text:
Displaced podcast
David Halpern on revolutionizing policy through behavioral science
People often act against their best interests, even when the stakes are high. How can that insight, from the field of behavioral science, help improve humanitarian interventions?
by Ravi Gurumurthy
Chief Innovation Officer, International Rescue Committee
and Grant Gordon
Director of Innovation Strategy, International Rescue Committee
Insights from behavioral science are helping governments and humanitarian organizations design simple, inexpensive and effective mechanisms to improve health, education and social cohesion without passing new laws or changing economic incentives.
Marketing agencies have been hacking our unconscious biases to get people to spend money on their products for decades. A "nudge" takes advantage of the same principles to encourage us to make choices that optimize our well-being.
The humanitarian sector is increasingly adopting behavioral science principles to improve the efficacy of programs, but more research is needed on how well nudges perform in fragile states.
David Halpern thinks it's possible to prevent people in fragile states from joining armed groups, ensure people drink clean water, help children receive routine immunizations, decrease school absenteeism, and more—all without enacting new legislation or rolling out massive overseas aid projects. But to do so, we need a better understanding of just how irrational we all are.
"For many people, you're using mental shortcuts to make decisions all the time, day in, day out," Halpern, the chief of the UK's Behavioral Insights Team, tells Grant and Ravi on today's episode. While classical economics imagines humans as rational actors who constantly seek to maximize their own best interests, behavioral scientists like Halpern argue that habit, ingrained biases, stereotypes, social pressures, and inertia complicate how we make decisions, often prompting us to act against our own best interests. Subverting those mental shortcuts to make policy more effective is the task of Halpern and the Behavioral Insights Team.
The Behavioral Insights Team works to change how choices are presented in order to make it easier for people to make smart decisions—a practice known as a "nudge," after the work of behavioral economists Cass Sunstein and Richard Thaler. Many parents, for example, say they wish they could save more money for their children's education—but when it comes to actually doing so, they're unable to live up to their aspirations. However, Halpern tells Grant and Ravi on today's episode, "if you pay [a parent's] wage in two envelopes, it is very likely that they will save because you're always going to open one envelope, but the second one you might just be able to keep shut. And if you give me an envelope where it's got a picture of their kids, they are even more likely to save. And if it's an envelope where their kids are on it, and they have to tear open through the picture of the kids, then you're double or more for savings rate." Simply dividing wages into two envelopes, where one is implicitly set aside for education, is able to help parents keep their commitments.
Likewise, many families in developing countries are aware of the need to decontaminate water before consuming it, as unclean water can carry bacteria that are among the primary causes of child mortality. But even when decontamination is as simple and cheap as adding one chlorine pill a day to water, many families continue to drink unclean water. It's not because people are unintelligent, but they're hemmed in by their own habits and by inertia. We can increase uptake simply by positioning a large plastic chlorine dispenser by a local watering hole or stream, creating social pressures to increase water decontamination—if we see others decontaminating their water, we're more likely to follow suit. This simple tweak has brought clean water to over 5 million people. In general, Halpern advises, "If you want to think about human behavior, think about making it easy, attractive, social, and timely."
Most policy, when it comes down to it, involves human behavior. We want people to get back to work faster and pay their taxes. We want kids not to be beaten by their teachers in parts of the world. We want teachers to turn up for school, let alone kids to turn up for school. It's hard to do this through conventional regulation, but … just like understanding aerodynamics means that you can design a better car … understanding behavioral science means you can design better policy.
It's easy to see the appeal of nudges as a policy tool: They promise simple, effective, often inexpensive tweaks to existing systems rather than expensive overhauls of underperforming systems. The Behavioral Insights Team, for example, advertises that it has saved the UK government ten times the team's operating costs by improving how programs work. But nudges, which Thaler and Sunstein have called a form of "libertarian paternalism," have also received their fair share of criticism. Some argue that they're inherently undemocratic because they're policy-making tools masquerading as regulatory adjustments. And it's clear that in some places, nudges alone will not be enough to change behavior. Some systems require massive overhauls rather than quick fixes.
This episode is about the nexus of behavioral economics and international aid and development. In many respects, this is a frontier, with more questions than answers: How do we use behavioral insights to better integrate refugees into host communities? Can we use nudges to improve instruction in schools in low-income and fragile places? And is it possible to incorporate behavioral insights into the design of our museums to increase empathy? We discuss these questions, and others, with David Halpern.
'Behavioural economics' may sound dry – but it can change your life -- The Guardian, David Halpern
The Economist Asks: Richard Thaler -- The Economist
The Neuroscience of Compassion | Tania Singer -- World Economic Forum
Corruption and Social Trust: Why the Fish Rots from the Head Down -- Bo Rothstein
Designing for Nudge Effects: How behaviour management can ease public sector problems -- Presented at London School of Economics Public Policy Group, Paul Rainford and Jane Tinkler
Why 'Nudges' Hardly Help -- The Atlantic, Frank Pasquale
This year's economics Nobel winner invented a tool that's both brilliant and undemocratic -- Vox, Henry Farrell
Trust Me -- Freakonomics Podcast
The Storrs Lectures: Behavioral Economics and Paternalism -- Cass Sunstein
Nudging in Education -- Economics of Education Review, Mette Trier Damgaard and Helena Skyt Nielsen
How the World Bank is 'nudging' attitudes to health and hygiene -- The Guardian, Tamsin Rutter
Opinions and views expressed by guests are their own and do not reflect those of the International Rescue Committee.
Subscribe on: Apple Podcasts
Episode1April 10, 2018
Madeleine Albright on the global refugee crisis
Steven Hickey on witnessing the unfolding Syria crisis
John Prendergast: The Enough Project and South Sudan
Episode4May 1, 2018
Alex Aleinikoff: Let's start with how we define 'refugee'
Mandy Patinkin: From 'Homeland' actor to refugee advocate
Episode6May 15, 2018
Sarah Smith on the challenges of educating children during crises
Helene Gayle on how to lead organizations that respond to crisis
Carolyn Miles: Innovative solutions for improving the lives of children
Episode9June 5, 2018
Vali Nasr on how to end wars
Episode10June 12, 2018
Bob Kitchen on how to respond to humanitarian emergencies
Wilmot Collins on being a refugee mayor in a pro-Trump state
Reshma Saujani, founder of Girls Who Code, on innovation and failure
Episode13July 3, 2018
Kanika Bahl pulls back the curtain on innovation in development
Episode14July 10, 2018
Jan Egeland on how to broker the world's most challenging peace agreements
Chris Elias on immunizing the developing world
Geoff Mulgan wants us to rethink how to use AI technology
Rachel Glennerster's insights on the randomization movement
Episode19August 14, 2018
Paul Skidmore on the radical transformation to education in fragile states
Alix Zwane on what philanthropists can learn from venture capitalists
Owen Barder: we need an alternative to refugee camps
Episode22September 4, 2018
Jeremy Konydyk on the flaws in the humanitarian business model
Episode23September 11, 2018
Nancy Lindborg on what 'fragility' actually means
Stefan Dercon: how insurance could make humanitarian response faster and cheaper
Nazanin Ash: The Trump administration is tearing apart U.S. refugee policy
Episode26October 2, 2018
Anne Richard on 'humanitarian diplomacy' and dealing with anti-refugee sentiment
Patrick Fine explains integrated development
Episode28October 16, 2018
David Miliband on politics, populism and the global refugee crisis
Ann Mei Chang's innovation playbook for the development sector
Viet Thanh Nguyen on trauma, displacement, and identifying as a refugee
Thanks to our friends at Vox
This podcast has been made in partnership with Vox Media.


text:
Pop singer Eva debuts latest single, 'Ashes' remix; Download for free
June 9, 2011 July 5, 2017 admin
Looking for a new hot blonde pop tart to add to your "Club Jamz" playlist? Look no further than newcomer, Eva.
Her debut single "Not My Daddy" features the ice-cream-tattoo-faced Gucci Mane and was penned by our favorite party girl, Ke$ha. The track has been heating up the club circuit and Billboard Dance/Club Play chart, but Eva's newest single "Ashes" is hot on its heels.
Zap2it has your first listen to "Ashes (DJ Chuckie Remix)." Check it out below.
A little background on Eva:
A native of Lincoln, Nebraska, the 20-year-old was raised in the Bay Area of California. Growing up, she idolized the likes of Britney Spears, Christina Aguilera and of course, those boybands that we children of the '80s and '90s all remember. In addition to teaming with Mane on her first single, she is also joined by Lupe Fiasco and Snoop Dogg on her upcoming album, due out later this year.
Check out the whole article here!

redpajama_set_name: RedPajamaCommonCrawl


text:
Malaria parasite protein identified as potential new target for drug treatment
Scientists have discovered how a protein within the malaria parasite is essential to its survival as it develops inside a mosquito. They believe their findings identify this protein as a potential new target for drug treatments to prevent malaria being passed to humans.
The researchers found that when this protein – a transporter responsible for controlling the level of calcium inside cells – is absent during the parasite's sexual reproduction stages inside a mosquito, the parasite dies before developing fully. They discovered that the calcium transporter protein is responsible for protecting the parasite from potentially lethal levels of calcium during these stages.
Nanomal smartphone-like malaria detection device to be field tested one year earlier than scheduled
A pioneering mobile device using cutting-edge nanotechnology to rapidly detect malaria infection and drug resistance will be ready for field testing this year, one year ahead of schedule.
The €5.2million (£4million) Nanomal project was launched last year to provide an affordable hand-held diagnostic device to detect malaria infection and parasites' drug resistance in 15 minutes. It will allow healthcare workers in remote rural areas to deliver effective drug treatments to counter resistance more quickly, potentially saving lives.
Legal high Benzo Fury may be dangerous due to stimulant and hallucinogenic effects
The 'legal high' known as Benzo Fury may have stimulant as well as hallucinogenic effects according to new research presented at the British Neuroscience Association Festival of Neuroscience today (Tuesday 9 April 2013).
In a poster presentation at the meeting, Dr Jolanta Opacka-Juffry and Dr Colin Davidson reported that one of the main ingredients of Benzo Fury (also known as 5-APB) acts on brain tissue like both a stimulant and a hallucinogen – a combination of properties that is often found in illegal drugs and which can make them dangerous to users. The researchers believe this information should be disseminated to let potential users know the possible dangers of the drug.
Researchers identify mutation that causes short-sightedness and hearing loss
Researchers have identified a new disorder caused by a genetic mutation that leads to short sightedness and deafness. They say the new link between the two sensory problems could lead to better understanding of the disease mechanism of each.
The researchers – led by St George's, University of London and the Miller School of Medicine in Miami – discovered that a mutation in the gene SLITRK6 causes a syndrome symptomised by myopia (short sightedness) and deafness.
St George's University Challenge team in final bid for semis
The St George's University Challenge team will be back on the show next Monday (1 April) to make their last bid for a place in the semi-final round of the competition in their third of three quarter-final matches.
This follows last week's defeat in their second quarter-final match against New College, Oxford. After leading from the start, the final buzzer sounded when the St George's team was trailing 110-160.


