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4.36.3 Examination Team Responsibilities
4.36.3.1 Introduction
4.36.3.2 Examination Procedures
4.36.3.2.1 Case Identification
4.36.3.2.2 Claim Filed During Examination
4.36.3.2.3 Discovery that Report Was Not Prepared
4.36.3.2.4 Claim Filed for Previously Examined Year
4.36.3.2.5 Information Given to Taxpayer
4.36.3.2.6 Form 870
4.36.3.2.6.1 Assessment Prior to Review
4.36.3.2.7 Refund Prior to Review
4.36.3.2.8 Restricted Interest
4.36.3.2.9 Claim Disallowance In Agreed Cases
4.36.3.3 Types of Joint Committee Reviews
4.36.3.3.1 JC Electronic Case Reviews (LB&I except for IIC)
4.36.3.3.2 JC Physical Case Reviews (SB/SE, TE/GE, and LB&Is IIC)
4.36.3.3.2.1 Case Processing After JCT Clearance - JC Electronic Case Review
4.36.3.4 Survey After Assignment Criteria
4.36.3.4.1 Survey Documentation
4.36.3.4.2 Survey Forms
4.36.3.4.3 Procedural Requirements Survey Cases
4.36.3.4.4 Refund Counsel Inquiries on Survey Cases
4.36.3.5 Statute of Limitations
4.36.3.5.1 Restricted Consents
4.36.3.5.2 Alpha Statutes
4.36.3.5.3 Examination Action on Short Statutes
4.36.3.5.4 Statute Control During Review and JC Report Process
4.36.3.6 Documentation Requirements
4.36.3.6.1 Revenue Agent's Report (RAR) Requirements
4.36.3.6.2 Closing Agreements
4.36.3.6.2.1 Competent Authority
4.36.3.6.2.2 Advance Pricing Agreements (APAs)
4.36.3.6.3 Compliance Assurance Process (CAP)
4.36.3.6.4 Taxpayer Information - Report Transmittal Requirements
4.36.3.6.4.1 Contact Information - Examination Team
4.36.3.6.4.2 Short Taxable Periods
4.36.3.6.4.3 Large, Unusual or Questionable Items
4.36.3.6.5 Joint Committee Spreadsheets
4.36.3.6.6 Transcripts of Accounts
4.36.3.6.7 Change of Accounting
4.36.3.7 Reporting Prior to Resolution Of All Issues
4.36.3.7.1 Cases with Unagreed Issues - Minimum Refund
4.36.3.7.1.1 Documentation Requirements on Minimum Refund Cases
4.36.3.7.2 Tentative Allowances from Unexamined Source Years-Report Required
4.36.3.7.3 Request for Refund Claims from Unexamined Source or Refund Years Modified Expedite Refund Report
4.36.3.7.4 Posting of Security Modified Expedite Refund Report
4.36.3.8 Case Ready for Joint Committee Review
4.36.3.8.1 Joint Committee Review Contact Information
4.36.3.9 Inquiries from Joint Committee Review
4.36.3.9.1 Types of Inquiries
4.36.3.9.2 Proposed Changes to the RAR
4.36.3.10 Disclosure of Correspondence with Joint Committee on Taxation
4.36.3.11 Referral to Taxpayer Advocate Service by the Examination Team
4.36.3.12 Examination/Appeals Case Coordination
Exhibit 4.36.3-1 Sample Security Agreement
Exhibit 4.36.3-2 Procedures for Cases Involving Claims From Unexamined Source or Refund Years - Modified Expedite Refund
Exhibit 4.36.3-3 Sample Request For Advanced Review of Closing Agreement
Exhibit 4.36.3-4 CCP Instructions for Examination Team (Only LB&I Examination Teams Except for IIC)
Part 4. Examining Process
Chapter 36. Joint Committee Procedures
Section 3. Examination Team Responsibilities
Manual Transmittal
(1) This transmits revised IRM 4.36.3, Joint Committee Procedures, Examination Team Responsibilities.
Material Changes
(1) Added link to acronym database and list of acronyms in IRM 4.36.3.1.
(2) Removed references to Limited Issue Focused Examinations in IRM 4.36.3.2.
(3) Added references to the new $5 million Joint Committee threshold for C corporations throughout.
(4) Clarified use of Form 870 in IRM 4.36.3.2.6.
(5) Removed IRM 4.36.3.2.6.1 relating to net deficiency cases and qualified waivers and renumbered subsequent subsection.
(6) IRM 4.36.3.3 and IRM 4.36.3.8 were updated to include new electronic referral procedures.
(7) Removed IRM Exhibit 4.36.3-1, IRM Exhibit 4.36.3-2 and IRM Exhibit 4.36.3-4 and renumbered subsequent exhibits.
(8) Added new IRM Exhibit 4.36.3-4 on CCP instructions for LB&I examination teams.
(9) Various editorial changes and corrections have been made throughout this IRM.
Effect on Other Documents
This section supersedes IRM 4.36.3, Examiner's Responsibilities, dated May 4, 2010.
LB&I, SB/SE, TE/GE
Tina Meaux
Director, Pre-Filing and Technical Guidance (PFTG)
Large Business and International Division
4.36.3.1 (09-22-2015)
This section sets forth examination team responsibilities and procedures relative to Joint Committee cases. It covers the following areas:
Examination procedures (IRM 4.36.3.2)
Types of Joint Committee reviews (IRM 4.36.3.3)
Survey after assignment criteria (IRM 4.36.3.4)
Statute of limitations (IRM 4.36.3.5)
Documentation requirements (IRM 4.36.3.6)
Reporting prior to resolution of all issues (IRM 4.36.3.7)
Submission of case to Joint Committee Review (IRM 4.36.3.8)
Inquiries from Joint Committee Review (IRM 4.36.3.9)
Disclosure of correspondence with Joint Committee on Taxation (JCT) (IRM 4.36.3.10)
Referral to Taxpayer Advocate Service by the examination team (IRM 4.36.3.11)
Examination/Appeals case coordination (IRM 4.36.3.12)
A complete list of commonly-used acronyms in Joint Committee cases can be found in IRM 4.36.1.1. In addition, the meanings of most IRS acronyms can be found in the Acronym Database, http://rnet.web.irs.gov/Other/acronymdb.asp. The following acronyms are not listed in the database:
ARC Aging Reason Code
CRT Case Return Transmittal
GBC General Business Credit
GHW Global High Wealth
JCR Joint Committee Review Program (LB&I)
JCS Joint Committee Specialist (LB&I JCR Program)
NSR Notice of Suspended Referral
PC Project Code
Rev. Rul. Revenue Ruling
SRM Staff Review Memorandum
Joint Committee cases are to be given the same thorough examination as other cases of a similar size and difficulty. It is the examination team's responsibility to determine the scope and depth of the examination. The JCT will generally accept business decisions that are made in examinations, but those decisions must be properly supported and documented. In addition, other management initiatives, such as Fast Track Settlement and Accelerated Issue Resolution, may also be used in resolving issues in Joint Committee cases. However, see IRM 4.36.4.7 for applicable closing agreement procedures.
When a loss is attributable to a flow-thru entity, the examiner should, at a minimum, inspect the return and determine whether an examination is warranted. A copy of the flow-thru return, whether examined or not, should be included in the case file for informational purposes.
When Competent Authority is involved in a Joint Committee case, keep in mind that closing agreements (if prepared) must be reviewed by the JCT before being signed by the Service.
Fully agreed cases are reported to the JCT.
For unagreed cases, no report is required at the time the case is closed to the Office of Appeals. However, once an agreement has been reached and the case still meets JCT criteria, Appeals will be responsible for preparing and submitting a report to the JCT.
Partially agreed cases will require reporting to the JCT if the taxpayer is entitled to a refund over $2 million ($5 million for C corporations) regardless of the resolution of the unagreed issues. This situation is known as a minimum refund. If the taxpayer signs Form 870 requesting the refund, the examiner will follow the Joint Committee procedures, and Joint Committee Review will prepare and submit a report to the JCT on the minimum refund. The Appeals Officer will submit a supplemental report to the JCT when the unagreed issues are finally resolved even if the resolution of such issues does not cause an additional refund or credit. See IRM 4.36.3.7.1 for detailed information and procedures on minimum refunds.
4.36.3.2.1 (09-22-2015)
Case Identification
The examination team is responsible for identifying all Joint Committee cases in their inventory, or when the case qualifies as the result of the examination. The examination team must ensure that all returns in the case file have project code 0077 on ERCS/AIMS. See IRM 4.36.2.4 for guidance in determining the jurisdictional amount.
Claim Filed During Examination
Where a case is under examination or has been examined but not closed out by the examination team and the taxpayer files a claim for refund or application for tentative allowance sufficient to bring the case within the jurisdiction of the JCT, the examination will be extended to include such source year. Certain cases can be closed and reported to the JCT prior to the resolution of all issues. See IRM 4.36.3.7.2 for the procedures and criteria for tentative allowances from unexamined source years and IRM 4.36.3.7.3 for the procedures and criteria for claims from unexamined source or refund years.
Examination resulted in an overassessment of $1,600,000 for 2013. During the examination a claim (Form 1040X, Amended U.S. Individual Income Tax Return)is filed for 2013 for $410,000 based on a 2015 NOL.
The examination should be extended to include 2015, since the aggregate amount of the refunds or credits under IRC 6405(a) exceeds $2 million.
Examination resulted in an overassessment of $1,600,000 for 2013. During the examination a claim (Form 1120X, Amended U.S. Corporation Income Tax Return) is filed for 2013 for $410,000 based on a 2015 NOL.
The examination should not be extended to include 2015, since the aggregate amount of the refunds or credits under IRM 6405(a) is not in excess of $5 million (threshold for C corporations effective 12/19/2014).
Examination resulted in an over-assessment of $700,000 for 2013. During the examination an application for tentative allowance (Form 1139, Corporation Application for Tentative Refund) is filed for 2013 for $1,400,000 based on a 2015 NOL.
The examination will not be extended for purposes of JCT consideration since separate computations of jurisdictional limits under either IRC 6405(a) or IRC 6405(b) do not exceed $5 million (threshold for C corporations effective 12/19/2014).
Examination resulted in an overassessment of $900,000 for 2013. During the examination an application for tentative allowance (Form 1139, Corporation Application for Tentative Refund) is filed for 2013 for $4,200,000 based on a 2015 NOL.
Discovery that Report Was Not Prepared
Upon discovery that an overpayment in excess of $2 million ($5 million for C corporations) has been refunded without a report to the JCT, the examiner will notify the manager and the Joint Committee Specialist team.
When a case that requires reporting to the JCT was inadvertently not reported, the examination team that concluded the examination of the case will be responsible for securing the files and preparing the case for Joint Committee review. The normal guidelines will be followed, even though the examination has been completed and closed. See IRM 4.36.5.4.
Claim Filed for Previously Examined Year
All pertinent years (both refund and source years) must be covered in a current examination or survey action, even if one or more of the refund years has been previously surveyed or examined. All prior audit or survey reports pertaining to such years must be included in the case file.
If the refund or credit is for a year that was previously examined, that year should not be reexamined unless such action is necessary under reopening criteria, also known as case return criteria.
Information Given to Taxpayer
Upon completion of the examination, the examination team will solicit an agreement to the findings and inform the taxpayer that a report to the JCT is necessary and additional processing time will be required. The examination team should also advise the taxpayer to expect written notification when the report has been forwarded to the JCT. The examination team should answer any taxpayer questions until Letter 1573 (P) is issued at which time Joint Committee Review will answer questions about Joint Committee procedures. Letter 1573 (P) is a letter Joint Committee Review sends to the taxpayer when the JC Report is sent the JCT.
Joint Committee cases are considered "Excepted Agreed Cases" and as such the reopening procedures do not apply. IRM 4.10.8.4 states that Form 870, Waiver of Restriction on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment, will be used along with Form 4549-A in all Joint Committee cases.
Form 870 must not contain any restricted language.
A qualified Form 870 will not be accepted for Joint Committee cases.
4.36.3.2.6.1 (09-22-2015)
Assessment Prior to Review
If six (6) months or less remain on the statute of limitations, and the taxpayer will not extend the statute, the deficiency must be assessed prior to forwarding the case to Joint Committee Review.
Refund Prior to Review
When the taxpayer signs an unqualified Form 870 and the net overassessment is less than $2 million ($5 million for C corporations), the overassessment (and deficiency, if any) may be processed prior to reporting the IRC 6405(b) refund (tentative allowance) to the JCT. This only applies if there is sufficient time open on the statute of limitations to follow deficiency procedures.
Restricted Interest
Adjustments due to carrybacks will result in restricted interest. Even if there is no tax change to a carryback year, there may be a net interest assessment or abatement. The restricted interest provisions should be explained to the taxpayer.
The JC Specialist or the Tax Computation Specialist (TCS) (if assigned) is responsible for the preparation of Part I of Form 2285, Concurrent Determinations of Deficiencies and Overassessments in Cases Involving Restricted Interest Provisions of the Internal Revenue Code. For estate tax, use Form 1366, Tax Analysis Worksheet of Overassessment of Estate Tax Involving Restricted Interest. Form 2285 is required if there are tax changes from current year adjustments and at least one carryback year, or changes from two or more carryback years without any current year adjustments. The examination team should review the computations with the TCS.
If all of the tax adjustments to a year are due to an increase or decrease of just one carryback year, the Form 3198, Special Handling Notice for Examination Case Processing, needs to have this information. Form 2285 will not be required for this year.
Claim Disallowance In Agreed Cases
