a woman out shopping for food. She paused for a moment and gave birth to a baby, which fell to the floor. She never even sat down. Onlookers in the city of Yunfu called an ambulance and paramedics but she waved them away and walked home, baby in one hand and shopping in the other.
Just imagine the conversation. Husband: "What did you get?" Wife: "Four carrots, a baby, and some bananas." Husband: "Good, I like bananas."
The wave of self-reliance spread to the US. On April 2, a car hit a woman, sending her flying. She picked herself up, refused an ambulance and drove herself to the hospital, the Tennessee press reported. On the same day, a man in Las Vegas was shot – but also drove himself to hospital, according to the local radio news.
This is a bit worrying, conjuring up a vision of US highways being filled with motorists zooming along while severely injured. "Oops, sorry for crashing into you, someone shot my head off so I can't see anything." "No problem, bud."
Self-reliance was demonstrated in Southeast Asia at the same time too. An economy passenger on a Kuala Lumpur to Hong Kong flight upgraded herself. The flight attendant sent her back, but she sneaked forwards three times. Eventually the passengers in the expensive seats shouted at her to go back. This seems unfair, since she was doing no harm to them besides damaging their elitism.
I told colleagues that these were trivial examples compared to the ultimate do-it-yourself tale. Jadav Payeng of Assam moved to a large sandbar in a river. He spent 30 years planting trees and eventually turned it into a new forest 1,360 acres in size. (An acre is about the size of a soccer pitch.) The forest was so successful that tigers and elephants now share it with him.
And possibly the worst do-it-yourself true story is that of Oscar Taylor of California. He performed a surgical operation on himself in 1909. He died and his family members didn't even have a doctor to sue, so they missed an important US tradition.
When I got home, I discovered that my kids were watching a viral video about a dog named Drewbert who was playing "fetch" with himself. Owner Jialu Wong was busy so the dog threw his own ball and fetched it.
But going back to where this started, one of my kids told me that modern people no longer used TV remote controls. They changed channels by giving voice commands to their Alexa electronic assistants.
So basically, they're agreeing with me: Reaching for the remote and pressing a button is just too much work, right?
BBC TV documentary


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text:
En la mitología griega, Zeuxipo (Griego antiguo: Ζεύξιππος) era hijo de Apolo y de la ninfa Silis (hija de Hilo y Iole). Sucedió a Festo como rey de Sición. Fue sucedido por Hipólito.

Mitología
Zeuxipo aparece en los escritos de Pausanias "Descripción de Grecia":"Después de Festo en la obediencia a un oráculo emigraron a Creta, el siguiente rey se dice que ha sido Zeuxipo, el hijo de Apolo y de la ninfa Silis. En la muerte de Zeuxipo, Agamenón dirigió un ejército contra Sición y contra el rey Hipólito, el hijo de Rópalo, el hijo de Festo."

Referencias

Descendientes de Apolo
Personajes de la mitología griega

redpajama_set_name: RedPajamaWikipedia


A collection of Thank You SMS, Thank You Wishes, Thank You Messages, Thank You Quotes collection here. We have variuous type of Thank You messages like Romantic Thank You SMS, Thank You SMS in Hindi, Thank You SMS in English. Thankyou sms messages are usually sent as a thank you greeting. Some people like to send funny thank you jokes, some prefer to send thank you text messages in their native languages i.e urdu or hindi. Every one is suppose to send a thank you love sms> or a sweet / romantic thank you sms when his/her lover has done something for him/her.