text:
Wayne Embry, right, built the Milwaukee Bucks' lone championship winner.
Milwaukee Talks
Milwaukee Talks: Former Bucks GM Wayne Embry
Wayne Embry, who was in town recently to receive the Legends Award at the Fellowship Open golf tournament, talked with OnMilwaukee.com about building a champion in Milwaukee, trading for Oscar Robertson, trading away Kareem Abdul-Jabbar and what it means to be a pioneer in professional sports.
By Jim Owczarski Sports Editor Published Aug 24, 2012 at 11:00 AM
Four decades ago, the Milwaukee Bucks and Wayne Embry made history when the organization offered – and he accepted – the position of general manager.
Just three years prior, in 1969, Embry finished his playing career for the expansion Bucks, a career which included five all-star appearances and one NBA title with the Boston Celtics.
Suddenly, he was the first African-American GM not only in the NBA, but in all professional sports.
In recognition of that achievement, Embry was back in Milwaukee recently to be honored by his former teammate and fellow Hall of Famer Oscar Robertson with the Legends Award, which was presented during the Fellowship Open at Silver Spring Country Club in Menomonee Falls last week.
OnMilwaukee.com caught up with Embry, currently a senior basketball advisor with the Toronto Raptors, to talk about his pioneering role in the game, acquiring Robertson and trading away Kareem Abdul-Jabbar and how Michael Jordan prevented him from winning more championships in the 1990s.
OnMilwaukee.com: You're a Hall of Famer, you've been recognized for other off-court accomplishments – what is like to continue to be recognized for what you've accomplished like the Legends Award?
Wayne Embry: You're always appreciative that people recognize. As you get older you don't think much about what the consequences might be or what honors might come forth when you're doing it back during the day. But as you get older and you reflect back, it's just nice to know that there are those who appreciated what you've done. All the while we were in Milwaukee we came here as a player – I say "we" because my wife is very much a part of it – played a year, retired, went back to Boston and had a city job and not knowing what the future was. I did some color on the Celtics broadcast but I didn't know if broadcasting was going to be the future or what. I didn't have a clue what the future might be. Then (owner) Wes Pavalon came here later and asked me to come back to the front office. That was the defining moment in my life.
All the while I played offseason things with kids around here, clinics around the city in Cincinnati and Boston. I was there as the director of recreation – I started the Boston neighborhood basketball league which is still going strong – and when I came here I thought it was important to be involved in the community. The community embraced us and I wanted to return that and embrace them and make any contribution I could to the community and I've always encouraged our players to do the same, to be a part of the community where they played. It would be kind of mutual.
OMC: Do you feel like a pioneer?
WE: I feel that way only because people tell me I was! You just accept things as they come and you try to do the best you can and as you get older you reflect back and say "Wow, guess I was." I have that kind of attitude.
OMC: Former teammate and Bucks guard Oscar Robertson presented you with this award – does that add to the experience?
WE: I'm very appreciative that he accepted the role of presenting me. Oscar and I were roommates when we played together in Cincinnati and our families are very close and he meant so much to me as a player. He advanced my career as a player because of his greatness. Greatness defined is making other players better on your team and he certainly did that and did that with me. He encouraged me to the best I could be because he set a standard. If you responded to what his demands were and the challenges he presented to all of us on the team, we could probably be a better team. We were pretty good but we just couldn't beat the Boston Celtics.
Then in later years, when I was in the process of making the decision – after I was asked back here in the front office – Wes Pavalan said to me when he came to Boston to talk to me, "Oh by the way we're negotiating a trade for Oscar Robertson, would you mind giving him a call and give him a little bit of encouragement since you're coming back? What do you think of that?" I said if you get Oscar Robertson it'll be an instant championship. So I was kind of a prophet as well!
He said, "do you mind calling him," and I said, sure, "I'll call him." I called Oscar and told him the great experience we had here in Milwaukee and that I think he deserves to win a championship and you hadn't won anything until you won a championship and I said, by the way, I'm coming back to the front office and it'd be great. So we moved back here together.
OMC: How special were those years, from 1970 to 1975, which included a championship and another finals appearance?
WE: It was just great. A small market team advancing as we did. Of course we had great players. I often tell people when I launched my career as general manager how could you fail when you start with Oscar Robertson and Kareem Abdul-Jabbar and Bobby Dandridge? That's three great players who were already in place. The way the city responded was just amazing. They responded to us in our expansion year here (in 1968-69), I was just overwhelmed by the fan support even though basketball was coming into Packers land. We didn't know how it was going to be accepted or received, I should say. We were received with great enthusiasm and it was kind of an inspiration the way people came down to the old Mecca and supported us. The expansion year I think we exceeded expectations and I'm proud to be a part of that and I'm proud to have been captain of the team. I think that was my main purpose here, to provide veteran leadership to the other guys. Then, of course, bringing Oscar on board to go with Kareem and Dandridge and the rest, that was it. The fans responded well. It was just amazing as I look back on it.
OMC: Talk about having to move Kareem Abdul-Jabbar after the 1974-75 season.
WE: I think Kareem, when he announced to us that he wanted to be traded, it kind of deflated our mood at the time but it had been (six) years of just great basketball, a championship and almost another championship. It was my feeling – and I presented this to the board – that we should honor his desire out of respect to him. Of course part of that was he could've become a free agent after that and moved on anyway. But we were able to salvage enough pieces, talented players, to begin the next era. We came out of that just fine.
OMC: You mentioned that as a player in Cincinnati you couldn't get past Boston to win a title, and the same thing happened when you were the GM of the Cleveland Cavaliers from 1985 to 1992. You built some really talented teams, but a certain bald guy in Chicago prevented you from maybe capturing more championships.
WE: We tried to do the best we could, to put together the best product as possible and it was unfortunate during that time that Michael Jordan emerged in Chicago and the Bulls did a terrific job of complimenting him with some pretty good players in Scottie Pippen and Horace Grant, (Bill) Cartwright and guys like that. But it was Michael's greatness that propelled him to the dynasty that they were. You're right – here I am faced with greatness like we were in Cincinnati against Boston – and so we're facing it in Michael and somehow if we could've gotten by them once it would've changed things for us. I thought, at the time, we had the best team in the league one through 12, but we just couldn't overcome Michael's greatness.
OMC: You've been in the NBA in some capacity since 1958 – what's the biggest change you've seen?
WE: One big difference is you see the mega teams, like Miami and now it looks like L.A. is trying to follow. I wouldn't say the players are bigger and stronger – I think there's more star quality in the players have established winning like LeBron James, Michael (Jordan), Kobe (Bryant) and with expanded media you get more exposure. As a historian as well, having played it, if the Elgin Baylors and the Oscars and going back further in history to the Bob Pettits, Bill Russells, (Wilt) Chamberlain, guys like that, that era would compare with the players today.
Someone asked me to compare the Dream Team (of 1992) with this current team and I said, well, can we throw the '60 Olympic Team in there as well? That was a pretty good team, too. If you consider (Jerry) West, Robertson, (Jerry) Lucas, (Walt) Bellamy, you know. Then of course we couldn't put together NBA players and had to take players from the Armed Service. You had Bob Boozer. That was a pretty good team, too, and had a great, legendary coach in Pete Newell. The guy said 'I never thought of that' and I said of course you didn't.
OMC: You mentioned the super teams – which is something you're going up against now in Toronto – people here in Milwaukee and these mid-markets, fans get frustrated. Is that bad for the league?
WE: I tell you, it's been a great experience in Toronto for me and I encourage players to really take a hard look at it when we draft them. Part of the process in drafting and vetting is that you want players that are strong enough in character that will allow them to adapt to their environment, whatever that may be. I think Toronto's terrific to play and live, so we're in the process of convincing our players when they come there to just be patient, you'll love it here. That's what I did in Milwaukee. I've always managed in small markets and it was the same thing – a lot of players have stayed here (in Milwaukee).
Notwithstanding Kareem back then, which was quite understandable given his profile and that sort of thing, but that was a learning experience for me because I didn't want it to happen again. I convinced our owner that it may take a little longer, but in our vetting process what I'm going to try to do is get players that are indigenous to small markets, the Midwest players who don't need the glamor of the large city or the large market, and I think that we'd build something and we'd get players how had the character to respect where they are and we tried to manage accordingly. It takes a little longer, but it can be done. And it's more gratifying when you do it.
OMC: Finally, what's your assessment on this new-look Eastern Conference? The Heat are re-tooling as the defending champions. Dwight Howard is gone, Derrick Rose is injured, Brooklyn has a new look. Maybe some new teams, like the Bucks, are being brought into the playoff mix.
WE: The Knicks will be better, Miami is going to be Miami. Orlando will probably back up a little bit. Atlanta could possibly back up a little bit. Chicago, without Rose, will be ... so there are opportunities for the Bucks, for Toronto, to succeed. Ti's just a matter of taking pride in yourself, making the commitment and taking advantage of it.
Wayne Embry, Milwaukee Bucks, Oscar Robertson, Kareem Abdul-Jabbar, NBA Championship, BMO Harris Bradley Center
Jim Owczarski Sports Editor @JimOwczarski
Jim Owczarski is an award-winning sports journalist and comes to Milwaukee by way of the Chicago Sun-Times Media Network.
A three-year Wisconsin resident who has considered Milwaukee a second home for the better part of seven years, he brings to the market experience covering nearly all major and college sports.
To this point in his career, he has been awarded six national Associated Press Sports Editors awards for investigative reporting, feature writing, breaking news and projects. He is also a four-time nominee for the prestigious Peter J. Lisagor Awards for Exemplary Journalism, presented by the Chicago Headline Club, and is a two-time winner for Best Sports Story. He has also won numerous other Illinois Press Association, Illinois Associated Press and Northern Illinois Newspaper Association awards.
Jim's career started in earnest as a North Central College (Naperville, Ill.) senior in 2002 when he received a Richter Fellowship to cover the Chicago White Sox in spring training. He was hired by the Naperville Sun in 2003 and moved on to the Aurora Beacon News in 2007 before joining OnMilwaukee.com.
In that time, he has covered the events, news and personalities that make up the PGA Tour, LPGA Tour, Major League Baseball, the National Football League, the National Hockey League, NCAA football, baseball and men's and women's basketball as well as boxing, mixed martial arts and various U.S. Olympic teams.
Golf aficionados who venture into Illinois have also read Jim in GOLF Chicago Magazine as well as the Chicago District Golfer and Illinois Golfer magazines.
Milwaukee Talks: Milwaukee Preservation Alliance's Jeremy Ebersole
Bobby Tanzilo Jul 26 Milwaukee History
Milwaukee Talks: Summerfest's Bob Babisch and Scott Ziel
Bobby Tanzilo Mar 09 Music
Milwaukee Talks: Ray Nitti
Molly Snyder Jun 30, 2021 #RaiseMKE
Milwaukee Talks: Marcus Corporation CEO Greg Marcus
Matt Mueller Jun 07, 2021 Movies & TV


We are a multicultural family (two parents and one child) who left the city six years ago to live a more natural life in the country. Our other family members include Bruce, our farm dog, Nestor, our guinea pig, and Lollypop, our pigmy bearded dragon!
We teach permaculture and we host Kids holiday camp programmes as well as camping and house guests.
We tend large food producing gardens and raise many forms of farm animals.
We bush regen a lot and 'rewild' as often as possible!
We are down to earth people, serious and fun at the same time! and we aim at living a simpler life.
We speak, English, French, Spanish, Italian, and some Japanese and Chinese. We travelled a lot before we sent roots down on our farm and we enjoy multicultural exchange.
We teach permaculture and skills for simple living.
We are backed by the State Forest, the Jilliby State Conservation Area, and the Watagans National Park. Creek frontage, wet sclerophyll and rainforest, abundant wildlife and very quiet (apart from the Bell Birds!). Set on a 100 acre block (20 cleared acres) the farm is in its fifth year of establishment. It has been set up as a productive homestead and beyond-organic permaculture farm, currently in Biodynamic conversion.
Everything to date has been established – veggie patch, orchard, fences, off-creek water set up, and needs to be maintained, improved or troubleshooted!
Other activities include slashing, moving, pruning, bush regeneration, weeds management, bush track management, compost making, animal care, building and repairs, and general farm chores, etc.
You need to feel comfortable working on your own three days a week.
- Our 1960's caravan needs to be refurbished... Once it is, this could be your room! Access bathroom, toilet, kitchen and living areas in our own house.
Initial one week stay. We prefer long-staying guests.
Eat with us at the family table.
I fed the chickens, helped with whipper snipping and planting and cooked. And none of these things felt like work, because I was so happy to do all these tasks.