Because of the time required to process a Joint Committee case, the examiner will not solicit Form 2297, Waiver of Statutory Notification of Claim Disallowance, in an agreed claim case involving the disallowance in full or in part of a claim for refund or credit. Such action disadvantages the taxpayer by prematurely starting the running of the two-year period for filing suit. On Joint Committee cases, Form 3363, Acceptance of Proposed Disallowance of Claim for Refund or Credit, should be secured in addition to Form 870.
The examiner should indicate on Form 3198 (or other special handling form) that a statutory notice of claim disallowance should be issued after release from the JCT.
Types of Joint Committee Reviews
Joint Committee Review is responsible for the preparation of the report that is furnished to the JCT. These reviews are either conducted as Joint Committee electronic case reviews or as physical case reviews.
JC Electronic Case Reviews (LB&I except for IIC)
The Joint Committee electronic case reviews are conducted remotely by Joint Committee Review with the examination team's participation as needed for all of LB&I's Joint Committee cases except for the International Individual Compliance (IIC) organization. The instructions to request the mandatory Joint Committee review are at: http://lmsb.irs.gov/hq/pqa/4/downloads_JC/JCCaseMailingandClosingInstructions.asp.
To initiate a Joint Committee review, the Joint Committee Electronic Referral form is required to be prepared and submitted by the examination team. The form can be accessed electronically on the LB&I Joint Committee Review website: http://lmsb.irs.gov/hq/pqa/4/home.asp.
JC Physical Case Reviews (SB/SE, TE/GE, and LB&I's IIC)
A physical case review is conducted after the JC case has been forwarded from the examination team to Joint Committee Review. Joint Committee Review is responsible for statute controls, controlling the case on ERCS, and closing the case to Centralized Case Processing (CCP) upon clearance of the JC case from the JCT. See IRM 4.36.3.8 for submission procedures.
Joint Committee Review conducts a focused review of the case which includes the RAR, JC spreadsheet, and other supporting documentation. This JC review and the preparation of the report to JCT take place at the JC Specialist's post-of-duty.
Case Processing After JCT Clearance - JC Electronic Case Review
When the clearance letter or staff review memorandum is received from the JCT, Joint Committee Review will prepare and mail Letter 1574(P) to inform the taxpayer and authorized representative, if applicable. See Exhibit 4.36.3-4 for case closing instructions to the examination team.
Survey After Assignment Criteria
Returns in Joint Committee cases may be surveyed after assignment if the returns would normally have been surveyed before or after assignment during a regular examination except for the fact that the returns require Joint Committee review. The examination team can survey some or all of the returns.
Survey Documentation
There must be sufficient documentation in the examiner's case file to justify that an examination is not warranted. If the reason, economic or otherwise, for the overassessment is not readily available from the return or file, attempts should be made to obtain the necessary information from public sources (e.g., annual report, Security Exchange Commission's filings, Moody's, Standard and Poor's, etc.) or directly from the taxpayer.
Examination's request for retained copies of the taxpayer's tax returns, prior RARs, or information otherwise available from public sources is within the confines of a survey action. If the taxpayer is contacted, the examination team should point out that the Service proposes to accept the return as filed; that such action is subject to review by the JCT; and that certain additional information is needed to properly prepare the report. See the JC Website at http://lmsb.irs.gov/hq/pqa/4/Joint_Committee/jcforms.asp for an example of a pro-forma survey contact letter and information document request for survey cases.
However, if examination makes an inspection of any portion of the taxpayer's books and records (except as provided in this section) or discusses any potential issues with the taxpayer, the return may not be surveyed under this procedure.
All returns will be surveyed using Form 1900, Income Tax Survey After Assignment. The survey form will fully explain the reasons for the survey and include references to pertinent portions of the examiner's case file.
Each year must be shown separately on the survey form. Entries for the tentative allowance column are from Form 1139 or Form 1045. Entries for the claim amount column are from Form 1120X or Form 1040X. The form requires both the examiner's and team manager's signature.
Procedural Requirements – Survey Cases
All pertinent years (the refund years and the source years i.e., NOL, credit, etc.) not currently being examined must be covered in the survey action, even though one or more of the refund years may have been previously closed either by survey or examination. Also, all prior examination reports pertaining to such years must be included in the case file.
Surveys of tax returns may be made on the basis of the taxpayer's retained copies. However, care must be taken to insure that the tax shown on the copies agrees with current transcripts (no more than 30 days old at time of submission).
The documentation requirements of IRM 4.36.3.6 are applicable.
Form 3198 or other special handling form will be completed and marked "Mandatory Review" and "Joint Committee Case" .
Form 5351, Examination /Non-Examined Closings, will be signed by the manager and included in the case file.
Form 5344, Examination Closing Record, is required where there are unpaid survey claims (Form 1120X or 1040X).
The case file should contain a detailed explanation justifying the survey action. An explanation of the reason for the overassessment and prior audit history should also be included.
Form 5231, Joint Committee Case Check List, must be prepared.
Refund Counsel Inquiries on Survey Cases
If an inquiry from the JCT cannot be resolved without taxpayer contact, Joint Committee Review should contact the JCT Refund Counsel to discuss any problems that exist. All inquiries from JCT are Congressional Inquiries subject to disclosure rules.
If the Refund Counsel and the Service believe the requested information is critical, the taxpayer's returns will be examined only to the extent necessary to respond to the inquiry. The examination may take the form of a telephone call to the taxpayer, perhaps coupled with a letter of explanation to the taxpayer or representative, or limited in scope to an in-process examination of specific portions of the taxpayer's books and records that are relevant to respond to the inquiry. Therefore, survey procedures are no longer applicable and a RAR is required.
Absent formal instructions to the contrary, requests by the JCT Refund Counsel for additional documentation in specific cases will not be considered precedents for similar documentation in other cases involving the same issue.
Every effort will be made to obtain consents to extend the statute of limitations so that at least 12 months remain on the statute for both source and carryback years. If the taxpayer will not extend the statute and there are less than 12 months remaining on the statute, the examination team should contact Joint Committee Review. Refer to IRM 25.6.23 for statute control procedures.
Restricted Consents
Restricted consents will not be used in Joint Committee cases since it would restrict the rights of the JCT to perform their oversight function.
Alpha Statutes
The statute date of the carryback years should be updated on IDRS and ERCS with the correct alpha code when the regular statute has expired or is about to expire. See IRM Exhibit 25.6.23-3 for instructions on updating the statute .
For unpaid claims, replace the day field with AA. The month and year do not change.
When the claim or tentative allowance has already been paid, BB (NOL) and DD (credits) replace the day. The month and year will be changed to those of the earliest source year return.
Examination Action on Short Statutes
The examination team is required to comply with IRM 25.6, Statute of Limitations.
Form 895, Notice of Statute Expiration, must be placed on the outside of the case folder on top of all other documents, whenever a statute will expire within 180 days.
Statute Control During Review and JC Report Process
For a Joint Committee electronic case review, the examination team retains the case files and closes the case to CCP. The examination team is responsible for maintaining the required statute controls.
For a Joint Committee physical case review, Joint Committee Review retains the case files and closes the case to CCP. Joint Committee Review will maintain statute controls under existing procedures throughout the review and reporting process. Occasionally, a case may need to be sent back to the examination group to close out to CCP.
IRC 6405 requires a report to be submitted to the JCT. These reports are the principal source of information for the JCT. The examiner is expected to adequately explain and to furnish necessary supporting information for the issues reflected in the RAR. Therefore, care must be taken to ensure that the case files contain sufficient information for the preparation of the report.
Revenue Agent's Report (RAR) Requirements
A Form 5231, Joint Committee Case Checklist, must be completed by the examination team for each case. An RAR will be prepared for all examined cases, and will include all of the following:
Form 4665, Report Transmittal
Form 870, Waiver of Restriction on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment
Form 4549-A, Income Tax Examination Changes
Tentative refunds should be shown separately on Line 13(a).
Computation schedules for other taxes and credits
Alternative Minimum Tax (AMT) schedules, even if there is no AMT liability
Written explanation of adjustments on Forms 886-A or 5701 must be attached to the Form 4549-A
All electronic data files used to generate the RAR must be included.
Per IRM 4.10.8.15.3.3, when there are tentative NOL carrybacks, the RAR should show the correct net operating loss deduction (NOLD) amount. If the NOLD is allowed in full, the entire NOLD would be shown as an adjustment. If the NOLD is not allowed, the adjustment would be zero. The taxable income should be before the NOL carryback. The total corrected tax liability should be shown as follows:
Line 12 - Tax Per Return or as Previously Adjusted XXXXXXXX
Line 13(a)-(d) Tentative Allowances XXXXXXXX
Line 14 - Deficiency or Overassessment XXXXXXXX
Closing Agreements
Closing agreements must not be executed on behalf of the Government until reviewed by the JCT. See IRM 4.36.4.7 .
Except as explained below, if a case requires the execution of a closing agreement and must be reported to the JCT, the case files should be provided to Joint Committee Review with the closing agreement not executed on behalf of the IRS. Upon receipt of the clearance letter, the examination team will be responsible for execution of the closing agreement. The examination team will close the case to CCP after the closing agreement has been signed by the appropriate official.
In those situations where an issue is resolved early in the examination, such as Fast Track Settlement or Early Referral to Appeals, and it is known or likely that the case will require a report to the JCT, the examination team may request an advanced review of the closing agreement by the JCT prior to the case closing. If the examination team wishes to pursue this option, the examination team will prepare a cover memo and forward a copy of the closing agreement and any relevant supporting documents to Joint Committee Review. JCR will forward the documents to the JCT. After review by JCT, the agreement can be signed by the appropriate Service official. (See Exhibit 4.36.3-3.)
When the examination is still in process, there is a disclosure issue in sending a closing agreement to the JCT. The examination team will solicit written authorization from the taxpayer to provide the closing agreement to the JCT. If the taxpayer refuses, a redacted copy will be sent.
Competent Authority determinations can be executed by the Service prior to review by Joint Committee. However, these agreements must be included in the Service's report to JCT.
Under certain circumstances, a Minimum Refund Report can be submitted to the JCT. Under the Minimum Refund procedure, all issues relating to an ongoing Competent Authority determination will be considered as unagreed issues in determining whether the Minimum Refund procedures apply. If a Minimum Refund report is submitted, a supplemental report to the JCT will be required upon completion of the Competent Authority determination provided that any resulting additional refund meets the applicable jurisdictional threshold. See IRM 4.36.3.7.1.
Advance Pricing Agreements (APAs)
Advance Pricing Agreements must be finalized before a report can be submitted to the JCT. A copy of the APA should be provided to Joint Committee Review for inclusion in the report to the JCT.
Compliance Assurance Process (CAP)
At the conclusion of a Compliance Assurance Process review, if it is determined that the filed tax return will result in a JC refund claim, JC procedures will apply. Closing agreements in these cases must be submitted to the JCT prior to being signed by the Service.
For a Full Acceptance return, once the post-filing review is complete, the Account Coordinator will prepare the necessary documents for submission to Joint Committee Review.
For a Partial Acceptance return, once all of the remaining issues have been fully resolved, the report will be sent to the JCT.
Additional information relative to required documentation for CAP cases is located on the LB&I Joint Committee Review website at http://lmsb.irs.gov/hq/pqa/4/home.asp .
Taxpayer Information - Report Transmittal Requirements
Form 4665, Report Transmittal, (also known as the transmittal letter or T-Letter) will explain the cause or causes of the overassessments. If the overassessments result from a net operating loss, the economic reason for such loss must be briefly explained.