text:
Latest NBA Leads
James Harden Is Soft in Body and Spirit
By Kyle Koster | Jan 13, 2021, 9:02 AM EST
Carmen Mandato/Getty Images
James Harden is the hero of his own story, the only pages in which he can find vindication right now. Like any author stricken with myopia, he's trying to write himself out of the corner he finds himself in. Watching him run into dead ends, mix metaphors, and unable to find the right words to bring the reader aboard his train of thought feels hauntingly familiar.
He won't stop until he pulls the Houston Rockets — a franchise he helped soar to great heights — crash back down to the Earth. Harden showed up late and overweight. His trade demands have been public and not at all subtle. There hasn't been a face-saving attempt at reconciliation, even a hollow one.
Friction rose to a spark-shooting level after the Rockets' 117-100 loss to the Los Angeles Lakers. A dejected superstar sat with a hang-dog look and assessed the situation he's responsible for creating.
"I love this city. I literally have done everything that I can," he said. "I mean, this situation is crazy. It's something that I don't think can be fixed."
At some point, perhaps later this month, we should have a national fireside chat about what the word literally means. Because Harden hasn't literally done everything he can. It's a situation that may be irreparable but a very obvious and helpful option would be to suffer about three notches more quietly and not try to actively detonate all available explosive devices to get what he wants and get it right now. He doesn't have to grin and bear it, he could simply bare it with less public grievance.
"We're not even close, honestly, to that team -- obviously the defending champions -- and all the other elite teams out there," he continued. "I mean, you can tell the difference in these last two games. We're just not good enough -- chemistry, talentwise, just everything. And it was clear these last two games."
This may all be true. The Rockets are 3-6 and appear rudderless and listless. Yet it's worth wondering how much of that is self-fulfilling prophesy. Those defending Harden's on-court contributions may not notice that he's averaging almost 10 points per game fewer than last year. That's he's shooting a quarter less than he has over the past few years. And, it should go without saying, that his attitude has an impact.
John Wall, brought in to be a Robin to a Batman, has already seen the so-called hero unmasked and revealed as a bit of modern Bruce Wayne. Wall admitted things have been rocky and didn't sound entirely hopeful amid last night's mess.
Harden is being paid over $41 million this year. His professional problems pale in comparison to those facing the average fan in a normal year, let alone one with a society-crippling pandemic not yet at its apex. Is he so disconnected from reality that he doesn't understand how much he's alienating himself from the mean? Does he not realize how tone-deaf and toxic he's actions are making him, and at quickening pace?
We're left to conclude that he doesn't. Because if he did, he'd change course.
It's not fair to criticize without self-reflection. And I understand that some of the ranting above come off like a smooth-brained sports-talk caller who wants to rail on an athlete. It's not a pleasurable thing to do, especially for someone like myself who believes in player empowerment and has found the traditional machismo lens through which we experience sports small-minded and unhelpful.
But even with this preamble, here comes the pitch.
Harden is soft in composition and soft in resolve. It's unpleasant to watch as a neutral observer and has to be maddening for invested parties. He has not literally done everything he can for the city. He's essentially quit and thrown a fit until he can get his way. The Rockets may not be fixable.
Is Harden?


Published: Sep 21, 2018 at 12:26 p.m.
Updated: Sep 24, 2018 at 3:29 p.m.
WOLFVILLE. N.S. - Over the early summer months, Allie Berry patiently waited to hear about extending her basketball career after her graduation from Acadia this past spring.
From Yarmouth, N.S., Berry was an AUS All-Star and named to the AUS Championship Tournament All-Star team this past season. She had reached the end of her playing career as most university women's basketball players settle for, but she didn't settle on just university basketball. The opportunity for women to continue to play basketball in the professional ranks has grown immensely.
With the help of former Axewomen powerhouse Abbey Duinker, Berry was able to find somewhere to extend her playing career.
"Abbey helped me find some contacts overseas. She had been playing over there for a few years. She was a great help. Coach Harvey helped me put together a video, which was sent to my agent. He also helped me with what questions I should ask about how it all worked. After everything was sent it became a waiting game to see if I would get a contract," noted Berry.
"Two days before I left for Italy my agent called with a contract to play in Germany and if I accepted then I would fly from Italy after the tournament to Germany. I accepted the contract and have been in Germany since August 20th," said Berry.
"Allie is a testament to putting in hard work on and off the court. She developed so much as a student, an athlete, and a community leader during her time here at Acadia, but it all stemmed from her work ethic and positive attitude. We are over the moon for her and the opportunities she earned overseas," said Axewomen head coach Len Harvey on Berry's opportunity in Germany.
"I think Allie is a fine example to the current players here in Wolfville, but also at other schools, that with hard work and dedication you can continue to play basketball after your university eligibility is done. I look forward to her text messages every day about something new she learned, saw, or experienced. I know she has plenty of fans cheering her on here at home, we're all incredibly proud of her," added Harvey.
"I play in Division 2 and the play at this level is strong. It is important to stay fit and healthy in order to be competitive. It has been a great experience so far," said Berry in an e-mail.