The Money Advice Service has yet again exceeded its main target for 2014/15 –six months early. Its latest performance figures show that people took almost five million actions to improve their financial circumstances after using the Service in the first six months of the year (April to September 2014). The target was for 4.5 million actions to be taken in the full year (April 2014 – March 2015).
The figures show that the Service is being particularly effective in helping people to budget. In the year to date, people have taken 3.5 million budgeting actions such as sticking to a budget and shopping around for deals. People have also taken 535,000 actions to improve their saving position, for example starting saving for a home or car, and 221,000 actions in the area of preparing for later life.
The numbers of people seeking advice from the Service in the last three months of 2014 remained constant quarter on quarter, in spite of the pressures to spend before Christmas.
In the period October to December, the Service received over 4.5 million contacts from customers through its online, phone, and face-to-face services. Satisfaction levels remained high with 90% of customers stating they would re-visit the Service and 87% suggesting they would recommend it to friends and family.
Partnership remains at the heart of the Service's strategy. During the quarter, there was a particular focus on building links with financial services firms. RBS incorporated the Service's advice on interest rates into its website and Virgin Money developed a Money Advice Service hub on their site. The Service also worked with MSN to provide a wide range of personal finance articles for their money portal.
The Service continues to work closely with lifestyle organisations, for example incorporating its advice into sites such as Mumsnet and Rightmove. The Service also took advice on tour, participating in the Daily Mirror's money roadshows around the UK.
The Service also held a number of consultation events around the UK for partners to input into the emerging Financial Capability Strategy for the UK.
The Service devoted significant effort during the quarter, working collaboratively with a whole range of organisations, to develop products to help people going through retirement – particularly important in the light of the forthcoming changes. Its services will complement and support the new Pension Wise service.
The Service launched a new and improved annuities comparison table in November, which takes people through a simple six step journey using videos, FAQs and tables. The aim is to demystify the variety of annuity products available. The tool has been extremely well received, with 86% of people who start using it following it through to completion.
The Service also made considerable progress on its retirement adviser directory during the period. The directory aims to signpost people to regulated advisers as they approach retirement and beyond.
Another key focus during the quarter was helping consumers to prepare for possible interest rates rises. In October, it launched a campaign to encourage consumers think about the impact of a rate rise on their finances and plan ahead. Over the quarter, both of the Service's mortgage calculators, which help consumers choose which mortgage is best for them and how much they can afford to borrow, were used 100,000 times.
More and more people continue to benefit from the Service's debt advice work. 66,000 people received debt advice from the Service's partners over the quarter, bringing the total number of people helped across the UK in 2014-15 to date, to 166,000. During the quarter, the Service began its new three year grant agreements with partners in England and Wales including Citizens Advice, which will enable an increase in debt advice provided and greater targeting at those areas and communities in most need. The new arrangements will help 35% more people to receive advice this year from its partners than in 2013-14.
"We've made some great leaps forward during the October-December period, helping more people than ever to take action to improve their financial situation. These figures are a tribute to our staff and our partners who work hard every day to help people across the UK.
"I'm really pleased to see our partnerships with financial services organisations - banks, building societies, insurance firms and regulated advisers, coming to fruition. If we are going to improve the financial capability of the UK, it's vital to have those partners on board.
1) The methodology for the number of actions taken as a result of the Service is as follows: between September and November the Service surveyed 1,908 people – a mix of web, phone and face-to-face customers who had had interactions with the Service between July 2014 and September 2014. Customers were asked about their propensity to take positive actions following interaction with the Money Advice Service, and to understand the barriers and enablers they had faced, in doing this. They were given a list of 20 different actions, and asked which ones they had taken. These actions could be either something the respondent had started to do, such as taking out new insurance or taking steps to reduce their debt, or things that they had started to more or less of, such as going into arrears less on bills or sticking to a budget more often.
2) Customer satisfaction scores are measured through monthly exit polls - surveys are conducted by telephone and online by independent market research agencies and measure customer satisfaction across all three Service delivery channels - online, phone, face-to-face. During the three months of quarter three, we interviewed 33,000 customers across all channels. Since April 2014 we have extended our exit poll questions to incorporate 'was your visit helpful?' The result of this question is then used to calculate the KPI 'Number of times we have provided customers with the help they required'.
3) Data about usage of articles and calculators has been taken from internal analytics and site data.


text:
Judit Polgár (n. 23 iulie 1976 în Budapesta) este o  șahistă evreică maghiară.

Date biografice
Judit joacă șah din copilărie, antrenată de tatăl ei, László Polgár, care era pedagog. Între anii 1988 - 1990 ea a început să câștige turnee de șah la juniori, fiind singura fată din categoria de vârstă între 12 și 14 ani. Titlul de mare maestru la șah îl obține la 15 ani, doborând astfel recordul deținut de Bobby Fischer. Spre deosebire de surorile ei Zsuzsa și Zsófia, ea participă și la turneele masculine de șah, fiind de fapt singura femeie din lume care a luat parte la acestea. Judit Polgár împreună cu surorile sale și cu Ildikó Mádl câștigă de două ori medalia de aur la olimpiadele feminine de șah din Thessaloniki 1988 și Novi Sad 1990. În 1994 este pentru prima oară învitată la un turneu de clasă mondială, la Linares. Din 1994 a participat la 5 olimpiade de șah ca membră a echipei naționale maghiare de șah. Printre reușitele șahistei maghiare se numără victoria în 1993 într-o partidă scurtă, în fața fostul campion mondial Anatoli Karpov. Nigel Short, jucătorul de clasă mondială care a pierdut mai multe partide în fața ei, declară "Ea este un ucigaș la șah, care miroase de la 20 de mutări matul". La campionatul mondial de șah din 1999, desfășurat la Las Vegas, ajunge până în sferturile de finlă, unde pierde în fața câștigătorului campionatului Alexander Khalifman. În 2001, la campionatul european de șah de la Ohrid, ocupă locul trei. La campionatul mondial din Moscova pierde în runda a doua în fața lui Vadim Milov. Revine în 2005 după nașterea copilului său, ajungând în finală cu alte opt candidate. În 2002 a reușit să îl învingă pe cel mai puternic jucător de șah din lume, Garry Kasparov.

Judit Polgár este prima femeie din lume care a jucat direct într-un turneu în campionatul mondial de șah masculin. Ea a realizat 4,5 puncte din 14 posibile din 6 partide. A ocupat locul întâi cu șahistul azerbaidjan Șahriar Mamediarov, depășindu-l la puncte pe vicecampionul mondial Veselin Topalov.

A eșuat în 2007 în prima rundă din turneul candidaților, cu 2,5-3,5 în fața șahistului rus Evgheni Bareev. La începutul anului 2003 depășește punctajul Elo de 2700 puncte, fiind numită "Super-Mare maestru la șah". În mai 2003 a avut 2682 puncte, plasându-se astfel pe locul 52 în clasamentul mondial FIDE la masculin. În noiembrie 2010, Judit Polgár câștigă turneul la șah fulger din Mexico City, învingâdu-l detașat cu 2,5:1,5 pe Vasil Ivaciuc și în finală cu 3,5:0.5 pe Veselin Topalov.

Judit Polgár este căsătorită cu Gusztáv Font, cu care are doi copii.

Note

Bibliografie
 Tibor Károlyi: Judit Polgar, the princess of chess. Batsford, London 2004. ISBN 0-7134-8890-5

Legături externe

The Chess Games of Judit Polgar Kurzbiografie und sämtliche Partien
Interview mit Judit Polgár
All Polgár Games (englisch)
Biographie auf fembio.org

Nașteri în 1976
Șahiști maghiari
Maeștri ai șahului
Șahiști evrei
Oameni în viață
Oameni din Budapesta