Information concerning the financial history and changes in capital structure of corporations will be furnished in every case. This should include:
Date and place of incorporation
A brief statement of the principal business activity and/or principal products and any major changes in these during years under examination
If stock is closely held, who controls the corporation
Names of subsidiaries or affiliates (if numerous, state the number and indicate where names can be found in case file)
Any changes in capital structure such as mergers, acquisitions, dispositions, etc, during the years under examination or survey
Whether the stock is publicly held and on which exchange it is listed
If an issue arises as to the proper carryback period of losses or credits of a newly acquired member of a consolidated group, the report will state whether the newly acquired corporation was organized by or for a preexisting member of the consolidated group.
Contact Information - Examination Team
The team manager's and examiner's name, address and telephone numbers must be entered on Form 4665, Report Transmittal, or survey form. The name and title of the taxpayer's corporate officer who is to receive correspondence must also be included on Form 4665.
Short Taxable Periods
Short taxable periods have numerous possible tax consequences. In order to fully understand the tax implications of the tax years reported, the examination report will disclose the existence and cause of any short taxable period.
Large, Unusual or Questionable Items
Any large, unusual or questionable items (LUQ) will be fully explained, even if not adjusted, on Form 4665.
Joint Committee Spreadsheets
Spreadsheets for regular tax and Alternative Minimum Tax (AMT) must be included with the case. Joint Committee spreadsheets can be found on the LB&I Joint Committee Review website for individual, corporate, and life/non-life insurance groups.
Additional Joint Committee spreadsheets should be prepared if the taxpayer has credits carried from numerous years. Separate spreadsheets should also be prepared for foreign tax credits involving different categories or baskets.
Transcripts of Accounts
The examination team must check the transcript against information in the case file to to ensure that all deficiencies, overassessments, claims paid, and refunds or credits, including tentative allowances and abatements, are properly reflected in the tax computation for the RAR and JC spreadsheets.
Change of Accounting
Copies of Form 3115, Change of Accounting Method, and approval memorandum from Counsel will be included in the case file.
Reporting Prior to Resolution Of All Issues
Certain cases can be reported to the JCT prior to the resolution of all issues. These cases include:
Cases with unagreed issues - minimum refund - see IRM 4.36.3.7.1
Tentative allowances from unexamined source years - report required (CIC cases only) - see IRM 4.36.3.7.2
Request for refund - claims from unexamined source or refund years -modified expedite refund report - IRM 4.36.3.7.3
Cases with Unagreed Issues - Minimum Refund
Upon completion of the examination, if the taxpayer is entitled to an IRC 6405(a) refund, and there are unagreed issues, the case may be a "minimum refund" case.
A minimum refund is an amount that the taxpayer is due to receive after offsetting any potential unagreed deficiency. The taxpayer would receive the net minimum refund amount regardless of the outcome of the unagreed issues.
A minimum refund may be processed before the case is sent to Appeals if:
The unagreed issues require a substantial period of time to resolve (one year or more for Coordinated Industry Cases (CIC), six months or more for all other cases), and the delay would deprive the taxpayer of a timely refund to which it is clearly entitled, in spite of the resolution of the unagreed issues, and
The taxpayer signs Form 870 indicating agreement with the minimum refund. See examples below for determining the "minimum" refund due the taxpayer.
Agreed Overassessment (4,500,000) (2,000,000) (6,500,000)
Unagreed Deficiency 1,000,000 500,000 1,500,000
Total results of examination (3,500,000) (1,500,000) (5,000,000)
Minimum amount entitled to receive 5,000,000
Agreed overassessment (3,000,000)
Unagreed overassessment (2,000,000)
Total results of examination (5,000,000)
If the minimum refund exceeds $2 million ($5 million for C corporations), and the taxpayer has indicated agreement with the examination team's findings by signing Form 870, Joint Committee Review must report the refund to the JCT before releasing the unagreed issues to Appeals. A final report (supplemental report) will be submitted to the JCT by Appeals when the unagreed issues are finally resolved.
Once JCT clearance is received on the minimum refund report, the examination team must process the minimum refund and ensure that the overassessment posts to the master file before the unagreed issues can be forwarded to Appeals. The case file must be clearly documented and verification included in the case file that the minimum refund has been issued to the taxpayer.
A minimum refund may also apply when there are unfinished flow-thru entity examinations. See IRM 4.36.4.11 for TEFRA and non-TEFRA flow-thru suspense procedures.
Documentation Requirements on Minimum Refund Cases
If a taxpayer indicates agreement to issues in the examination report, but refuses to sign the Form 870 indicating formal agreement with the minimum refund, the examiner will document the taxpayer's indication of agreement as well as their reason for not signing Form 870. In this situation, the examiner will treat the entire case as unagreed, including the "agreed issues" , and write up all issues in unagreed report format.
The examination team will advise taxpayers that in order for Appeals to accept the case, they will be required to provide an adequate response to all issues in the protest, even the ones the taxpayer agreed to informally. A proper protest must be secured from the taxpayer and the appropriate rebuttal must be prepared by the examination team prior to forwarding the case to Appeals. Appeals will return the case if all issues are not addressed.
If the taxpayer refuses to address all issues in the unagreed report, and refuses to sign the Form 870, the examination team should consider other appropriate actions such as the issuance of a Statutory Notice of Deficiency or Statutory Notice of Claim Disallowance.
Tentative Allowances from Unexamined Source Years-Report Required
A case can be submitted to Joint Committee Review with tentative allowances from unexamined source years, if:
It qualifies as a Joint Committee case without regard to the carryback from the unexamined source years, and
The examination of the source years will not be completed for a substantial period of time (six months or one year for CIC taxpayers).
When an NOL, capital loss, or credit carryback is allowed subject to future examination of the subsequent year, the examination report, (Form 4549-A) should contain the following statement:
"The net operating loss (or capital loss or credit) carryback from the year ending XX/XX/XXXX, reflected herein, is subject to correction upon examination of the tax return from which it originated."
If, as a result of the examination, the tentative allowances are reduced to less than the jurisdictional amount, the examination team will notify Joint Committee Review in writing. Otherwise, these source years and their carrybacks will be submitted for review at the completion of their examination or survey.
If the current examination would not be a Joint Committee case but for those carrybacks, the case should not be submitted to Joint Committee Review for review until the examination action is completed on the subsequent source years.
Request for Refund – Claims from Unexamined Source or Refund Years – Modified Expedite Refund Report
The Service can issue a conditional refund in excess of $2 million ($5 million for C corporations) prior to the completion of the examination or survey action if:
The taxpayer has requested the refund.
The examination team, in their discretion, are satisfied that the claim issues resulting in the refund will reasonably lead to allowance of all or a substantial part of the claimed refund.
No disadvantage to the government will occur.
The taxpayer posts security. See Exhibit 4.36.3-1.
The examination will not be completed within six months from the date the taxpayer requests the refund.
There is sufficient time on the statute of limitations to complete the examination.
This procedure is also applicable if the taxpayer files a claim after the due date to correct errors on its original return. An amended return filed before the due date does not require that a report be submitted to the JCT.
A Modified Expedite Refund Report will be prepared by Joint Committee Review and submitted to the JCT.
A Supplemental Report may be required at the completion of the examination.
See Exhibit 4.36.3-2 for the procedures to be followed.
Posting of Security Modified Expedite Refund Report
The taxpayer is required to post a bond or other similar security for the amount of the refund as a condition for submitting a modified expedite refund report. The Director of Field Operations or Area Director is responsible for determining the sufficiency of collateral. Refer to IRC 7101, the Regulations thereunder and IRM 5.6.1, Collateral Agreements and Security Type Collateral, for further guidance. At the discretion of the Director of Field Operations or Area Director , an additional amount of bond or security may be required with respect to interest on the refund in the event all or part of the refund must be repaid. This amount should be measured by the reasonably anticipated time to complete the examination and the interest rate currently in effect under IRC 6621. The posting of the bond must be accomplished prior to the submission of the claim to Joint Committee Review . A copy of the security agreement signed by the taxpayer must accompany the modified expedite refund report. The security agreement will be executed on behalf of the Service subsequent to the expiration of the 30-day period after the submission of the report. The refunds must not be released until Joint Committee Review notifies the examination team that the appropriate documents may now be executed and such action has been taken.
It is necessary to submit a copy of the executed security or collateral agreement with the modified expedite refund report. The agreement should reflect the amount of the proposed refund, plus previously assessed interest, if any, and estimated refund interest, if required. The agreement must be executed by the taxpayer prior to submission. Upon expiration of the 30-day period after submission of the report, the Director of Field Operations or Area Director having jurisdiction over the case should execute the agreement on behalf of the Service. Coordination with local Counsel in the development of the security agreement is required.
Any security or collateral agreement needs to specify that in fully agreed cases the agreement will not terminate until the JCT determines (if required by law) that it has taken no exception to the results of the examination. See Exhibit 4.36.3-1 for a sample security agreement.
Case Ready for Joint Committee Review
Once the examination of the agreed or partially agreed Joint Committee case is complete, the examination team requests a mandatory Joint Committee review by following the instructions at: http://lmsb.irs.gov/hq/pqa/4/downloads_JC/JCCaseMailingandClosingInstructions.asp.
Joint Committee Review Contact Information
Check the Joint Committee Review web site at http://lmsb.irs.gov/hq/pqa/4/home.asp for current contact information.
Inquiries from Joint Committee Review
There are times when it may be necessary for the Joint Committee Specialist to contact the examination team for additional information or clarification regarding a Joint Committee case. Inquiries will be treated with the highest priority.
The need for additional information or clarification may arise while the case is being reviewed by Joint Committee Review or as a result of a formal or informal inquiry the Joint Committee Review may have received from the JCT. They should be treated as a priority.
There may be times when it is more expedient for the examination team to communicate directly with the JCT. Joint Committee Review will arrange for this contact and remain involved to ensure the staff attorney receives a timely and satisfactory response.
All IRS personnel should remember that the JCT Staff Attorneys are congressional staff and any inquiry from them constitutes a congressional inquiry.
Types of Inquiries
There are two types of inquiries from Joint Committee Review:
Informal – Telephone or email
Formal – Written memorandum via a Case Return Transmittal (CRT) or Notice of Suspended Referral (NSR)
See IRM 4.36.4.2 for case return criteria and IRM Exhibit 4.36.4-3 for guidance on dispute resolution.
Proposed Changes to the RAR
If the examination team does not agree with the position of Joint Committee Review or the JCT regarding proposed changes to the RAR and the matter cannot be resolved on a mutually satisfactory basis, the dispute will be elevated according to the schedule in Exhibit 4.36.4–3.
4.36.3.10 (05-04-2010)
Disclosure of Correspondence with Joint Committee on Taxation
Generally, any IRS records generated during an examination or other process giving rise to the credit or refund should be considered agency records subject to the Freedom of Information Act (FOIA).
Informal or formal correspondence, including email, from the JCT should also be considered agency records subject to FOIA but should not be released to the taxpayer without the permission of the JCT. If the JCT communication contains a legend that says the document should be treated as a Congressional record and is beyond the scope of FOIA, it should be treated as such.
When the JCT raises an issue on a case, the Service has two options:
Agree to adopt that position and present it to the taxpayer as the position of the Service; or
