text:
Site C construction along the Peace River, October 2018. Photo: Garth Lenz / The Narwhal
The Site C dam is a 1,100 megawatt hydro dam currently under construction on the Peace River in northeastern British Columbia, Canada.
The dam has been proposed since the 1970s and, if completed, would be the third dam on the Peace River. With a price tag of $16 billion, Site C is both the costliest dam in Canadian history and the most expensive publicly funded infrastructure project in B.C. history.
The B.C. government gave Site C the go-ahead in December 2014, but the dam faced several court challenges from landowners and First Nations who oppose flooding 128 kilometres of the Peace River and its tributaries, putting Indigenous burial grounds, traditional hunting and fishing areas, habitat for more than 100 species vulnerable to extinction and some of Canada's richest farmland under up to 50 metres of water.
Harry Swain, the chair of the joint federal-provincial panel that reviewed the Site C dam, criticized the B.C. government's actions on the dam in March 2015, in comments called "unprecedented" by environmental law experts.
Two Treaty 8 First Nations are awaiting court dates for civil actions that allege the Site C dam and the two previous dams on the Peace River unjustifiably violate their constitutionally protected treaty rights.
Construction started on the dam in fall 2015 and B.C. Premier Christy Clark vowed to get the project past the "point of no return" before the May 2017 election. Local farmers and First Nations members prevented logging at historic Rocky Mountain Fort for two months, but BC Hydro won an injunction against them in March 2016 and the camp was removed.
The Site C dam became a major election issue in the May 2017 B.C. election, with the B.C. NDP vowing to send the Site C dam for an independent review by the B.C. Utilities Commission if elected. The NDP were sworn in as the new government of British Columbia on July 18 and sent the dam for an expedited review by the B.C. Utilities Commission shortly after. A final report released Nov. 1 found the project is behind schedule and over budget and could be replaced by alternatives for $8.8 billion or less.
The B.C. government announced it would proceed with Site C on December 11, 2017. On Feb. 26, 2021, Premier John Horgan reiterated his commitment to build the dam, raising the budgeted cost from $10.7 billion to $16 billion amid growing geotechnical problems.
For weekly updates on our reporting, sign up for The Narwhal's newsletter.
Latest News about "Site C Dam"
How the Blueberry ruling in B.C. is a gamechanger for the Site C dam, extractive industries and Indigenous Rights
By Matt Simmons (Local Journalism Initiative Reporter)
Nov. 1, 2021 12 min. read
In a precedent-setting ruling, B.C.'s Supreme Court found the province guilty of breaching its obligations...
B.C. pays Blueberry River First Nations $65 million as 195 projects approved before court victory proceed
Oct. 7, 2021 4 min. read
In 'long overdue' initial agreement, the province will support the nations' efforts to restore habitat...
Site C dam, oilsands pushing Canada's largest national park closer to endangered list
By Judith Lavoie
June 22, 2021 7 min. read
Despite repeated calls for action from the UNESCO World Heritage Committee, Canada has failed to...
The Narwhal's Site C dam investigation wins Canadian Journalism Foundation award for exemplary journalism
By Carol Linnitt
June 9, 2021 3 min. read
Sarah Cox's 'ground-breaking reporting' to expose secrecy around B.C.'s most expensive public infrastructure project was...
BC Hydro, province ordered to release secret Site C dam docs to West Moberly First Nations
By Sarah Cox
May 6, 2021 6 min. read
Reports and internal records, which will be released as part of a landmark Treaty Rights...
The Narwhal's Sarah Cox wins World Press Freedom Award for Site C dam investigation
By Arik Ligeti
The honour from World Press Freedom Canada is a recognition of Cox's efforts to overcome...
How government scientists tried — but failed — to protect endangered bats from a Site C dam quarry
April 25, 2021 27 min. read
The perfect coincidence of geothermally heated cliffs, a deciduous forest and wetlands created a unique...
The Narwhal named finalist for CJF Jackman Award for Excellence in Journalism
The Narwhal is recognized for 'ground-breaking reporting' based on freedom of information requests on the...
'It's blown me away': Sheryl Lightfoot becomes first Indigenous woman from Canada appointed to UN expert body
By Brishti Basu
Canada is 'behind on almost everything' when it comes to implementing the historic UN Declaration...
'We need to learn to do things faster': Canada's new environment minister talks climate — and compromise
By Caitlin Stall-Paquet
Jan. 9, 2022 18 min. read
Canada's new environment and climate change minister has some first-hand experience when it comes to living in a resource town that goes through boom and...