In tip 1199, Leon Tribe talked about the power of using variables in Microsoft Flow. Leon astutely pointed out that using variables can simplify process development by allowing reuse of values between steps in Flow, and they can also be used for calculation purposes and building strings.
One challenge with working with integer type variables in Flow from a CDS/Dynamics 365 perspective is that you cannot directly write the value from an integer variable into a Dynamics 365 field.
Recently I created a Flow to calculate a contact score based on data quality–more about this in a future tip. As part of this flow, I created an integer variable called "score" to be used to calculate the data quality score.
At the end of the Flow when I wanted to update the contact with the data quality score, I tried the three types of number fields in Dynamics 365/CDS–whole number, floating point, and decimal. The variable was being calculated, but I could not get the flow to update any standard number field (or text field) with the value of the integer variable.
The solution was to use the int() transformation expression. By using the expression int(variables('score')), I was able to update a decimal number field in Dynamics 365 with the value of my integer variable.


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Council protects and maintains more than 14,500 street trees in the Dubbo urban area. Street trees play a major role our urban environment by absorbing heat, providing shade and reducing solar radiation. They also assist in noise reduction and air purification.
If you have a request for planting, pruning and removal of trees on Council land, contact us. The tree will be assessed and any necessary work will be carried out by our staff.
Council does not prune trees for power line clearance. Essential Energy is responsible for pruning street trees in these circumstances and sets out the required clearance for its power lines. Please visit the Essential Energy website for more information.
If you would like to ringbark, cut down, top, lop, and/or remove a tree from your property but aren't sure if it's permissible, you can consult the Significant Tree Register. This register is intended to preserve trees and groups of trees which are attached additional values that make them "significant". For example, it may be a remnant of a previous landscape, have been planted by a famous person, be rare or an endangered species, or be of cultural or aesthetic value. If the tree in question is listed on the register, contact us to discuss further.
The Dubbo Street Tree Master Plan is a strategic planning document that provides a clear direction in improving the quality and extent of our urban forest over time. To assist in the use of this document it has been provided in three booklets.
APPENDIX 1 of this document provides a prioritised planting plan (1-10) for the planting/replanting of trees across the City and the associated list of streets and approximate tree numbers for each.
APPENDIX 2 consists of a spreadsheet that identifies the proposed Tree Species by Street. Each street has been assessed and a maximum of three (3) suitable tree species identified for it.
An important component of the implementation of this Dubbo Street Tree Master Plan is community consultation with the residents of each street being given the opportunity to identify their preferred tree species (as shown in appendix 2) leading up to the planning/replanting of the streetscape. This consultation will be done through a voting system with the tree species collecting the most votes being planted.
This document provides fact sheets for approximately 100 tree species identified within the Trees by Street spreadsheet. This booklet will provide the backbone of the information that will be sent out to residents during the community consultation phase for individual street tree planting.
A tree species selection matrix. Approximately 250 trees have been assessed and graded against 15 criteria to assist in the identification of suitable trees for Dubbo.
Street Typology drawings that identify the hierarchy of streets within the City of Dubbo and suitable planting solutions.
The Tree Protection Zones, as identified under the Australian Standard (AS 4970 - 2009).


text:
using Susanoo.Mapping;
using Susanoo.Processing;
using System;
using System.Collections;
using System.Collections.Generic;
using System.Data.Common;
using System.Linq;

namespace Susanoo.Deserialization
{
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    {
        /// <summary>
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        /// <returns><c>true</c> if this instance can deserialize; otherwise, <c>false</c>.</returns>
        public bool CanDeserialize(Type type)
        {
            return SusanooCommander.GetDbType(type) != null;
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redpajama_set_name: RedPajamaGithub