Reply to the Committee with the reasons for disagreement.
Any documents created by the Service in connection with a response to any JCT correspondence should also not be released to the taxpayer without permission of the JCT.
Referral to Taxpayer Advocate Service by the Examination Team
Complete Form 911, Request for Taxpayer Advocate Service Assistance (and Application for Taxpayer Assistance Order), and refer the taxpayer to the Taxpayer Advocate Service (TAS) if, during a taxpayer contact on a case subject to Joint Committee Review:
The taxpayer asks to be referred to the TAS
The taxpayer meets TAS case criteria (see IRM 13.1.7)
You cannot resolve the issue
See http://tas.web.irs.gov/ or http://www.irs.gov/Advocate for more information.
Do not refer a taxpayer to TAS if you are able to resolve the taxpayer's problem or take steps to resolve the taxpayer's problem within 24 hours, unless the taxpayer asks to be referred to TAS.
Examination/Appeals Case Coordination
Appeals and Examination often have different years open for the same taxpayer; however, when the taxpayer files a tentative refund or refund claim affecting the years under Appeals jurisdiction which is attributable to the year under examination, then the examination team needs to consider the situation in light of Joint Committee reporting requirements. See IRM 8.7.9.5.1.3 for details.
Exhibit 4.36.3-1
Sample Security Agreement
This is only an example of a security agreement where an Irrevocable Letter of Credit will be posted as collateral. Any agreement that is drafted must, at a minimum, contain the termination events in paragraph 6. Counsel must be involved in the drafting of the agreement.
This AGREEMENT is hereby entered into between (name of taxpayer) (hereinafter "taxpayer" ), having an address at (taxpayer's address) and the UNITED STATES OF AMERICA (hereinafter USA), having an address in care of its agent, Director, Field Operations (Industry) of Internal Revenue (hereinafter DFO), (industry headquarters address).
Whereas on (date), the taxpayer filed a Form 1120X, Amended U. S. Corporate Tax Return for the tax year ending (date of year end) (hereinafter (YYYYMM) tax year), claiming (reason and amount), resulting in a refund of income tax for the (YYYYMM) period in the amount of (amount of refund) (hereinafter the (YYYYMM refund); and
Whereas the examination of the (YYYYMM) tax year has not commenced; and
Whereas the taxpayer has requested the (YYYYMM) refund be issued prior to the initiation and conclusion of the examination of the tax return for the (YYYYMM) tax year; and
Whereas the taxpayer desires to furnish an Irrevocable Letter of Credit (hereinafter the letter) to the DFO in order to induce the issuance of the (YYYYMM) refund.
Now, THEREFORE, in consideration of the mutual covenants, promises, obligations, and conditions contained herein, the parties hereby agree as follows:
1. Prior to the issuance of the (YYYYMM) refund, the taxpayer shall deliver to the DFO the letter consistent with the terms set forth herein. The letter shall be in favor of the DFO, and the DFO will hold the aforesaid letter in safekeeping in accordance with the terms and conditions herein.
2. The letter to be provided to the DFO shall be for the total amount ($ amount), which represents the sum of the following ($) amount of the tax to be refunded, plus ($), the estimated interest to the date of the refund.
3. The letter is given to indemnify the Internal Revenue Service for all or any part of the (YYYYMM) refund plus interest which may be due back to the Internal Revenue Service in the event the DFO determines there is any income tax due for the (YYYYMM) year.
4. As soon as practicable after delivery of the letter, the DFO shall commence an examination of the (YYYYMM) tax year.
5. If, as a result of the examination, the DFO determines there is a deficiency in the income tax for the (YYYYMM) tax year and notice and demand for payment thereof is issued as permitted by IRC section 6303(a), the Internal Revenue Service may draw upon the letter by draft at sight unless within 90 days from the date of the notice and demand, the taxpayer pays in full the amount(s) so determined (including statutory accruals). The draft shall be accompanied by a statement executed by the DFO (or his delegate) stating that notice and demand have been made and the taxpayer has failed to pay within 90 days of the date of such notice and demand. The foregoing statement shall be sufficient to satisfy any requirements for documentation supporting the taxpayer's failure to pay within the 90 day period.
6. The taxpayer shall have the right to terminate the letter upon the occurrence of any of the following TERMINATION EVENTS pursuant to the PROCEDURES described below:
(a) TERMINATION EVENTS
(i) in the event the examination results in a fully agreed case (that is, no issues remain to which the taxpayer has not agreed), the later of, the date of payment in full of all such agreed liabilities (if any), plus statutory accruals or the completion of the review of the Joint Committee Supplemental report and release by the Joint Committee on Taxation
(ii) in the event the examination does not result in a fully agreed case, the later of, the date which is 120 days after "notice and demand" have been made upon the taxpayer with respect to the final issue(s) in the case ( taking into account the taxpayer's ability to pursue all available administrative and judicial procedures to challenge the determination(s) of the DFO in whole or in part), or the completion of the review of the Joint Committee Supplemental report and release by the Joint Committee on Taxation or
(iii) in the event the Internal Revenue Manual provisions addressing the reports to the Joint Committee in cases involving claims for refund prior to completion of an examination are modified so as to no longer require the taxpayer to post a bond or similar security in order to obtain the refund prior to completion of the examination, but only upon mutual consent of the DFO and the taxpayer.
(b) PROCEDURES
In order to terminate the letter, the taxpayer must establish to the DFO that a termination event has occurred. Thereafter, the DFO (or his delegate) and the taxpayer shall execute a statement which sets forth the basis for the termination and the effective date for such termination. The statement shall be prepared by the taxpayer and executed by the DFO within 5 days of receipt of the taxpayer's request to execute the statement. THE LETTER SHALL NOT BE TERMINATED UNTIL THE STATEMENT HAS BEEN FULLY EXECUTED BY THE PARTIES AND DELIVERED TO THE DFO .
7. The funds under the letter shall continue to remain available to the DFO until the letter is terminated pursuant to the provisions of paragraph 6. In the event the funds may cease to be available to the DFO (i.e. due to the expiration of time or the refusal to extend), the DFO shall have the right to draw upon the full amount of funds available (or any part thereof) beginning ten (10) days prior to the expiration date unless prior to that time, the taxpayer provides another letter (hereinafter the substitute letter) which is comparable in all respects to the letter which is about to expire (hereinafter the first letter). The DFO's determination as to whether the substitute letter is comparable to the first letter shall be binding on the parties.
8. Nothing contained herein shall be construed as a waiver of or limitation on any collection action(s) available to the DFO pursuant to applicable law.
WITNESS our signatures and seals this ___ day of _____________, (year).
(Taxpayer Name)
By: ______________________________________
(Typed name of signer)
(Position)
By: _______________________________________
Director of Field Operations (Industry)
Procedures for Cases Involving Claims From Unexamined Source or Refund Years - Modified Expedite Refund
These procedures are an accommodation to taxpayers and are not statutorily required. These procedures are only applicable when the examination team is satisfied that the claim issues resulting in the refund will reasonably lead to allowance of all or a substantial part of the claimed refund.
These procedures are to be followed when taxpayers request prompt payment of Form 1120X claims under the provisions of IRM 4.36.3.7.3. Under these provisions, taxpayers are required to post bonds or other similar types of security (e.g. an irrevocable bank letter of credit) to protect the Government's interest until resolution of the claim. In these cases, typically Coordinated Industry Cases, examination or survey of the claim will not be completed within six months from the date of the taxpayer's request.
To invoke Modified Expedite Refund procedures the taxpayer must file a claim and request that it be paid prior to a final determination.
The taxpayer is required to provide a draft of the Security Agreement. In addition, the taxpayer will furnish a draft of the surety bond or other form of collateral to the examining officer, who will arrange a meeting with the appropriate Counsel Office to review the drafts. A Joint Committee Specialist may participate in the meeting. Since a Security Agreement is a legal document, it must contain, at a minimum, that specific language identified as mandatory in Exhibit 4.36.3-1.
The examining officer will return the draft to the taxpayer for preparation of a final version, incorporating any additions and/or deletions provided by Counsel.
The taxpayer will execute and return the approved Security Agreement and collateral documents as required. Upon receipt of the agreement and other required documents the examining officer will inform the taxpayer that the Service will execute the agreement after it has been reviewed without objection by the Joint Committee on Taxation (JCT).
The examining officer will prepare a processing file and submit it to the Joint Committee Specialist staff consisting of the following documents:
Three copies of the executed Security Agreement and collateral documents
A memorandum, addressed to the Manager, Joint Committee Review, which includes a brief taxpayer history and the basis for the refund claims
If claims are for carrybacks of NOLs, then the economic reasons for NOLs should be stated. In addition, the facts and circumstances regarding the proposed return of funds should also be included.
Copies of each Form 1120X claim and first four pages of each related Form 1120 tax return and Form 4626, Alternative Minimum Tax
Current transcript (no more than 30 days old) for each claim year
Form 5344, Examination Closing Record, for each claim year
Since this is being used merely for processing purposes the examiner should only complete the taxpayer information section and Box 15.
Forms 872, Consent to Extend the Time to Assess Tax, extending the statute(s) sufficient to allow completion of the examination
This includes the source year for any NOL, Foreign Tax Credit or Capital Loss carrybacks.
These procedures DO NOT apply to years where the statute is open by claim only. See IRM 4.36.3.5 and IRM 25.6.23 for statute requirements.
The statutes must be protected for all years, including the source year(s), until the supplemental report has been released by the JCT.
Joint Committee Review will prepare a Modified Expedite Refund Request Report to the JCT. A copy of the Security Agreement and collateral documents executed by the taxpayer (but not yet executed by the Service) will be attached to the report.
If the JCT does not raise concerns about payment of the refund(s) within 30 days from the date the JCT receives the Modified Expedite Refund Request report, the Joint Committee Specialist will notify the examiner that the appropriate documents may now be executed on behalf of the Service by the executive (or authorized delegate) having jurisdiction over the case.
The examining officer will provide the taxpayer with a copy of the fully executed documents.
Joint Committee Review will coordinate the processing of the refund through Case Processing Support.
The examination team will continue to be responsible for obtaining all necessary letter of credit extensions and statute extensions until the case is closed.
Sample Request For Advanced Review of Closing Agreement
To: Senior Refund Counsel, Joint Committee on Taxation
Thru: Joe Brown, Joint Committee Specialist
From: Mary Smith, LB&I Team Manager
Subject: Request for Advance Review of Closing Agreement - Taxpayer, Inc.
In accordance with IRM 4.36.3.6.2 and 4.36.4.7 we are requesting your office review the attached closing agreement in advance of a Section 6405 report. [Insert concise statement as to the issue and the source of resolution. For example, "This was a COLI issue that was resolved in the Fast Track Process.]"
If you have any questions, please call me at (123) 456-7890
Form 906 - Closing Agreement
Explanation of Adjustment
CCP Instructions for Examination Team (Only LB&I Examination Teams Except for IIC)
The following documents should be placed at the top of the case file in the following order when closing a case to CCP:
Letter 1574P – JC Specialist sends to the taxpayer after clearance letter is received.
Clearance Letter (Release Letter) – The taxpayer does not get a copy of the release letter
Joint Committee Report – The taxpayer does not get a copy of the report.
Letter 1573P – JC Specialist sends to the taxpayer after case is sent to the JCT for review.
Where applicable, any spreadsheets or other documents which were submitted to JCR which had to be changed.
The above letters are file copies. The clearance letter (release letter) and the Joint Committee Report should not be provided to the taxpayer.
The following may be helpful information to consider when closing the case to CCP:
Make a SAIN 022 and put all the JC documents in that section.
Form 3198 – Include the following statement in the Other section: "JC Case cleared and Letter 1574P issued to taxpayer" .
Form 3198: Check the restricted interest box if appropriate.
Update ERCS to Status 51.
Mail to appropriate CCP. Complete a form 3210 for closing and note on it that this is a JC case being closed. Attach a CCP Routing document on top of the Form 3210.
Page Last Reviewed or Updated: 13-Sep-2017