So after today, we're never talking about this again. I made a pie crust with spelt flour, which has provided good results for my muffins, and terrible results in my cookies. Add pastry dough to the list of items I will never make with spelt again.
The dough was very thick, and tore terribly while I was rolling it. I had planned to make two pies but gave up after rolling out the first. It was just way too difficult to work with.
This pie was doomed from the start, Boyfriend Unit had a tough time coring the apples, they were very hard. The taste of the pastry wasn't to my liking.
It's not bad, I mean it's apple pie so GET IN MY MOUTH, it's just not what I'm accustomed to producing. Back to the drawing board.
Picked up a waffle maker last week and made some waffle batter today.
Making waffles was way easier than I thought.
I put the batter together and Boyfriend Unit cooked them.
This is the very first one. There is a small learning curve about how much batter to use.
This is the same recipe as the first vegan muffins with two minor additions. They turned out great for a healthy and delicious breakfast.
I used the organic lemon extract I purchased at The Spice Trader, and added ground cinnamon. These were so good fresh out of the oven, Boyfriend Unit just woke up as they finished and we ate them for breakfast. The smelled so amazing.


text:
/**
 * @constructor
 *
 * @param {double}
 * 			distanceTolerance
 * @param {boolean}
 *          isEnsureValidTopology
 */
jsts.simplify.DPTransformer = function(
    distanceTolerance, isEnsureValidTopology) {
  this.distanceTolerance = distanceTolerance;
  this.isEnsureValidTopology = isEnsureValidTopology;
};

jsts.simplify.DPTransformer.prototype = new jsts.geom.util.GeometryTransformer();

/**
 * @type {double}
 */
jsts.simplify.DPTransformer.prototype.distanceTolerance = null;

/**
 * @type {boolean}
 */
jsts.simplify.DPTransformer.prototype.isEnsureValidTopology = null;

/**
 * @param {jsts.geom.CoordinateSequence}
 *          coords
 * @param {jsts.geom.Geometry}
 *          parent
 * @return {jsts.geom.CoordinateSequence}
 */
jsts.simplify.DPTransformer.prototype.transformCoordinates = function(
    coords, parent) {
  var inputPts = coords;
  var newPts = null;
  if (inputPts.length == 0) {
    newPts = [];
  } else {
    newPts = jsts.simplify.DouglasPeuckerLineSimplifier.simplify(inputPts, this.distanceTolerance);
  }
  return newPts;
};

/**
 * Simplifies a polygon, fixing it if required.
 * @param {jsts.geom.Polygon}
 *          geom
 * @param {jsts.geom.Geometry}
 *          parent
 * @return {jsts.geom.Geometry}
 */
jsts.simplify.DPTransformer.prototype.transformPolygon = function(
    geom, parent) {
  // empty geometries are simply removed
  if (geom.isEmpty()) {
    return null;
  }
  var rawGeom = jsts.geom.util.GeometryTransformer.prototype.transformPolygon.apply(this, arguments);
  if (parent instanceof jsts.geom.MultiPolygon) {
    return rawGeom;
  }
  return this.createValidArea(rawGeom);
};

/**
 * Simplifies a LinearRing. If the simplification results
 * in a degenerate ring, remove the component.
 * @param {jsts.geom.LinearRing}
 *          geom
 * @param {jsts.geom.Geometry}
 *          parent
 * @return {jsts.geom.Geometry}
 */
jsts.simplify.DPTransformer.prototype.transformLinearRing = function(
    geom, parent) {
  var removeDegenerateRings = parent instanceof jsts.geom.Polygon;
  var simpResult = jsts.geom.util.GeometryTransformer.prototype.transformLinearRing.apply(this, arguments);
  if (removeDegenerateRings && !(simpResult instanceof jsts.geom.LinearRing)) {
    return null;
  }
  return simpResult;
};

/**
 * Simplifies a MultiPolygon, fixing it if required.
 * @param {jsts.geom.MultiPolygon}
 *          geom
 * @param {jsts.geom.Geometry}
 *          parent
 * @return {jsts.geom.Geometry}
 */
jsts.simplify.DPTransformer.prototype.transformMultiPolygon = function(
    geom, parent) {
  var rawGeom = jsts.geom.util.GeometryTransformer.prototype.transformMultiPolygon.apply(this, arguments);
  return this.createValidArea(rawGeom);
};