redpajama_set_name: RedPajamaWikipedia


text:
Adnan Asar
Lucid Lane, Inc
Adnan has extensive experience and success in building fast-growing digital health, e-commerce, consumer and enterprise services at companies such as Yahoo!, Shutterfly / Tiny Prints, Livongo Health among others. Adnan has built $100mm+ companies in the consumer and digital health space that went I.P.O or were successfully acquired and that were backed by investors from Kleiner Perkins, TCV and General Catalyst. He was the founding Chief Technology Officer at Livongo Health (NASDAQ: LVGO) responsible for product and technology solution for diabetes management. Adnan was previously Global Head of Technology at Shutterfly Inc. responsible for their products fetching $1 billion in revenues. He was head of technology at Tiny Prints that was acquired by Shutterfly. He was also the first engineer hired at Keynote Systems (now Dynatrace) that went I.P.O. in the late 1990s.
Six Damaging Myths About Teletherapy That Prevent Patients From Getting Help
Teletherapy is a safe, effective way to receive mental health care on your terms.
AI In Healthcare Presents Unique Challenges And Amazing Opportunities
The bar is high for AI in healthcare: It must adhere to ethical standards, protect patient data and lead to better patient outcomes.
AI Could Reduce Racial Disparities In Healthcare
What makes one AI tool shortchange Black patients while another produces more equitable treatment? The difference may boil down to one of the simplest rules of computer programming.
Mental And Physical Health Challenges Will Persist In The Aftermath Of The Pandemic — We'll Need Tech Tools To Cope
If millions of more people need help today, our health care system may strain to keep up with the need.
Mental Health Assessment Testing Goes Digital
Even as doctors and mental health providers welcome patients back into offices, and leave their doors open for people in search of treatment, online assessments will continue to be a vital means for connecting patients with providers.
How Wearables And Apps Can Help Patients Avoid Addiction Relapse
Telehealth options allow patients to get the benefit of medical treatments along with self-management skills, cognitive behavioral therapy and access to other support.
16 Strategies To Prevent Your Team Members From Adopting 'Shadow IT'
Wherever there is a company tech program, there is also the risk of people trying to work around it on their own without consulting IT. While the use of "shadow IT" isn't a new issue for tech professionals, recent increases in remote work could potentially worsen the problem. Therefore, IT leaders must stay especially vigilant to prevent team members from downloading and using unapproved or unauthorized technology.
Opening Up To A Robot? How Mental Health Tech Can Help Patients
Stigma and feelings of shame can be barriers to seeking treatment, so AI tools may be particularly useful in aiding people who are struggling with mental health issues begin to get help.
The Best Tech Tool For Mental Health May Be The Simplest: Broadband Internet Access
The vulnerable populations who don't have reliable internet access are often precisely the people who could benefit most from teletherapy.
How Digital Symptom Tracking Is Remaking Medicine For The Better
The use of telehealth allows doctors to supplement in-person visits with remote visits, enabling more frequent check-ins with patients who need them.
Five Tech Innovations That Changed Mental Health In 2020
Technology pervades our daily lives, but we've only begun to harness its potential to improve mental health.
How Technology Is Reinventing Traditional Support Groups
In some ways, for some patients, old-fashioned group support may actually work better online.
How AI And Technology Can Help Patients Manage Chronic Pain
Chronic pain can be a bewildering and life-altering problem. New technology, including AI-enabled tools, can help patients navigate the maze of chronic pain.
Five Ways AI Can Help Revolutionize Mental Healthcare
AI has the potential to revolutionize mental healthcare, ultimately making care more accessible, more responsive and more affordable.
Teletherapy And Digital Health Aren't Just Stopgaps — They're The Future Of Mental Health Care
Telehealth provides an opportunity to take a step forward in the way we care for ourselves and each other with an emphasis on individualized care and real-time response.
Empowering People Living With Medication & Substance Dependence, Anxiety & Depression To Live Better & Healthier Lives Professional, Licensed, And Vetted Counselors That You Can Trust


text:
L' est une subdivision de l'Éocène (deuxième époque de l'ère Cénozoïque) dans l'échelle des temps géologiques, plus ou moins équivalent au sous-étage de l'Yprésien inférieur — l'Yprésien supérieur correspondant au Cuisien. Il dure approximativement de . Il est à l'extrême pointe de la transgression marine.

C'est la toute première et plus ancienne division de l'époque Éocène.

Historique

Doncieux (1906, 1911) reconnaît cet étage dans les Corbières septentrionales et l'attribue au Cuiso-Lutétien. Il remarque dans le Lutétien à Fontcouverte et dans une dizaine d'autres gisements des Corbières septentrionales des plaques marginales d'astérides qu'il rapporte à un Goniaster proche de Goniaster poritoides Desm., et à un Astropecten.
Valette (1925) décrit, dans le matériel recueilli par Lambert, en particulier à Fontcouverte, deux espèces nouvelles qu'il affecte, très correctement compte tenu des connaissances de l'époque, à deux genres, l'un fossile, l'autre actuel.

Avec l'élaboration d'une échelle chronostratigraphique fondée sur les biozones à  et nummulites par Hottinger et Schaub en 1960, ces deux auteurs sont amenés à identifier l'Ilerdien comme entité stratigraphique basée sur ces formations marines.
Ils le placent, selon Bessière et al. (1978) « entre le Sparnacien à  levis Hott. et le Cuisien (biozone à  oblonga) » ;
ou, selon Breton & Vizcaïno (1997) « entre le Thanétien () marin et le Cuisien ».

Mais en 1975 Bignot et Moorkens trouvent que seule la partie supérieure de l'Ilerdien coïncide avec l'Yprésien inférieur.

Selon Jean-Claude Plaziat (1970), le "calcaire basal" (de l'Ilerdien) surmonte les dépôts fluvio-lacustres du "Sparnacien" ; il dit aussi (1981, 1983), que l'Ilerdien correspond au Sparnacien moyen et supérieur et au Cuisien inférieur.

Son existence et sa présence en Languedoc ont animé des débats passionnés et engendré de nombreuses études. En 1997, Breton & Vizcaïno le disent « aujourd'hui admis par la plupart des auteurs ».

Durée

L'Yprésien durant de , si l'on considère une durée égale pour ses deux sous-divisions, l'Ilerdien durerait de  et le Cuisien de .

Mais en 1975 Bignot et Moorkens trouvent que seule la partie supérieure de l'Ilerdien coïncide avec l'Yprésien inférieur.

Événement marquant

Pour Cavelier et al. (1997), le milieu de l'Ilerdien marque la fin de la progression vers l'est du bassin aquitain, avec l'océan s'avançant jusqu'à Béziers lors de cette troisième transgression marine — la première datant du Danien () et atteignant le Mas-d'Azil, la deuxième au Sélandien-Thanétien (respectivement  et ) et atteignant les Corbières de l'est.

Stratigraphie

Selon la définition de Hottinger et Schaub (1960), corroborée par les observations de nombreux auteurs subséquents, « l'Ilerdien désigne l'ensemble des couches nummulitiques paléocènes dans les Pyrénées orientales attribuées jusqu'ici au Lutétien inférieur et à l'Yprésien » ; il débuterait par la zone à Alveolina cucumiformis, suivie par celle à Alveolina corbarica (marnes bleues) et se terminerait par la zone à Alveolina trempina (grès à huîtres).

Stratigraphie dans les Corbières

La position de l'Ilerdien à l'extrême pointe de la transgression marine se retrouve dans sa stratigraphie ; ainsi cette série marine, qui avoisine les  d'épaisseur dans les Corbières, y est caractérisée par une transgression marine brutale suivie d'une régression progressive. L'Ilerdien du mont Alaric, vers la frange nord des Corbières, donne la stratigraphie suivante (de bas en haut) :

 le « calcaire marin basal » qui surmonte en continuité les dépôts fluvio-lacustres du « Sparnacien » ;
 les « marnes à  », avec la base de cette formation localement envahie (dans certaines parties de l'Alaric notamment) par des faciès carbonatés et gréseux : « calcaires gréseux et calcaires blancs à  », « calcaires à nummulites et algues » ;
 les « marnes et grès à Ostrea strictiplicata » ;
 les « marnes à cérithidés » ;
 les « marnes et marno-calcaires lacustres », ces trois dernières formations préludant à la sédimentation fluvio-continentale de la "molasse de Carcassonne".

Le niveau e3b, un calcaire à , est dit « calcaire à  » et comprend trois niveaux :
 un niveau inférieur à calcaire oolithique avec d'une part des calcaires en plaquettes à ostracodes et milioles (mont Alaric) et des bancs à  flosculinisées et à Ovulites maillolensis à Arce et Belcastel et des orbitolites (0. gr. biplanus) à Belcastel. À ces orbitolites sont souvent associées Alveolina cucumiformis et A. gr. subtilis ;
 un niveau moyen de marnes ocre à huîtres, brachiopodes, gastéropodes, serpules avec, du côté de Pradelles-en-Val, des épisodes détritiques (grès à graviers) sous forme lenticulaire ;
 un niveau à calcaire blanc avec des , assilines et milioles. On y trouve des mélobésiées et des dasycladacées, notamment l'association de  O'Gormani et des algues du genre Halimeda avec quelques archaeolithothamniées encroûtantes.
Les niveaux que l'on retrouve sur la bordure nord du Mouthoumet sont en partie des équivalents latéraux des niveaux à  (O. subgranulosa) décrits ci-dessous.
Cette formation, qui atteint  sur le flanc nord de l'Alaric puis  sur le flanc sud (Pradelles-en-Val), n'a plus qu'une quinzaine de mètres sur la partie septentrionale du Mouthoumet.

Les niveaux e3c et e3d sont des marnes bleues à  et des marnes bleues à turritelles.

Le niveau e3e est un grès à huîtres

Observations sur la chronologie des formations e3b, e3c, e3d et e3e :
La nomenclature classique de la carte géologique à 1/80 000 donnait la formation du calcaire à  comme yprésienne, celle des marnes bleues et des grès à huîtres, comme étant d'âge lutétien inférieur.

Paris (1971) rapporte à l'Ilerdien supérieur (noté « e4d ») un ensemble géologique près de Mirepoix (hameau sur Montmaurin, Haute-Garonne), jusque là rapporté au Lutétien moyen, défini par la présence de Lophiaspis baicheri dans une molasse gréseuse dite « grès de Saint-Quentin » alternant avec des poudingues du type Palassou, le tout reposant sur de l'Ilerdien moyen.

Stratigraphie en Égypte

La question de la différence entre Yprésien inférieur (ou Ilerdien) et Yprésien supérieur (ou Cuisien) se pose aussi ailleurs qu'en France, par exemple en Égypte. Keheila et al. (1990), étudiant les formations carbonatées de l'Éocène inférieur à l'est de Qena et Sohag, y trouvent deux zones de foraminifères :
 une zone à Nummulites soliturius ( irregularis /  libyca) de l'Yprésien inférieur (formation de Thèbes) ; et
 une zone à Nummulites planulatus / N. burdigalensis de l'Yprésien supérieur (formation de Drunka), qui est par ailleurs marquée par trois zones d'algues, avec du plus ancien au plus récent : Ovulites maillolensis, puis Carpathoporella occidentalis et enfin Belzungia borneti.

La formation de Thèbes, qui correspond à l'Ilerdien, est caractérisée par :
 une couche inférieure gris clair, dure, massive et parfois , avec une alternance de shales et de marnes calcaires qui se transforment progressivement (vers le haut) en calcaires crayeux et dolomitiques à grain fin. Des nodules de chaille sont éparpillés dans ce faciès lithique, plus nombreux dans la partie supérieure ;
 une couche intermédiaire essentiellement blanc jaunâtre, déposée en lames fines, avec des alternances de mudstones calcaires pures et dolomitiques et des wackestones riches en nodules et bandes de chaille ;
 une couche supérieure marquée par des plaques de calcaire dur, gris foncé, silicifié, contenant des nummulites ; en alternance avec des calcaires mélangés à des boues qui ont pu les enrober. Ce faciès contient des , des  et des huitres.