A resident of Chatham, Doris Marshall passed away at the Chatham-Kent Health Alliance on Friday, September 7, 2018 at the age of 96.
Born in Halifax, Doris was the daughter of the late Thomas and Charlotte (nee Croft) Andrews.
Beloved wife of 70 years to the late John (2014).
Loving mother of Ernest John (Lisa) Marshall of Blenheim, Jay (Selina) Marshall of Nelson, BC and Barbara Ann (Paul) Gardiner of Pain Court.
Grandmother of Thomas Marshall (Sue), Andrew Marshall (Heather Henning), and Matthew Marshall (Christa Asseltine).
Great-grandmother of Blake, Charlotte, Kate, Abigail, Ryan, Nathan, and Audree May.
Sister of George Andrews of Courtney, BC, the late Doug Andrews, and the late Joe Andrews.
Missed by many nieces and nephews.
Doris enjoyed knitting dolls for children and spending time with her family.
A Memorial Service will take place on Saturday, September 15, 2018 in the Catholic Chapel (2nd floor of the Towers) within the Chatham Retirement Resort, 25 Keil Drive at 1:30pm. A Private Family Interment will take place at a later date in Maple Leaf Cemetery.
Donations made in memory of Doris to the CKHA Foundation or to a charity of choice would be appreciated.