/**
 * Creates a valid area geometry from one that possibly has
 * bad topology (i.e. self-intersections).
 * Since buffer can handle invalid topology, but always returns
 * valid geometry, constructing a 0-width buffer "corrects" the
 * topology.
 * Note this only works for area geometries, since buffer always returns
 * areas. This also may return empty geometries, if the input
 * has no actual area.
 * @param {jsts.geom.Geometry}
 *          rawAreaGeom
 * @return {jsts.geom.Geometry}
 */
jsts.simplify.DPTransformer.prototype.createValidArea = function(
    rawAreaGeom) {
  if (this.isEnsureValidTopology) {
    return rawAreaGeom.buffer(0.0);
  }
  return rawAreaGeom;
};

redpajama_set_name: RedPajamaGithub


text:
in south Oxfordshire
Owl Barn
For reservations, bookings, rates and enquiries:
info@owlbarnrental.co.uk
Finding Owl Barn, and information about the area.
Owl Barn is situated in the beautiful countryside of South Oxfordshire in the village of Warborough.
The market town of Wallingford is close by, and there are many amenities within walking distance or a short drive. The village of Dorchester-on-Thames is about a ten minute drive away where Dorchester Abbey can be found, and there are some lovely walks along the River Thames.
We have some fantastic restaurants in Oxfordshire close by: The Home Sweet Home pub in Roke (10 min drive),Crazy Bear in Stadhampton for Thai food (10 min drive), Lord Nelson in Brightwell Baldwin (20 mins drive) and The Mole Inn in Toot Baldwin.
Also, in the surrounding villages such as Benson, Dorchester-upon-Thames and of course Wallingford, there is a large number of pubs that serve food. Well worth taking a look around!
The historic city of Oxford is only about 12 miles away where the dreamy spires of the Oxford Colleges rise into the Oxfordshire sky - some of the landmarks such as the Radcliffe Camera will recognisable to any fans of 'Inspector Morse' and of course 'Lewis'.
Visit www.visitoxfordandoxfordshire.com for more ideas on things to see and do in the area.
Other useful links and info:
www.wallingford.co.uk
www.oxfordcityguide.com
Warborough is 3.4 miles from the market town of Wallingford, which is a 10 mins drive (local train station to Wallingford is Cholsey), Oxford City centre is 11.5 miles away which is a 25 mins drive - from there, trains to London Paddington take 59mins, and it's 8 miles to Didcot Parkway (the fast train to London Paddington takes 45 mins). Local taxi services are available.
You can find Owl Barn and its surrounding villages and services on the map below:
Inside Owl Barn
Find Owl Barn
© Owl Barn Rental | 2019 | mobile: 07919304636 | site by: jswebscape.co.uk

redpajama_set_name: RedPajamaCommonCrawl


A file to close? Our shared and connected workspace welcomes you 24 hours a day.
With two iMacs and a printer at your disposal (printing subject to reasonable use), this informal area is ideal for quietly finalising a presentation or checking your emails between appointments.
Our team is also at your disposal to make your photocopies.


text:
Q: How is the matrix $A^{2}$ related to $a\times(a\times b)$? I have a matrix, $$A = \left( \begin{matrix} 0&-a_3& a_2\\ a_3&0&-a_1\\ -a_2&a_1&0\end{matrix}\right)$$
So, $$A^{2} = \left( \begin{matrix} -a_3^{2}-a_2^{2}&a_2a_1& a_3a_1\\ a_1a_2&-a_3^{2}-a_1^{2}&a_3a_2\\ a_1a_3&a_2a_3&-a_2^{2}-a_1^{2}\end{matrix}\right)$$
I know that $a=\left( \begin{matrix}3\\2\\1\end{matrix}\right)$ and $b=\left( \begin{matrix}1\\2\\3\end{matrix}\right)$
Subbing in $a_1=3$, $a_2=2$ and $a_3=1$ into $A^2$, I get
$$A^{2} = \left( \begin{matrix} -5&6&3\\ 6&-10&2\\ 3&2&-13\end{matrix}\right)$$
I've also determined that $a\times(a\times b) = \left( \begin{matrix}0\\16\\-32\end{matrix}\right)$
I'm told $a\times(a\times b)$ can be found using $A^{2}$, but I don't see the connection. What am I missing?