Les formations de Thèbes et de Drunka ne se superposent pas régulièrement : au nord-ouest de la zone étudiée, le contact entre le milieu et la partie supérieure de la formation de Thèbes d'une part, et la formation de Drunka d'autre part, se présente comme les doigts croisés de deux mains. Par ailleurs, des diastèmes (surfaces d'érosion discontinue) apparaissent dans la formation de Thèbes, principalement au milieu de celle-ci où ils sont caractérisés par des couches de calcaires phosphatiques à gros grain allant jusqu'à  d'épaisseur. Selon les auteurs, cette formation se serait déposée dans un environnement de marées sur fond plat et une circulation d'eau en partie restreinte, avec des bancs de nummulites déposés par des tempêtes. Dans des lits de shale, des foraminifères du Paléocène (Planorotalites pseudomenardii, Globorotalia compressa, Planorotalites pusilla pusilla, Morozovella uncinata, Morozovella angulata, Globigerina triloculinoides) sont remaniés et coexistent avec des ostracodes yprésiens (Leguminocythereis aff. lokossaensis Apostolescu) ; ce qui suggère que la séquence du Paléocène, avec ses formanifères probablement originaires de la mer Rouge voisine, a pu être soulevée, subséquemment exposée à l'air libre et sujette à une sévère érosion pendant l'Yprésien inférieur. L'absence des couches du Paléogène correspondantes serait due à ce soulèvement important plutôt qu'à une absence de sédimentation.

Stratotype
Le stratotype de l'Ilerdien moyen est aux lieux-dits Pech des Fourches et les Croisettes, inclus dans la coupe de Coustouge à Jonquières (Aude), à environ  à l'ouest de Coustouge.
Il est marqué par une grande diversité des astérides cénozoïques.

Localisation

On le trouve du nord-est de l'Espagne aux Corbières, où il est marqué par la présence de , un foraminifère encroûtant (formant récifs) de la famille des .

Le « grès de Coudures »

Le « grès de Coudures » ou « pierre de Coudures » (Landes), qui date de l'Ilerdien, est un grès quartzitique très dur, à cassure blanche ou rosée, qui se présente sous forme de blocs allongés de .
Localement cette pierre est appelée peyre d'azou (pierre d'âne) car elle considérée comme impropre à la construction.
Mais elle était exploitée autrefois pour faire des pavés,
notamment à l'ouest de Coudures en rive droite du Gabas ; en aval de Sainte-Colombe dans les bois proches de Mounon ; et au nord-ouest de Saint-Aubin.

Voir aussi

Bibliographie

 .
 .
 .
 .
 .
 .
 .
 .
 .
 .

Liens externes

Notes et références
 Notes

 Références

Éocène


text:
Elder Quotes
Santa Fe Living Treasures – Elder Stories
Berchtold, Betty
Betty Berchtold
Born in Albuquerque in 1905, Betty Berchtold attended the University of Illinois, but then was drawn back to New Mexico. With an insatiable zest for life, she held various positions in her hometown, including working in real estate. She played a formative role in the establishment in 1950 of the Council of Albuquerque Garden Clubs Inc., which went on to make flower shows a prominent part of the State Fair. She also worked ceaselessly to spread the knowledge she had gained about natural foods. But her main quest was to find a spiritual philosophy to which she could commit her life.
Coming from a line of Methodist and Presbyterian ministers, Betty was familiar with Protestantism, and also grew up with many Jewish and Catholic friends. But the more she learned about organized religion, the more she dismissed all forms of piety. She felt a reverence for life, but found structured religion false, and could not accept any "pie in the sky" doctrines, as she phrased it. "The more esoteric the doctrine, the more harm is done," she said. Then she found the Unitarian church, and the "home" she was seeking.
First in Albuquerque, then in Santa Fe, she helped small congregations blossom. In Santa Fe in the 1970s, the church welcomed hippies with sleeping bags, and had speakers ranging from drug addicts to Native Americans to medical professionals to homeless people. Open to it all, Betty watched her emotional and intellectual life expand enormously. Giving back, she became the church's "flower lady" and "health-food nut."
Entering her 90s, Betty received several awards. In 1994 came the Medal of Merit from the Garden Club of America. In 1995 the Santa Fe Salon, a local discussion group honored her, as did the Unitarian/Universalist Women's Federation. And also in 1995, Betty Berchtold became a Santa Fe Living Treasure.
Copyright © 2021 Santa Fe Living Treasures. All Rights Reserved.
Design by Story Portrait Media. Joomla! development by Santa Fe Web Design


text:
Čandragupta je jméno, jehož nositelů je více:

 Čandragupta Maurja – zakladatel Maurjovské říše, vládl okolo 322–293 př. n. l.
 Čandragupta I. – král říše Guptů, okolo 320–335 n. l.
 Čandragupta II. – král říše Guptů, okolo 375–414 n. l.


You are visiting the placeholder page for Cathy Cox. This page is here because someone used our placeholder utility to look for Cathy Cox. We created this page automatically in hopes Cathy Cox would find it. If you are not Cathy Cox, but are an alumni of Stockbridge High School Stockbridge, GA, register on this site for free now.


text:
Online Classes & Webinars
The Power of How: A journal about The Alexander Technique and Movement
WHEN YOUR HEART IS TOO BROKEN TO FIX, THE REAL WORK BEGINS
The first week of June 2020 has broken us.
Maybe like me your heart is in pieces, maybe like me you are aware that fixing it is not an option.
Words are not my native language, but I try. The day on which I wrote this was a "national day of stopping" business as usual. Stopping to look at what we have become, where we are as a culture, a country, a gathering of human beings.
This is a new level of stopping I wouldn't have come to on my own, if not for the public health crisis brought on by COVID and the senseless murders of black people in this country: George Floyd, Breonna Taylor, Tony McDade, and Ahmaud Arbery, and so many others that I don't, yet, know by name. Memory is embodied in language as "knowing something by heart." There are so many that we have never even collectively heard of, whose names are known only to their families and friends. Every day now as I write this new unknown murders of innocent black people are coming to light – all of them happening since January of this year. It's too big for my mind, but not my heart.
Without my heart my mind is useless.
What saved me this morning was picking up bell hook's book "All About Love."
It helped me to remember that I can look at everything that's happening right now as if it was all about love. My fear, pain, anger, even hatred of Trump when it comes, is all about the loss of love and the need for love, the profound effort to return, over and over again, to love of life in all things. The risk that young people are taking in the streets is a return to love. The smashing of stores is painful and often senseless, but the refusal to put profit over life is not. It makes deep sense. We have let hate become a way of life and we have to stop it.
All the work we have done to get in touch with our bodies is going to come in handy now. Your body, your true home, is so vulnerable. It has everything you need to know about racism contained in it. Your body knows what it means to feel free, to move as you wish, to have space to breath. Your body knows what it really means when you forget about how important that is for other human beings.
Your body knows what it feels like to not be free to move even an inch, to breath, to speak. George Floyds last words were words of love. If you watch the video, you don't just hear that love. You feel it in your whole body as his precious life is taken from him. Your heart knows what it is to be stomped on, enslaved, imprisoned for profit, brutalized, and beaten. Our sensitized bodies feel the violence done to others as if it was happening to us.
Our body instantly recognizes the complete disassociation expressed in the calm, cruel demeanor of policeman Derek Chauvin as he took George Floyd's precious life away. I'm grateful to feel broken, to feel angry, to feel outrage, to feel grief, to feel hope. I'm grateful to be a mess today. Today, these are the fruits of embodiment.
I'm not scared of these feelings.
I'm more scared about what will happen to us if we can no longer feel them. And that gives me courage to keep doing what I'm doing.
Get close to what you love. Hold, touch, and share it. Help each other to get close and stay close to it, whatever it is. Trust it and let it be your guide.
I want to thank the students who came to class this week and helped me to stay in touch with my body, heart, and mind in motion. And that's what we need to do – move forward in a new way. Let the old broken way go and stumble on, not knowing how we are going to end racism but knowing that we must if we love life.
There is something very important about a dance class – it's a collective revivification of ourselves in each other's presence that energizes us in a way that we cannot do on our own. Even online, this magic always visits us.
We move forward together and reconstitute our broken hearts into something new.
June 10th, 2020 • No Comments
Please complete this equation to post your comment: (required) + four =
Subscribe to Email List - this link will take you to alternate page
© Clare Maxwell — Contact
Subscribe to my email newsletter.
Photos by Lidia Sek


text:
Scammon is een plaats (city) in de Amerikaanse staat Kansas, en valt bestuurlijk gezien onder Cherokee County.

Demografie
Bij de volkstelling in 2000 werd het aantal inwoners vastgesteld op 496.
In 2006 is het aantal inwoners door het United States Census Bureau geschat op 472, een daling van 24 (-4,8%).

Geografie
Volgens het United States Census Bureau beslaat de plaats een oppervlakte van
1,6 km², geheel bestaande uit land.

Plaatsen in de nabije omgeving
De onderstaande figuur toont nabijgelegen plaatsen in een straal van 12 km rond Scammon.

Externe link

Plaats in Kansas


text:
Dunoon Burgh Hall is a municipal structure in Argyll Street, Dunoon, Scotland. The structure, which is used as an events venue, is a Category B listed building.

History
Following significant population growth, largely associated with the fishing industry, the area became a police burgh in 1868. In this context, the new police commissioners decided to procure a burgh hall: the site they selected was a piece of open land known as Gallowhill which was donated to the burgh by the local laird, James MacArthur Moir.

The foundation stone for the new building was laid with full masonic honours on 30 August 1873. It was designed by Robert Alexander Bryden in the Scottish baronial style, built in schist stone at a cost of £4,000 and was officially opened on 25 June 1874. (Bryden also designed the adjacent and now-demolished St Cuthbert's Church around the same time.) The design involved an asymmetrical main frontage with six bays facing onto Argyll Street; the left-hand section, which accommodated the main offices, featured, in the right-hand bay, an arched doorway on the ground floor and a bi-partite window on the first floor. The other bays in the left-hand section were fenestrated with bi-partite windows on the ground floor and single windows on the first floor. The right-hand section, which projected forward and accommodated the main hall, featured, in the centre bay, two segmental windows on the ground floor, two tall square-headed windows on the first floor and a stepped gable containing a rose window on the second floor. The left-hand bay in this section featured twin arched windows on the ground floor with a bartizan above, while the right-hand bay was fenestrated with a single window on the ground floor. The stained glass in the rose window, which depicted a viking, was designed and manufactured by Ballantine and Allan. Internally, the principal room was the main assembly hall which was designed to accommodate 700 people.

Pollock's Dictionary of the Clyde, published in 1888, described the building as "one of the principal edifices in the town most worthy of notice". The building was altered in 1896 to create extra capacity; the changes included the creation of a seating gallery in the main hall, the transfer of the main entrance from Hanover Street to Argyll Street and an enlarged caretakers' flat.

During the Second World War, the burgh hall was used as a centre to administer the allocation of homes for 1,000 evacuee children from Glasgow. The burgh council closed the upper floors of the burgh hall after deciding to promote the Queen's Hall, which was rebuilt in 1959, as the main events venue in the town. The burgh hall ceased to be the local seat of government when the enlarged Argyll District Council was formed in 1975.

The upper floors of the building remained empty, and its condition deteriorated: the building was sold to Dunoon and Cowal Housing Association in 1993 and then to Fyne Homes in 2001. Fyne Homes presented proposals for the redevelopment of the building at a public meeting at Dunoon Grammar School in 2002 but, following local objections, the scheme did not proceed and the condition of the building continued to deteriorate.