WW-569 Send an elegant St Patrick's Day arrangement of green roses, green fujis, green carnations, Bells Of Ireland, and Green Trick dianthus, designed in a golden glass trumpet vase. Celebrate your Irish heritage with this pretty bouquet!
Send an elegant St Patrick's Day arrangement of green roses, green fujis, green carnations, Bells Of Ireland, and Green Trick dianthus, designed in a golden glass trumpet vase. Celebrate your Irish heritage with this pretty bouquet!


Stryker, a surgical equipment manufacturer, chose Pathfinders to help them initiate, drive, and execute an entire launch of their System 7 line of heavy-duty power tools. Before drafting a full-scale plan, we researched customers and competitors to understand key value props, features, and benefits that are attractive to customers. With this understanding, we defined the most effective marketing strategy and developed an actionable rollout plan – on-time and on-budget.


The whiskey was aged for seven years and six months in barrel and infused with Madagascar vanilla beans in October 2012.
Brian Prewitt, master distiller said: "This marriage was a bit challenging to get it to come out just right.
The Abraham Bowman Limited Edition Vanilla Bean Infused Whiskey will mostly be available in its domestic market – Virginia - for $69.99.


When it comes to architecture, tiny homes have been a popular design for the past few years. We have seen tiny houses of all sorts, and today we get a look at some more. These designs, the Sunnuhlio Tiny Houses, are a unique resort that is set overlooking the Eyjafjördur fjord. Providing an idyllic getaway in Iceland, this unique retreat features a trio of cozy, comfortable cabins that sit along the shore on a piece of farmland.
The minimalistic structures feature a plywood interior with a kitchenette, dining area, and a sleeping loft. Large glazed panels provide unrivaled views over the water to the mountain peaks in the distance. The Sunnuhlio Tiny Houses are also situated within walking distance of an art museum, a small village with a pool and beach. For those looking to enjoy the environment, there are trails for bird watching while the city of Akureyri is just a short drive away as well.
Have a look at this unique and beautiful retreat in the images below and plan your stay at the Sunnuhlio Tiny Houses immediately. Keep it locked for more great travel destinations coming soon.


text:
Ballet / Dance news & information
Press Release: English National Ballet's Cinderella in-the-round at the Royal Albert Hall
By Jan McNulty, March 3 in Ballet / Dance news & information
Jan McNulty 16,772
Cinderella in-the-round
Thursday 6 – Sunday 16 June 2019
Tickets: ballet.org.uk/cinderella / royalalberthall.com/cinderella / 0845 401 5045
English National Ballet will perform a new in-the-round version of multi-award-winning choreographer, Christopher Wheeldon's, Cinderella, at the Royal Albert Hall from 06-16 June 2019.
Co-produced by English National Ballet and the Royal Albert Hall, Wheeldon's inventive production features over 90 dancers and combines magnificent sets and costumes, theatrical surprises, and lively choreography set to Prokofiev's famous score performed by English National Ballet Philharmonic, in what promises to be the ballet spectacular of 2019.
Tamara Rojo, English National Ballet's Artistic Director said: "I'm so thrilled that Christopher is re-staging his magical Cinderella for English National Ballet. I can't wait to see this production take shape in the magnificent space of the Royal Albert Hall, a venue we are always so pleased to return to."
Lucy Noble, Artistic and Commercial Director for the Royal Albert Hall, said: "Nothing can compare to the epic spectacle of a ballet at the Royal Albert Hall, and this extraordinary re-staging of Cinderella will bring the immortal story to life on a grand scale. We're thrilled to be working once more with English National Ballet and can't wait to see what Christopher does with the world's most famous stage."
Working from the darkly intriguing Brothers Grimm version of the story, Wheeldon originally created Cinderella to great acclaim for Dutch National Ballet and San Francisco Ballet: he and his creative team now reunite for the re-staging of this sparkling ballet. The production includes striking set design by Julian Crouch – founder of the influential theatre company, Improbable – puppetry from Basil Twist (whose credits include Charlie and the Chocolate Factory) and projection from Daniel Brodie.
English National Ballet has presented grand-scale in-the-round productions at the Royal Albert Hall since 1997, including Swan Lake – with its record-breaking 60 swans – and re-workings of Romeo & Juliet and Sleeping Beauty.
Listings:
Thursday 6 June – Sunday 16 June 2019
ballet.org.uk/cinderella / royalalberthall.com/cinderella
Choreography: Christopher Wheeldon
Music: Sergei Prokofiev
Libretto: Craig Lucas
Design: Julian Crouch
Lighting design: Natasha Katz
Puppetry design: Basil Twist
Projection design: Daniel Brodie
About English National Ballet
English National Ballet has a long and distinguished history. Founded in 1950 as London Festival Ballet by the great English Dancers Alicia Markova and Anton Dolin, it has played a major role in the growth and history of ballet in the UK. Today, English National Ballet is renowned for taking world-class ballet to the widest possible audience through its national and international tour programme, offsite performances at festivals including Glastonbury and Latitude, its distinguished orchestra English National Ballet Philharmonic, and being a UK leader in creative learning and engagement practice and delivery, building innovative partnerships to deliver flagship programmes such as English National Ballet's Dance for Parkinson's. Under the artistic directorship of Tamara Rojo, English National Ballet has gained new acclaim as it introduces innovative new works to the Company's repertoire while continuing to honour and reinvigorate traditional ballet.
ballet.org.uk
About the Royal Albert Hall
The Royal Albert Hall is the world's most famous stage. Over the past 148 years, it has hosted everyone from Albert Einstein to Arctic Monkeys, The Beatles to Beyoncé, Churchill to Chvrches (we could go on). Last year, its breath-taking auditorium presented 401 events by the world's greatest performers – taking in rock, pop and classical music, theatre, dance, films, Cirque du Soleil and even tennis – with the magical setting and inspired artists creating amazing memories for audiences.
Opened in 1871 to fulfil Prince Albert's vision of a central hall to promote the arts and sciences, the Hall is a registered charity that remains true to his founding ambitions while looking to the future. With 1.8million visitors a year, 'the nation's village hall' is the world's busiest venue, while its 1,000 events in secondary spaces help to welcome a young, diverse audience to the Hall. Research conducted by Populus in 2018 found that the Hall was the most respected venue in its field, with members of the public regarding it as more special and yet less elitist than any comparable venue.
Its Education & Outreach programme reaches more than 200,000 participants each year, working with schools, young people and the community, as well as other charities such as Music for Youth, as part of its extensive public benefit remit. It creates memories, changes lives and provides inspiration through music for all, regardless of age or background.
royalalberthall.com
zxDaveM 5,684
talk about clashing - with the visit of San Francisco Ballet at Sadlers Wells, the RB's Firebird mixed and R&J programmes at ROH, not forgetting Ballet Black in the Linbury.
Madness!!
RHowarth 167
1 hour ago, zxDaveM said:
Or the opposite, for those who travel long distances to watch ballet.
Dawnstar 694
I'm hoping to see this but I can't say the mention of puppetry is encouraging. Also, no mention of casting. Does anyone know how far in advance ENB usually announce casting? I'd like to try to see some of the dancers I was impressed by in Manon.
6 hours ago, RHowarth said:
last time I checked, you could still only watch one show at a time
Lizbie1 2,795
4 minutes ago, zxDaveM said:
But you can line them up more efficiently! My plan, if I can get the tickets, is to see the Firebird triple and SFB programme D on Friday 7th then SFB programme C and the Fonteyn gala on Saturday 8th. If the Cinderella interested me I'd add that on on the Thursday evening or Sunday afternoon.
The Saturday before I'll be at the R&J matinee and SFB programme B, with probably SFB programme A on the Sunday afternoon.
We out-of-towners get quite adept at looking for these opportunities, with travel being the major outlay.
The latest press release from ENB:
This summer, English National Ballet will perform a new in-the-round version of multi award winning choreographer, Christopher Wheeldon's, Cinderella, at the Royal Albert Hall (06-16 June 2019).
Emma Hawes and Francesco Gabriele Frola © Jason Bell. Art Direction and Design Charlotte Wilkinson Studio.
Tickets from £15
Still no casting information though.
cavycapers 1,018
As another out of towner, I too am taking advantage of the clash of programmes, seeing R and J on the 11th, Cinderella on the 12th and Firebird, etc in the 13th!
Edited May 10 by cavycapers
SPD444 841
Following a tweet from me ENB replied that they hoped to announce casting very soon???
16 minutes ago, SPD444 said:
I'm glad they're replying to somebody. I've asked twice on Instagram & had no reply.
Edited May 10 by Dawnstar
bangorballetboy 5,013
Casting for RAH is now on the website
CCL 95
I'm going on the 11th - I would have been happy with any cast but I'm delighted that I'll be seeing Alina Cojocaru!
alison 10,406
The "casting for all dates" option doesn't seem to be working past the first 3 performances (or 3 and a bit, depending on browser) again
LinMM 6,295
It's a bit irritating as an email dropped in my box announcing casting for Cinderella in the Round but it's only a very general casting giving some pairings and the role of Benjamin but nothing about who is exactly dancing on which day!!
2 hours ago, alison said:
It's showing up alright for me. I'm using Firefox.
I'm very pleased that they've finally put up the casting. The downside for me is that the pair I want to see, Hawes & Frola, are only doing 2 Friday matinees plus a Sunday that I can't make, so I'll have to hope I can beg an afternoon off work. The stalls prices are also rather more than I was expecting so, given how many seats there are still available, I may try holding out for a bit & see if there are any offers.
No Jurgita Dronina ?
Anyone tell me where this daily casting is?
I can only get the dates of performances for Alina Cojacaru Isaac Hernandez and Jeffrey Cirio
This is when you go into casting for all dates.....these three come up but no other dancers and when they are performing. 😬
Edited May 17 by LinMM
26 minutes ago, LinMM said:
Follow the link I posted. Scroll down to the casting sections and click on "casting for all dates"; if you're on a phone you may just have to use the drop down menu under "meet the principal casts".
Bluebird 957
I've pasted it in below:
Cinderella in-the-round casting
Please note: casting is subject to change. In the order of Cinderella, the Prince and Benjamin.
Thursday 6 June, 7.30pm
Alina Cojocaru, Isaac Hernández, Jeffrey Cirio
Friday 7 June, 2pm
Emma Hawes, Francesco Gabriele Frola, Ken Saruhashi
Friday 7 June, 7.30pm
Erina Takahashi, Joseph Caley, Barry Drummond
Saturday 8 June, 2pm
Alina Cojocaru, Isaac Hernández, Ken Saruhashi
Saturday 8 June, 7.30pm
Maria Kochetkova, Jeffrey Cirio, Francesco Gabriele Frola
Sunday 9 June, 2.30pm
Wednesday 12 June, 7.30pm
Thursday 13 June, 7.30pm
Friday 14 June, 2pm
Maria Kochetkova, Jeffrey Cirio, Barry Drummond
Saturday 15 June, 2pm
Saturday 15 June, 7.30pm
Sunday 16 June, 2.30pm
Thanks, Bluebird.
Kochetkova? I hadn't expected that! Will be nice to see her back with her old company.
Flippin' heck, though. £40+ (or lower) for a restricted view from the balcony? I thought there only used to be 2 ticket bands up there? There are 4 this time - and less generous in the amount of restriction you get..
Thanks for the casting you two!
Irmgard 975
14 hours ago, MAX said:
Sadly she is unable to do the Albert Hall performances. Hopefully she will be back next season!
Thanks for posting the casting in full Bluebird. I was away for the weekend and had very limited internet availability.
This is the body of the press release that came with the casting:
Thursday 06 – Sunday 16 June 2019
This summer English National Ballet performs their biggest production to date, a new, in-the-round version, of Christopher Wheeldon's Cinderella at the Royal Albert Hall (06–16 June 2019.)
Principal casting for the production is announced today and sees Lead Principals Alina Cojocaru and Isaac Hernández, Lead Principals Erina Takahashi and Joseph Caley, Lead Principal Jeffrey Cirio and Guest Artist Maria Kochetkova, and First Soloist Emma Hawes and Principal Francesco Gabriele Frola dance the roles of Cinderella and Prince Guillaume respectively.
Kochetkova joins English National Ballet as Guest Artist for performances of Cinderella having previously danced the title role with San Francisco Ballet. Born in Moscow, the international ballet star trained at the Bolshoi Ballet School before going on to dance with companies across the world including The Royal Ballet, San Francisco Ballet, American Ballet Theatre, the Mariinsky and Mikhailovsky Theatres, and English National Ballet (2003-2007).
Also announced today are those dancing the role of Benjamin, the prince's friend: Jeffrey Cirio, Francesco Gabriele Frola, Soloist Ken Saruhashi, and First Artist Barry Drummond.
Co-produced by English National Ballet and the Royal Albert Hall, Wheeldon's inventive staging, with over 130 dancers working on the production, combines magnificent sets and costumes, theatrical surprises, and lively choreography set to Prokofiev's famous score performed by English National Ballet Philharmonic, in what promises to be the ballet spectacular of 2019.
AnneL 14
I have now booked for evening of 8th June as I wanted to see Maria Kochetkova. I saw her Sylphide recently in Berlin. So double ballet day for me, as I will be a Sadlers Wells in the afternoon!
10 minutes ago, AnneL said:
Hello AnneL and a belated welcome to the Forum!
Ian Macmillan 3,929
Location: Bishop's Stortford
For anyone who missed this morning's Link, it seems there will be some fairly fantastical costumes in this show:
https://www.theguardian.com/stage/gallery/2019/may/24/cinderella-costume-parade-english-national-ballet-christopher-wheeldon-in-pictures
Wow. I hadn't considered the realities of having to produce all the costumes from scratch - it's so long since they've done a new in-the-round show.
17 hours ago, Jan McNulty said:
Sabine0308 105
From Maria's instagram info: Maria Kotchetkova and Jeffrey Cirio will be dancing on June 8, 12 and 14. ❤

redpajama_set_name: RedPajamaCommonCrawl


Running seems like one of the easiest sports in the world. It's just like walking, but faster right? Is it really a "sport" if you "play" it when you just need to get somewhere faster? Regardless of personal opinions, running is a sport with a high rate of injuries. Runners pound the pavement, grass, or track up to eight hundred times per mile. For the average five kilometer run, that's almost two and a half thousand times. Something's going to go wrong if you do it that many times.
Here are some common running injuries in Santa Fe that affect the toes. They might not be specific to runners, but have a high prevalence in the running community.
Blisters: Almost everyone has gotten a blister at some point or another. If the blister does not cause excessive pain and doesn't interfere with your running, leave it alone. If it's affecting your day-to-day life, you can take care of it with a sterilized needle or razor blade and let out the juices inside.
Burning Between the Toes: Known as neuromas, the burning can be caused by the inflammation of the bundle of nerves between the toes. The area doesn't look any different usually, but the pain can't be denied. It happens when the foot moves around a little too much, which usually can't be helped. A simple icing can help alleviate the pain after a run.
Toenail Discoloration: Toenails changing color can be scary. A toenail can become black if there's a lot of repeated pounding from something like running downhill and the toe is smashed into the front of the shoe. When there's a lot of pressure, the toe might bleed underneath, causing the discoloration. You can attempt to release the pressure of the blood buildup underneath, but it can be difficult and dangerous. It is recommended that a doctor take care of injuries like this.
Toenail Growth: The toenail can grow thicker after repeated pressure, to a point that is noticeably not normal size. This is caused by repeated trauma from heavy running (possibly with shoes too small) or from tripping over something too many times. Like a toenail that grows too long out, you can just file down the top of this type of nail. It may grow back large again, but you can file it again.
These are some common Santa Fe toe injuries from running. Some of them may go away on their own after a while, but if they're causing too much discomfort or not disappearing on their own after a few days, it's a good idea to contact a doctor, such as Foot & Ankle Associates, Inc. The experienced Santa Fe podiatrist office set up a consultation to work with you on a recovery plan and get you back to running. You can also order their Foot and Ankle Health Book available for free online.


text:
Q: Stata duplicates drop with case insensitivity I've always used this
duplicates drop

to take care of duplicates.
However, this command thinks "Apple Computer" and "apple computer" are different. But obviously, they are the same. How can I remove such duplicates?

A: Not so. The strings are different to a programmer because they are not equal, and duplicates is entitled, indeed instructed, to treat them differently.
It's your decision to regard difference of upper case and lower case as immaterial. So, this example would be fixed by comparing strings made all upper case or all lower case using upper() or lower().
Further, the help for duplicates explains:

Duplicates are observations with identical values either on all
variables if no varlist is specified or on a specified varlist.

so for duplicates drop to drop observations values would need to be identical on all variables.

redpajama_set_name: RedPajamaStackExchange


What could be more exciting than buying a new home? The experience of a new community, new neighbors and friends, and perhaps even a whole new outlook on life can certainly prove to be an extremely exhilarating event.
Whether you're shopping for previously owned or new, if you're thinking about buying a home, make sure you know its true condition before you make an offer.
Choosing the right home inspector can be difficult. Unlike most professionals you hire, you probably won't meet me until your inspection appointment, after you've hired me.
Different inspectors have varying qualifications, equipment, experience, reporting methods, and pricing. One thing that's certain is that a home inspection requires a lot of work.
Ultimately, a thorough inspection depends heavily on the individual inspector's effort. If you honor me by permitting me to inspect your new home, I guarantee that I will give you my very best effort.


text:
Crews respond to rush-hour wreck on Highway 118 in Simi Valley
Ventura County Star
The California Highway Patrol responded to a traffic collision Wednesday in Simi Valley, authorities said.
The collision was reported shortly after 5 p.m. on eastbound Highway 118 near the Sycamore Drive exit, officials said. Officials reported that three vehicles were involved. One vehicle rolled over and blocked the left two lanes of traffic, according to authorities.
Authorities said two people were taken to Los Robles Hospital & Medical Center in Thousand Oaks. The patrol classified the incident as a minor-injury accident.


This talk will present a revolutionary connector technology providing unparalleled design flexibility at low cost.? A photolithographic approach to connector definition coupled with batch, printed circuit manufacturing methods allows highly configurable designs.? Pin-out modifications, electrical performance tuning, tailoring of mechanical characteristics, and even adjustment of connector thickness can be accomplished quickly and easily with CAD modifications to low cost photo-masks and/or by modifications to the bill of materials.? Connectors can be custom designed and fully optimized for each revision or generation of a product, with minimal tooling costs and lead time.? Lithographically defined contact arrays also enable high levels of integration and miniaturization â?? pitch is no longer limited by the practical limitations of injection molding connector housings into which free standing spring contacts are subsequently stitched.? Neoconix utilizes a MEMS process model, implemented using the low-cost printed circuit substrate infrastructure, to fabricate contact arrays that can scale with advances in photo-lithography and HDI printed circuit substrate technology.
The connector fabrication process starts by defining arrays of copper alloy beams, in sheet format, in their ultimate configuration using large format, batch lithography and etch methods.? The arrays of beams, still in sheet format, are then formed into three dimensional, 'S'-shaped cantilever beams, using low cost, programmable dies. The sheets of contact arrays are subsequently integrated into connector 'interposer' structures using standard printed circuit fabrication processes, including lamination, plating, and etching.? The resulting one or two sided contact arrays can function as freestanding interposers or are readily integrated into standardized, low cost connector housings that provide alignment, attachment and actuation.
This talk will review basic elements of the Neoconix PCBeam technology, and will use real-world applications as well as simulations to describe recent learning on the relative impact of the flexible design elements on signal integrity and bandwidth, mechanical characteristics, durability, contact resistance, and reliability, and will describe applications where system level designs have been improved from a functional, form factor and/or cost perspective by implementing Neoconix interconnect structures.