The John McAslan Family Trust acquired the hall from Fyne Homes for a nominal sum in 2008. The trust initiated an extensive programme of refurbishment works to convert the building into an arts and culture hub. The works, which were carried out to a design by Page\Park Architects, cost £3.5 million. The sources of funding included Creative Scotland, the Heritage Lottery Fund, Highlands and Islands Enterprise and Historic Environment Scotland. Following completion of the works, the building was reopened by the First Minister of Scotland, Nicola Sturgeon, in June 2017.

Architectural detail

A stone carving on the building's Hanover Street elevation features the initials of Robert Leslie Smith, provost of Dunoon.

See also
 List of listed buildings in Dunoon

Notes

References

Government buildings completed in 1874
1874 establishments in Scotland
City chambers and town halls in Scotland
Burgh Hall
Category B listed buildings in Argyll and Bute
Listed government buildings in Scotland
Scottish baronial architecture


text:
BUFFERD v. COMMISSIONER
BUFFERD v. COMMISSIONER, 506 U.S. 523 (1993)
BUFFERD v. COMMISSIONER(1993)
No. 91-7804
Argued: November 30, 1992Decided: January 25, 1993
Subchapter S of the Internal Revenue Code seeks to eliminate tax disadvantages that might dissuade small businesses from adopting the corporate form and to lessen the tax burden on such businesses by means of a pass-through system under which corporate income, losses, deductions, and credits are attributed to individual shareholders in a manner akin to the tax treatment of partnerships. Petitioner Bufferd, a shareholder in an S corporation, Compo Financial Services, Inc., claimed on his 1979 income tax return a pro rata share of a loss deduction and investment tax credit reported by Compo on its return for the 1978-1979 tax year. Code 6501(a) establishes a generally applicable statute of limitations allowing the Internal Revenue Service to assess tax deficiencies "within 3 years after the return was filed." (Emphasis added.) As provided in 6501(c)(4), Bufferd extended the limitations period on his return, but no extension was obtained from Compo with respect to its return. In 1987, the Commissioner determined that the loss deduction and credit reported by Compo were erroneous, and sent a notice of deficiency to Bufferd based on the deduction and credit he had claimed on his return. The Tax Court found for the Commissioner, rejecting Bufferd's argument that the claim was time-barred because the disallowance was based on an error in Compo's return, for which the 3-year period had lapsed. The Court of Appeals affirmed, holding that, where a tax deficiency is assessed against a shareholder, the filing date of the shareholder's return is the relevant date for purposes of 6501(a).
The limitations period for assessing the income tax liability of an S corporation shareholder runs from the date on which the shareholder's return is filed. Plainly, "the" return referred to in 6501(a) is the return of the taxpayer against whom a deficiency is assessed, since the Commissioner can only determine whether the taxpayer understated his tax obligation and should be assessed a deficiency after examining his return. That Compo erroneously asserted a loss and credit to be passed through to its shareholders is of no consequence. The errors did not and could not affect Compo's tax liability, and hence the Commissioner could only assess a deficiency against the shareholder whose return claimed the benefit of the errors. By contrast, the S [506 U.S. 523, 524] corporation's return does not contain all of the information necessary to compute a shareholder's taxes, and thus should not be regarded as triggering the period of assessment. Cf. Automobile Club of Mich. v. Commissioner, 353 U.S. 180, 188 . The statutory evidence and policy considerations proffered by Bufferd offer no basis for questioning this conclusion. Pp. 526-533.
952 F.2d 675, affirmed.
WHITE, J., delivered the opinion for a unanimous Court.
Stuart J. Filler, by appointment of the court, 506 U.S. 809 , argued the cause for petitioner. With him on the briefs were Toni Robinson and Mary Ferrari.
Kent L. Jones argued the cause for respondent. With him on the brief were Solicitor General Starr, Acting Assistant Attorney General Bruton, Deputy Solicitor General Wallacce, Ann B. Durney, and Janet Kay Jones. *
[ Footnote * ] Briefs of amici curiae urging reversal were filed for Arthur H. Boelter and John J. White, Jr., pro se; and for Charles T. Green et al. by Robert I. White.
JUSTICE WHITE delivered the opinion of the Court.
On his 1979 income tax return, petitioner, a shareholder in a Subchapter S corporation, claimed as "pass-through" items portions of a deduction and a tax credit reported on the corporation's return. The question presented is whether the 3-year period in which the Internal Revenue Service is permitted to assess petitioner's tax liability runs from the filing date of the individual return or the corporate return. We conclude with the Tax Court and the Court of Appeals for the Second Circuit that the relevant date is that on which petitioner's return was filed.
Subchapter S of the Internal Revenue Code, 26 U.S.C. 1361-1379, was enacted in 1958 to eliminate tax disadvantages that might dissuade small businesses from adopting [506 U.S. 523, 525] the corporate form and to lessen the tax burden on such businesses. The statute accomplishes these goals by means of a pass-through system under which corporate income, losses, deductions, and credits are attributed to individual shareholders in a manner akin to the tax treatment of partnerships. See 1366-1368. 1 In addition, since 1966, "S corporations" have been liable for certain capital gains and other taxes. 80 Stat. 111, 113; 26 U.S.C. 1374, 1378.
Petitioner was treasurer and a shareholder of Compo Financial Services, Inc., an S corporation. On February 1, 1980, Compo filed a return for the tax year of December 26, 1978, to November 30, 1979, as required by 6037(a) of the Code. 2 On that return, Compo reported a loss deduction and an investment tax credit arising from its partnership interest in a venture known as Printers Associates. Petitioner and his wife filed a joint return for 1979 on April 15, 1980. 3 Their return claimed a pro rata share of the deduction and credit reported by Compo pursuant to the pass-through provisions of Subchapter S.
Code 6501(a) establishes a generally applicable statute of limitations providing that the Internal Revenue Service may assess tax deficiencies within a 3-year period from the date [506 U.S. 523, 526] a return is filed. 4 That limitations period may be extended by written agreement. 6501(c)(4). In March, 1983, before three years had passed from the time the joint return was filed, petitioner agreed to extend the period in which deficiencies arising from certain claims on the return could be assessed against him. No extension was obtained from Compo with respect to its return for the 1978-1979 tax year.
In 1987, the Commissioner determined that the loss deduction and credit reported by Compo were erroneous, and sent a notice of deficiency to petitioner based on the loss deduction and credit that he had claimed on his return. In the Tax Court, petitioner contended that the Commissioner's claim was time-barred because the disallowance was based on an error in Compo's return, for which the 3-year assessment period had lapsed. The Tax Court found for the Commissioner, relying on its decision in Fehlhaber v. Commissioner, 94 T.C. 863 (1990), aff'd, 954 F.2d 653 (CA11 1992). See App. 61. The Court of Appeals for the Second Circuit affirmed, holding that, where a tax deficiency is assessed against the shareholder, the filing date of the shareholder's return is the relevant date for purposes of 6501(a). 952 F.2d 675 (1992). Because another Court of Appeals has a contrary view, we granted certiorari. 505 U.S. 1203 (1992). 5
Title 26 U.S.C. 6501(a) states simply that "the amount of any tax imposed by this title shall be assessed within 3 [506 U.S. 523, 527] years after the return was filed. . . ." The issue before us is whether "the" return is that of petitioner or that of the corporation which was the source of the loss and credit claimed on petitioner's return. Petitioner's position is that the Commissioner had three years from the date his return was filed to object to that return in any respect except the loss and credit items passed through to him by the corporation. To disallow those items, petitioner argues, the Commissioner must have acted within three years of the filing of the corporate return. Under this approach, "the" return referred to in 6501(a) becomes two returns, and petitioner claims that there is adequate statutory basis for his submission. We have no doubt that the courts below properly concluded, as the Commissioner argued, that it is the filing of petitioner's return that triggers the running of the statutory period.
The Commissioner can only determine whether the taxpayer understated his tax obligation and should be assessed a deficiency after examining that taxpayer's return. Plainly, then, "the" return referred to in 6501(a) is the return of the taxpayer against whom a deficiency is assessed. Here, the Commissioner sought to assess taxes which petitioner owed under the Code because his return had erroneously reported a loss and credit to which he was not entitled. The fact that the corporation's return erroneously asserted a loss and credit to be passed through to its shareholders is of no consequence. In this case, the errors on the corporate return did not and could not affect the tax liability of the corporation, and hence the Commissioner could only assess a deficiency against the stockholder-taxpayer whose return claimed the benefit of the errors. Under the plain language of 6501(a), the Commissioner's time to make the assessment ran from the filing date of petitioner's return. 6 [506 U.S. 523, 528]
By contrast, the S corporation's return, which petitioner asserts triggers the beginning of the limitations period, is deficient precisely because it does not contain all of the information necessary to compute a shareholder's taxes. If the Internal Revenue Service were required to rely on that return, it would be forced to conduct its assessment on the basis of incomplete information:
"While [the corporate return] may show petitioner's distributive share of losses, it does not indicate his adjusted basis in his corporate stock, which is information necessary to determine if the loss is deductible. Nor does it show petitioner's income, losses, deductions, and credits from other sources. Moreover, the information return of the S corporation does not relate to the same taxable period as petitioner's return. . . ." Fehlhaber, supra, at 869 (citation omitted).
As noted in analogous cases, tax returns that "lack the data necessary for the computation and assessment of deficiencies" generally should not be regarded as triggering the period of assessment. Automobile Club of Mich. v. Commissioner, 353 U.S. 180, 188 (1957) (citing Commissioner v. Lane-Wells Co., 321 U.S. 219 (1944)). 7
Petitioner asserts that 6501(a) supports a contrary view when read in light of two related Code provisions pertaining [506 U.S. 523, 529] to S corporations. Section 6012(a)(2) requires both Subchapter C and Subchapter S corporations to file income tax returns. 8 Section 6037(a) specifies the information that each S corporation's return must provide (including "each shareholder's pro rata share of each item of the corporation") and further states that: "any return filed pursuant to this section shall, for purposes of [26 U.S.C. 6501-6531], be treated as a return filed by the corporation under section 6012."
We do not see that these provisions aid petitioner's cause. Read together, 6012(a)(2), 6037(a), and 6501(a) establish only that each S corporation must file a tax return containing certain information, and that a Commissioner desiring to make an assessment must act within three years of filing. Nothing on the face of these provisions demonstrates that an individual's income tax return is brought within the compass of 6037(a)'s reference to "any return" simply because a portion of that return reports income and losses that have passed through from the return of an S corporation. If anything, the phrase "[a]ny return filed pursuant to this section," coupled with the fact that 6037(a) is concerned with describing the contents of the corporation's return, indicates that the provision is not meant to determine when the assessment period for a shareholder's individual tax return begins.
Petitioner argues that this reading of the relevant provisions runs afoul of the fact that, prior to 1966, S corporations were not subject to taxation. According to petitioner, no purpose would have been served by establishing an assessment period that applied to returns reporting corporate income on which no taxes could be assessed, but not to the returns [506 U.S. 523, 530] of corporate stockholders. This argument fails because, even in the period when the S corporation could not be taxed, examination of a corporation's return was necessary to determine if it could lay valid claim to Subchapter S status. Section 6037(a) thus originally functioned to set the starting date of the 3-year period within which that determination had to be made. See United States v. Adams Building Co., 531 F.2d 342, 343, n. 2 (CA6 1976); see also 952 F.2d, at 677 (citing Fehlhaber v. Commissioner, 94 T.C. 863 1990). 9 Petitioner maintains that such a function would be superfluous because, if the election of S corporation status were found invalid, the corporation's return would "automatically be subject to the existing rules for C corporations." Brief for Petitioner 38. But this proposition is hardly self-evident, and petitioner cites no authority to support it. In the absence of 6037(a), the Internal Revenue Service could claim that a corporation which files a return containing an erroneous election of Subchapter S status has failed to file any return, which would allow the Service to issue a notice of deficiency with respect to the return "at any time." See 6501(c)(3); cf. Germantown Trust Co. v. Commissioner, 309 U.S. 304, 307 (1940); Mason v. United States, 801 F.Supp. 718, 721 (ND Ga. 1992). 10 [506 U.S. 523, 531]
The Ninth Circuit's rejection, in Kelley v. Commissioner, 877 F.2d 756 (1989), of the view adopted by the Commissioner was prompted in part by a concern to avoid unfairly [506 U.S. 523, 532] burdening shareholders, who might find it difficult to obtain corporate records necessary to defend against a deficiency assessment based on an adjustment made to a corporation's return years after it was filed. The Fifth Circuit's opinion by Judge Goldberg in Green v. Commissioner, 963 F.2d 783 (1992), neatly summarizes the appropriate response to that concern:
"First, it is not unfamiliar in the world of tax to have `an individual's income tax return . . . dependent on records maintained by another entity.' Fehlhaber, 954 F.2d at 658 (citing partnership and trust taxation as examples). Second, the rule generally does not impose an undue burden on the corporation or the shareholder. . . . A shareholder can "take the necessary steps to ensure that the corporation preserves the relevant records." Id. Such protective steps simply do not constitute an overly oppressive task for the shareholder. Bufferd, 952 F.2d at 678. . . . Finally, we reject any suggestion that we elevate the "perceived unfairness to taxpayers" over our duty to strictly construe in favor of the government a statute of limitation when the petitioner seeks application of the statute so as to bar the rights of the government. Fehlhaber, 954 F.2d at 658. Id., at 789. 11 [506 U.S. 523, 533]
As found by the courts below, the plain language of 6501(a) supports the Commissioner. The statutory evidence and policy considerations proffered by petitioner offer no basis for questioning this conclusion. We hold that the limitations period within which the Internal Revenue Service must assess the income tax liability of an S corporation shareholder runs from the date on which the shareholder's return is filed. The judgment of the Court of Appeals is affirmed.
It is so ordered
[ Footnote 1 ] Subchapter S was substantially amended and recodified by the Subchapter S Revision Act of 1982, 96 Stat. 1669. The pass-through provisions in effect in the period relevant to this case, see 26 U.S.C. 1373-1374 (1976 ed.), differ in certain respects from the present provisions. These differences do not affect the case.
[ Footnote 2 ] In relevant part, the statute reads:
" 6037. Return of S corporation
"(a) In general
"Every S corporation shall make a return for each taxable year, stating specifically the items of its gross income and the deductions allow able by subtitle A [and other information]. Any return filed pursuant to this section shall, for purposes of chapter 66 (relating to limitations), be treated as a return filed by the corporation under section 6012."
[ Footnote 3 ] Phyllis Bufferd settled separately with the Commissioner, and is not a party to this action.
[ Footnote 4 ] The statute reads in part:
" 6501. Limitations on assessment and collection
"(a) General rule
"Except as otherwise provided . . . the amount of any tax imposed by this title shall be assessed within 3 years after the return was filed. . . ."
[ Footnote 5 ] Kelley v. Commissioner, 877 F.2d 756 (CA9 1989), held that the filing date of the corporation's return controls. The Eleventh and Fifth Circuits have joined the Second Circuit in declining to follow Kelley. See Green v. Commissioner, 963 F.2d 783 (CA5 1492); Fehlhaber v. Commissioner, 954 F.2d 653 (CA11 1992).
[ Footnote 6 ] Even if it could credibly be argued that 6501(a) is ambiguous because it does not expressly indicate how it is to be applied to S corporations and their stockholders, the Commissioner's construction of [506 U.S. 523, 528] the section is a reasonable one to say the least, and we should accept it absent convincing grounds for rejecting it. As noted in Badaracco v. Commissioner, 464 U.S. 386 (1984), "`limitations statutes barring the collection of taxes otherwise due and unpaid are strictly construed in favor of the Government.'" Id., at 392 (quoting Lucia v. United States, 474 F.2d 565, 570 (CA5 1973)).
[ Footnote 7 ] In these circumstances, the incompleteness of the corporate return provides a reason for doubting petitioner's understanding of the Code. We do not thereby suggest that, for cases in which a corporate return does supply all of the information necessary to process a shareholder's return, the mere fact of completeness is sufficient to establish the corporate return as "the" return of 6501(a).
[ Footnote 8 ] Section 6012(a)(2) reads:
" 6012. Persons required to make returns of income
"Returns with respect to income taxes under subtitle A shall be made by the following: . . .
"(2) Every corporation subject to taxation under subtitle A. . . ."
[ Footnote 9 ] Since S corporations are now subject to limited taxation, 6037(a) serves the additional function of determining the assessment period for those taxes. See 952 F.2d, at 678.
[ Footnote 10 ] Petitioner's reading of 6037(a) is sufficiently lacking in textual support to obviate any need to examine legislative history. However, several courts have noted that the history of 6037 contains evidence in support of the Commissioner's interpretation. See, e.g, Green v. Commissioner, 963 F.2d, at 788-790; Fehlhaber v. Commissioner, 954 F.2d, at 656-657. Section 6037(a) was introduced in the Technical Amendments Act of 1958, 72 Stat. 1606, 1656. The Senate Report explaining the provision states:
"Notwithstanding the fact that an electing small business corporation is not subject to the tax imposed by chapter 1 of the 1954 Code, such corporation must make a return for each taxable year in accordance with new section 6037. . . . Such return will be considered as a return filed under section 6012 for purposes of the provisions of chapter 66, relating to limitations. Thus, for [506 U.S. 523, 531] example, the period of limitation on assessment and collection of any corporate tax found to be due upon a subsequent determination that the corporation was not entitled to the benefits of subchapter S, will run from the date of filing of the return required under the new section 6037." S.Rep. No. 1983, 85th Cong., 2d Sess., 226 (1958).
Although the passage would seem to support the Commissioner's view, petitioner, following the reasoning of the Ninth Circuit in Kelley v. Commissioner, 877 F.2d 756 (1989), maintains that the phrase "for example" necessarily implies that the Senate also had in mind the present case. This implication is hardly necessary: The phrase just as easily could have been meant to avoid foreclosing other applications of section 6037(a) to corporate returns. Indeed, had "for example" been omitted, the Commissioner could now rely on this passage to argue that the period for assessing capital gains taxes under 26 U.S.C. 1374 is not controlled by 6037(a), but is instead governed by the filing date of a shareholder's return or some other triggering event. Likewise, in the absence of the phrase, it could be argued that, because the legislative history refers exclusively to a case in which taxes are assessed against a corporation that erroneously claims Subchapter S status, the period in which penalties may be assessed against the corporation should not be governed by 6037(a).
The Commissioner claims additional support in the Senate Report accompanying the 1982 amendments to Subchapter S, which states in relevant part:
"Under present law, a taxpayer's individual tax liability is determined in proceedings between the Internal Revenue Service and the individual whose tax liability is in dispute. Thus, any issues involving the income or deductions of a subchapter S corporation are determined separately in . . . proceedings involving the individual shareholder whose tax liability is affected. Statutes of limitations apply at the individual level, based on the returns filed by the individual. The filing by the corporation of its return does not affect the statute of limitations applicable to the shareholders." S.Rep. No. 97-640, p. 25 (1982).
This passage is of little value to either side. While the views of a Congress engaged in the amendment of existing law as to the intent behind that law are "entitled to significant weight," Seatrain Shipbuilding Corp. v. Shell Oil Co., 444 U.S. 572, 596 (1980), in this instance, the Report's account of "present law" may have been colored, if not wholly determined, by the Tax Court, which had already adopted the view espoused by the [506 U.S. 523, 532] Commissioner. See Leonhart v. Commissioner, 27 TCM 443 (1968), § 68,098 P-H Memo TC, aff'd on other grounds, 414 F.2d 749 (CA4 1969).
[ Footnote 11 ] Petitioner additionally asserts that the returns of shareholders of a Subchapter C corporation cannot be adjusted after the limitations period has run for assessing the corporation's return, and that therefore S corporation shareholders are entitled to identical treatment. Brief for Petitioner 11-12, 21-22. However, petitioner has not provided a single authority in support of the premise of this assertion. At oral argument, the Commissioner maintained that the opposite is the case, see Tr. of Oral Arg. 2728, relying mainly on Commissioner v. Munter, 331 U.S. 210 (1947), which, without addressing the limitations issue, allowed an adjustment of shareholders' 1940 taxes based upon the Commissioner's finding that, at the time of its creation by merger in 1928, the corporation had acquired the accumulated earnings and profits of its predecessor [506 U.S. 523, 533] corporations. A recent Tax Court decision also provides indirect support for the Commissioner's view:
"We have held that the relevant return for determining whether, at the time a deficiency notice was issued, the period for assessment had expired under section 6501(a) "is that of petitioner against whom respondent has determined a deficiency." [citing Fehlhaber, 94 T.C., at 868.] We have maintained that position consistently, without regard to the nature of the source entity involved. See [cases involving partnerships, trusts, and S corporations]. Lardas v. Commissioner, 99 T.C. 490, 493 (1992).
In any event, it is doubtful that petitioner's conclusion follows from his premise, for the taxation of C corporations and their stockholders is so markedly different from that of S corporations. [506 U.S. 523, 534]


text:
\section{Introduction}

We begin with a special case of the main result of this paper.

\begin{proposition}\label{propparam} Let $M$ be an o-minimal expansion of a
  dense linear order $(M,<)$.  Let $f:M^n\times M\longmapsto M$ be definable in
  $M$.  Then there exist functions $g:M\longmapsto M$ and $h:M^n\longmapsto M$
  definable in $M$ such that $f(x,t)\le g(t)$ for all $x\in M^n$ and $t>h(x)$.
  Moreover, if $M'$ is the prime model containing the parameters used to define
  $f$, then $g$ and $h$ are defined over $M'$.  \end{proposition}

This was already known under the additional assumption that $M$ expands an
ordered group; see 3.1 of \cite{FM5}, which uses \cite[C.4]{vdDMi96} and
\cite{MiSt98}.  Here, we remove the need for the group structure.  Indeed, we
show something stronger.

\begin{theorem}\label{paramsbounded} Let $M$ be an
  o-minimal expansion of a dense linear order $(M,<)$.  Let $f$ be an $n+1$-ary
  $M$-definable function with domain $A\times M$ for some $A\subseteq M^n$.
  Suppose that, for some $b\in M\cup\{\infty\}$ and all $x\in A$, we have
  $\lim_{t\to b^-}f(x,t)=b$ and $f(x,t)<b$.  Then there exist functions
  $g:M\longmapsto M$ and $h:A\longmapsto M$ definable in $M$ such that $h(A)<b$
  and for $t\in(h(x),b)$, we have $g(t)\in [f(x,t),b)$.  Moreover, if $M'$ is
  the prime model containing the parameters used to define $f$, then $g$ and $h$
  are defined over $M'$.\end{theorem}

If $M$ expands a field, then using the maps $1/(b-t)$ and $b-1/t$ this theorem
follows easily from 3.1 of \cite{FM5}.  When $b=\infty$ and $M$ expands an
ordered group, this is essentially 3.1 of \cite{FM5}.  However, this result is
new if $M$ does not expand a group, or if $M$ does not expand a field and $b\in
M$.