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Joe Biden, Tara Reade, and the Faltering of #MeToo
This article will describe a detailed allegation of sexual assault against current Democratic presidential candidate Joe Biden. Please be advised that the article may be disturbing and upsetting to some readers.
"Believe all women."
That is a phrase used widely by activists who claim membership among the #MeToo movement. It's a striking, useful and good-intentioned one — when it comes to sexual assault, victims all too often do not see justice done to their abusers. The #MeToo movement has strived to change that, but it seems even that has its limits.
Some weeks ago, Alexandra Tara Reade, a former staffer for Joe Biden's Senate office during the 1990s, came forward with an account of how the Democratic presidential candidate sexually assaulted her in 1993. One could assume that a serious, credible accusation against the then-Democratic primary frontrunner would have been covered extensively by major American news outlets, but one would be mistaken: not one story appears on the websites of any 24-hour cable news network or those of the large national newspapers.
As if the silence of major news outlets wasn't enough, the Legal Defense Fund of Time's Up — a movement dedicated to aiding sexual assault victims and helping them tell their stories — declined to provide assistance to Reade, according to reporting done by The Intercept.
However, some smaller news organizations have given the allegation the reporting it warrants. In interviews conducted with Reade by Amy Goodman of Democracy Now! and Krystal Ball of the Hill, Tara explained the incident occurred when she was working as a staff assistant for Joe Biden's office in 1993. Speaking to Goodman, Reade described the events that led up to the assault:
"I was approached by my supervisor. She handed me a gym bag and said, 'Hurry, Joe wants this, so get it to him. He'll meet you down towards the Capitol.' And I went down the stairs, and I don't remember exactly where I was because there are connections between the Russell Building and all of that and the corridors, but we were in a semi-private location. It wasn't a room. It wasn't, you know, the Russell Office Building — I mean, in his office. It was down in the corridors. And I handed him the gym bag."
Reade alleges the assault happened after she delivered the gym bag to then-Senator Biden. As she explained in her interview with Ball: "When I gave him the gym bag, it happened all in one motion, almost. And he had me against the wall and then his hands were down my skirt, and up my skirt, and I wasn't wearing anything. And then with his hands went from there and entered me, and as he was trying to kiss me, and so when I tell you it's hard because everything happened at once… He was trying to kiss me and I was trying to pull away, and what I remember of that time is feeling really trapped…"
Reading and listening to these interviews with Reade, this article's authors were deeply emotionally affected. So with such a serious, credible allegation, what justification exists for the near-blackout of the story in America's major news media? The allegations against Harvey Weinstein exploded in the news immediately, as did the allegations against then-Supreme Court nominee Brett Kavanaugh during his confirmation process. Neither of those men was running for President of the United States; surely anyone who is running for the highest office in the country deserves even more scrutiny in cases where they have been accused of sexual misconduct.
Activists have also remained silent, such as actress Alyssa Milano and Biden senior advisor Symone Sanders, who has recently scrubbed their Twitter bios of the hashtag and deleted their tweets about Brett Kavanaugh. In sharp contrast, actor and activist Rose McGowan has been vocal in her support of Reade and has recently made scathing criticisms of Milano for her silence about the seriousness of the allegations against the Democratic candidate.
Milano finally broke that silence last Monday but spoke in sharp tonal contrast as compared with her outspoken words against Harvey Weinstein. In an interview with SiriusXM's Andy Cohen Live, she said, "I did my work and I spoke to Times Up and I just don't feel comfortable throwing away a decent man that I have known for 15 years."
One more wrinkle in this story inspires a move from disappointment to downright suspicion: in the weeks following Time's Up's decision not to support Reade's allegation, public affairs and political consulting firm SKDKnickerbocker — which employs Time's Up Legal Defense Fund co-founder Hilary Rosen as a political strategist — was paid a total of $587,478.73 over four payments by Biden for America, according to the Federal Election Commission's website.
Since there is no disclosure of the reason these payments to SKDKnickerbocker from Biden's campaign were made, speculation is all that is available, but the timing and amounts of the payments are dubious, to say the least.
Silence and suspicion. Until now, no one could believe these to be a part of the #MeToo movement. In such a short length of time, it has made great strides in changing how our society sees and deals with sexual harassment and assault. But now, at a critical juncture, when it could be argued that the work of #MeToo is more important than ever, the movement seems to have faltered. For what? To coronate a certain candidate as their party's presidential nominee, to promote him as seemingly pure and unimpeachable, even at the cost of justice?
Joe Biden will most likely be the Democratic nominee for president — that became likely last week when Bernie Sanders suspended his presidential campaign — but should he be? Is there no true moral imperative that dictates allegations such as this one against Biden be fully investigated, and if it is discovered that the allegation is true, that the man responsible be, at the very least, barred from running for the highest office in the land? Should a man accused of stealing the freedom of a woman in such a heinous act be allowed to serve as the leader of the free world?
Joe Biden's incumbent opponent, President Trump, is, of course, such a man, but Democrats should challenge him with someone who is truly morally superior. If Tara Reade's allegation is to be believed, then as lamentable as it is to acknowledge, Joe Biden represents no moral difference from Donald Trump.
Biden for America did not respond to a request for comment.
Kyle Gombosi is a senior Music: Elective Studies major with a minor in journalism. KG806059@wcupa.edu
Kelly Baker is an alumnus of West Chester University who majored in English with a minor in journalism and film criticism. KB819687@wcupa.edu
How am I supposed to learn when the world is on fire?
The Future of the American Left, Part One: Moving On


text:
Der Tryggve Point ist eine Landspitze an der Westküste der antarktischen Ross-Insel. Sie liegt 1,5 km nordwestlich des Turks Head.

Teilnehmer der Terra-Nova-Expedition (1910–1913) unter der Leitung des britischen Polarforschers Robert Falcon Scott kartierten sie. Scott benannte sie nach Tryggve Gran (1888–1980), dem einzigen norwegischen Expeditionsmitglied.

Weblinks
  (englisch)
 Tryggve Point auf geographic.org (englisch)

Kap (Antarktika)
Ross-Insel

redpajama_set_name: RedPajamaWikipedia


ABC-TV's new show Snoops features video clips, show photos, behind the scenes interviews, episode guides, cast bios, and show info. Picture gallery of actress, Gina Gershon from ABC tv show, Snoops. Syriana Gina Gershon Fan Site Bombshell Picture Gallery - Dedicated to bad girl, Gina Gershon. Free Gina Gherson screen savers, wallpapers, and other desktop themes. Pictures and Links to fuel Gina Gershon photos obsessions.


text:
Паучницы  — семейство двукрылых насекомых.

Описание
Бескрылые мухи длиной тела от 1,5 до 5 мм желтоватого или коричневого цвета. У различных видов глаза утрачены или же редуцированы до нескольких фасеток. Специализированные кровососущие паразиты, преимущественно летучих мышей. Яйца и личинки развиваются в теле самок, которые рождают уже личинок последней стадии развития. После рождения личинка сразу окукливается.

Классификация
В состав семейства включают около 270 видов в 11 родах.
 Подсемейство Archinycteribiinae

 Подсемейство Cyclopodiinae

 Подсемейство Nycteribiinae

Примечания

Hippoboscoidea
Семейства насекомых
Паразитические насекомые
Гематофаги
Паразиты млекопитающих


East Brunswick office: East Brunswick, Old Bridge, Monroe Township, Piscataway, Sayreville, Spotswood, Parlin, Milltown, Somerset, Franklin Park, South Brunswick, North Brunswick, Edison, Iselin.
Fort Lee Office: Fort Lee, Cliffside Park, Leonia, Edgewater, Teaneck, Palisades Park, Englewood, Ridgefield, Fairview, Bogota, Little Ferry.
Generally, we serve the following counties in New Jersey: Middlesex, Bergen, Monmouth, Mercer, Union, Essex, Hudson.


text:
Croatia's Josip Simunic hit with 10-match ban and will miss World Cup
Fifa acts on pro-Nazi salute and chant 'For the homeland'
Defender addressed fans after play-off win against Iceland
Croatia's Josip Simunic in action during the 2-0 World Cup play-off second-leg win against Iceland. Photograph: Darko Bandic/AP
Mon 16 Dec 2013 12.40 EST
The Croatia defender Josip Simunic will miss the World Cup finals in Brazil after being suspended for 10 matches by Fifa for making pro-Nazi chants at the end of last month's play-off victory over Iceland.
Simunic took up a microphone after the match and shouted to supporters: "For the homeland!" The fans responded: "Ready!" The call was used by the Croatian pro-Nazi puppet regime that ruled the state during the second world war.
Fifa said on Monday that the salute was "discriminatory and offended the dignity of a group of persons concerning ... race, religion or origin". Simunic has also been banned from entering the stadiums where Croatia will play those 10 games. Simunic previously defended his action, saying he was driven by love for his country.
"After taking into account all of the circumstances of the case, and particularly given the gravity of the incident, the committee decided to suspend the player for 10 official matches," Fifa said on Monday.
"The committee took note that the player, together with the crowd, shouted a Croatian salute that was used during the second world war by the fascist 'Ustaše' movement. As a consequence, the committee agreed that this salute was discriminatory and offended the dignity of a group of persons concerning, inter alia, race, religion or origin, in a clear breach of article 58 par. 1a) of the Fifa Disciplinary Code."