Corollary \ref{cor} strengthens the theorem slightly, allowing $f$ to take any
value as its limit, from either direction.  Note that if Corollary \ref{cor} is
applied in the case that $f$ is definable in the prime model of an o-minimal
theory, this shows that any definable function is bounded as it approaches a
limit by one definable in the prime model, assuming the limit is in the prime
model or $\pm\infty$.

We use the terminology of \cite{Tressl05a}: the definable $1$-types in an
o-minimal theory are called ``principal.''  To each principal type over a
structure $M$ is associated a unique element $a\in M\cup\{\pm\infty\}$ to which
it is ``closest,'' in the sense that no elements of $M$ lie between $a$ and any
realization of the type.  We say that a principal type is ``principal
above/below/near $a$.''  We write $\langle a_1,\ldots,a_n\rangle$ to denote the
tuple of length $n$ having the element $a_i$ as its $i$th component.

\section{Results}

\begin{proof}[Proof of Theorem \ref{paramsbounded}]
We first note that the theorem is equivalent to the following:

\begin{claim}\label{modelclaim} Let $P$ be the prime model of the theory of $M$,
  let $b\in P\cup\{\infty\}$, and let $A\subseteq M^n$ be a
  $\emptyset$-definable set.  Let $f(x,t):A\times M\longmapsto M$ be a
  $\emptyset$-definable function and $a\in A$ a tuple, with $\lim_{t\to
    b^-}f(a,t)=b$ and $f(a,t)<b$ for all $t<b$.  Then there exists a
  $\emptyset$-definable function $g:M\longmapsto M$ such that $g(t)\in [f(a,t),b)$ for
  $t$ sufficiently close to $b$.  Similarly if the limit is taken as $t$
  approaches $b$ from above and $f$ approaches $b$ from above, with $b\in
  M\cup\{-\infty\}$.  \end{claim}

The theorem implies Claim \ref{modelclaim}, since the fact that $g$ bounds $f$
transfers to elementary extensions.  Inversely, if the theorem failed, then we
could add the parameters needed to define $f$ to the language, so that $f$ would
become $\emptyset$-definable, and then by compactness we could find $a$ in an
elementary extension of $P$ such that the claim failed.  (Note that $b$ is
definable from the parameters used to define $f$.)  Therefore, we prove Claim
\ref{modelclaim}.

\begin{notation}
  Let $w$ be an element in some elementary extension of $M$ that realizes the
  principal type below $b$ over $M$.  In other words, $w$ is infinitesimally
  close to $b$ with respect to $M$.  It is easy to see that all $M$-definable
  functions extend to this elementary extension, and that if $\varphi$ is any
  $\emptyset$-definable (respectively $M$-definable) predicate, $\varphi(w)$
  holds if and only if $\varphi(t)$ holds for all $t$ in some interval $(c,b)$,
  with $c\in P$ (respectively $c\in M$).  Thus, whenever we write $\varphi(w)$,
  the reader should understand this as equivalent to ``$\varphi(t)$ for all $t$
  in some interval with right endpoint $b$ and left endpoint definable over the
  same parameters used to define $\varphi$.''  \end{notation}

We go by induction on the length of $a$, simultaneously for all o-minimal
structures, all $\emptyset$-definable functions, and all tuples of appropriate
length.  Let $f(x,t)$ and $a$ satisfy the conditions of Claim \ref{modelclaim}
for some $b$.  If $a=\langle a_1,\ldots,a_n\rangle$ with $n>1$, we can add
constants for $a_1,\ldots,a_{n-1}$ to the language and use induction for the
cases of $n-1$ and $1$ to prove the claim.  Thus, we may suppose that $a$ is a
singleton.  If $a\in P$, then the claim is trivial, so suppose not.

We can use regular cell decomposition \cite[2.19(2)]{vdDries98} to ensure that
$f$ is monotone in $x$ and increasing in $t$ on its two-dimensional domain cell,
$C$, which we can take to be
\begin{equation*}
\{\langle x,t\rangle\mid x\in(d_1,d_2)\land k(x)<t<b\},
\end{equation*}
for some $\emptyset$-definable monotone function $k$ and $d_1,d_2\in
P\cup\{\pm\infty\}$ (with $d_1<a<d_2$).  We may also require that $f(C)<b$.

The case where $f(x,w)$ is constant in $x$ at $a$ is easy by standard
o-minimality arguments, since then the value $f(a,w)$ is definable from $w$
without using $a$.  Thus, we may suppose that $f(x,t)$ is non-constant in $x$ at
$a$, for all $t\in(k(a),b)$.  Without loss of generality, assume that $f$ is
increasing in $x$ on $C$.

If $\tp(a)$ is not principal below $d_2$, then we can choose $a'\in P$ with
$a<a'<d_2$.  Then $f(a',t)> f(a,t)$ for $t\in(\max\{k(a),k(a')\},b)$, and so we
are done.  Thus, we may suppose that $\tp(a)$ is principal below $d_2$.

The proof relies on the following claim.

\begin{claim}\label{tpinter}
Let $p\in S_1(\emptyset)$ be the principal type below $b$.  If there is no
$\emptyset$-definable map between $\tp(a)$ and $p$, then Claim \ref{modelclaim}
holds.
\end{claim}
\begin{proof}
  If $k(a)\models p$, then $k$ is the desired map between $\tp(a)$ and $p$.
  Thus, we can assume that $k(a)<c$ for some $c\in P$ with $c<b$.  Increasing
  $d_1$ if necessary, we may also assume that $c\ge\sup\{k(x)\mid x\in
  (d_1,d_2)\}$, so if $t\in (c,b)$ and $x\in(d_1,d_2)$, then $\langle
  x,t\rangle\in C$.  Now consider the formula
\begin{equation*}
    \varphi(t)\mycoloneqq \sup\{f(x,t)\mid x\in(d_1,d_2)\}=b.
\end{equation*}
First, suppose that $\varphi(w)$ does not hold.  Then, for any $t$
sufficiently close to $b$,
\begin{equation*}
  \sup\{f(x,t)\mid x\in (d_1,d_2)\}<b.
\end{equation*}
Let $z(t)$ be this (uniformly $t$-definable) supremum.  Then
$z(t)\in[f(a,t),b)$, and so Claim \ref{modelclaim} holds.  Thus, the case that
remains to consider is when $\varphi(w)$ does hold.  We can then fix
$t_0\in(c,b)$ with $t_0\in P$ such that $\varphi(t_0)$ holds, and we have a
$\emptyset$-definable map, $f(x,t_0)$.  We show $f(a,t_0)\models p$.  For any
$e\in P$ with $e<b$, we can find $r\in (d_1,d_2)\cap P$ such that
$f(r,t_0)\in(e,b)$, by $\varphi(t_0)$.  Since $r<a$ (else $a$ would not be
principal below $d_2$) and $f(x,t_0)$ is increasing in $x$, we have
$f(a,t_0)>f(r,t_0)>e$.  Thus, $f(a,t_0)\models p$, witnessing the
$\emptyset$-definable map between $\tp(a)$ and $p$.
\end{proof}

We now complete the proof of Claim 2.1.  By Claim \ref{tpinter}, we can assume
that $\tp(a)$ is principal below $b$.  Then the domain cell $C$ has the form
\begin{equation*} \{\langle x,t\rangle\mid x\in(d_1,b)\land k(x)<t<b\}.
\end{equation*}

If $k(w)\ge f(a,w)$, then we are done, so we may assume that $f(a,w)>k(w)$.
Then we may increase $d_1$ and suppose that for any $x\in(d_1,b)$ we have
$f(x,w)>k(w)$, as well as $f(x,w)>w$.  Fix $e\in P$ with $e\in(d_1,b)$.  We have
$f(e,w)>k(w)$.  Then $\langle w,f(e,w)\rangle\in C$.  For any $t\in(a,b)$, since
$f(e,t)>t$ and $f$ is increasing in both coordinates, $f(t,f(e,t))>f(a,t)$.  So
we are done, since $f(t,f(e,t))$ is $\emptyset$-definable and
$f(t,f(e,t))\in(f(a,t),b)$ for $t$ sufficiently close to $b$ -- namely, for
$t\in(a,b)$.  \end{proof}

\begin{corollary}\label{cor} Theorem \ref{paramsbounded} holds when $\lim_{t\to
    b^{\pm}}f(x,t)=c$, with $c\in M\cup\{\pm\infty\}$ and $f$ approaching $c$
  from either direction, with $g$ and $h$ now definable over the prime
  model containing $c$ and the parameters defining $f$.  \end{corollary}
\begin{proof} Suppose that the limit is taken as $t$ approaches $b$ from below
  and that $f(x,t)$ approaches $c$ from above.  The other cases are similar.
  Let $P$ be the prime model of the statement.  Choose $a\in A\cap P^n$.  Let
  $\psi(t)$ denote the inverse of $f(a,t)$, so $\psi$ is $\emptyset$-definable.
  Then for any $x\in M^n$, the limit of $\psi(f(x,t))$ is $b$ as $t$ goes to
  $b$, and this value approaches $b$ from below.  By Theorem
  \ref{paramsbounded}, there are $\emptyset$-definable $\tilde g$ and $\tilde h$
  with $\tilde g(t)\in [\psi(f(x,t)),b)$ for $t\in(\tilde h(x),b)$.  Then for
  $t\in(\tilde h(x),b)$, we have $f(a,\tilde g(t))\in(c,f(x,t)]$.  Since
  $f(a,\tilde g(t))$ is still $\emptyset$-definable, $f(a,\tilde g(t))$ is the
  desired function $g$, and $\tilde h$ is the desired function $h$.  \end{proof}

redpajama_set_name: RedPajamaArXiv


In pressurized water reactors (PWRs), light water is used as coolant in the primary side. Boron (as boric acid) is added to the coolant to absorb neutrons, thus controlling reactivity. Lithium hydroxide assures the alkaline pH value to prevent corrosion. This application allows to measure lithium content besides high boric acid concentrations. AN-C-138 shows the respective trace metal determination on the same system setup.