A: Try to verify by direct computation that given any $x \in \mathbb{R^3}$,
$$Ax=a\times x$$

redpajama_set_name: RedPajamaStackExchange


How does Ash have seven Pokemon with him?
Currently in the anime, Pokemon: Black and White, how does Ash have seven pokemon with him in his party. He has Pikachu, Oshawott, Tepig, Snivy, Tranquil, Scraggy, and Swadloon. Did I miss something or does one of them not count?
He doesn't. One of those Pokemon is with Prof. Juniper, he just switches out his Pokemon every now and then.
Plus the anime is not the same as the games in everything.
In terms of having only six Pokemon it is. Look at when he caught Sedaddle (or whatever) and also with Krabby.
Ah, I see. Well thanks for clearing that up.
Why does ash have female voice actors in English?


text:
Isaimini 2023 Movies Download isaimini Tamil Movies
isaimini 2022 Movies Download isaimini HD Movies Download isaimini 2022 Tamil Movies Download isaimini Mp4 Movies Download.
Isaimini Movies 2023: Isaimini 2023 is a public pirated site that lets people download and stream movies, web series, and programs online for free. Most people go to Isaimini web to get free copies of their #1 most recent Tamil and Hollywood movies.
You don't have to sign up to download Tamil, Malayalam, Kannada, or Bollywood movies from the Isaimini.vip site. You can watch Hit, Super Hit, and Blockbuster movies in many different languages on Isaimini.vip.
Who does not like watching movies? In their free time, everyone likes to watch movies. But if you want to see a new movie, you have to go to a movie theater or buy a CD or DVD so you can watch it on your computer or DVD player.
You spend time and money on both of these things. Because of this, most people are looking for a way to download mp4 movies 2021 easily and for free while staying at home. Now you're probably wondering if this is really possible. The simple answer to this question is yes, you can.
internet There are a lot of sites like this where you can download movies. By the way, all of the movies on these sites are stolen, so you shouldn't use them at all. But if you look at what they have to offer, you can easily download any new movies, TV shows, songs, or videos for free.
Also Check Bolly4u Movie Download Site
Isaimini.com is a very well-known site for downloading movies. It will soon have the latest Bollywood and Tamil movies available for download on its platform. Because of this, a lot of people like it. So I thought, why not tell you some important things about isaimini VIP today? This also shows that how to download movies from tamilrockers isaimini how secure is it? So, let's get started.
isamini tamilrockers website released latest movies
Isaimini Movies is an illegal site where you can download HD movies.
How can I get the Isaimini Tamil Movie?
Isaimini VIP 2023 lets you download Tamil, Telugu, and Malayalam dubbed movies online in HD.
Isaimini New Link 2023
Isaimini Malayalam Dubbed Movies has movies from what kinds of genres?
Who watches Isaimini Telugu Movies the most?
Information about Isaimini Download
What is Isaiminida Kannada 2023
Tamil Isaimini New Movies (Latest Updates)
Is Isaimini Movies legal?
Legal Tamil/Telugu Movie Download Websites:
Things about Isaimini
The newest HD movies can be downloaded from Isaimini VIP 2023.
How do I get to the Isaimini site?
Is it okay to download movies from Isaimini 2023?
What does Isaimini 2023 do for money?
How to watch movies online legally?
The Isaimini.Vip website has a huge number of Tamil movies, and you can also download Bollywood and Hollywood movies from there. Isaimini VIP Films is special because every time you go to the site, you can watch new movies that have just been added.
Isaimini Mob.Net lets its users download movies for free, including ones that are dubbed, animated, funny, or full of action. You can also find a large number of OTT shows and web series from well-known platforms like Netflix, Amazon Prime Video, Hotstar, and so on at www.Isaimini.VIP. At www.isaimini Vip.com, you can also watch movies in full 360p to HD quality.
Also Check Filmy4wap Movie Download Site
Isaimini 2023 is also one of the best sites in India for stealing movies, and it leaks movies online. This is a huge problem for movie makers because anyone can easily watch and download the movies they made from pirated websites and torrent files.
You can also easily download all hit movies from the Isaimini site, where you can get all movies in different qualities. You can download a movie here based on how much data you have and how fast your internet is (300MB, 700MB, 1GB, and 2GB).
Websites like isaimini songs let people directly download movies and also give them the option to watch movies online. On the other hand, if you want to learn more about Isaimini Movie download, how to use it to watch movies, etc., you should read this whole article.
Also Check iBOMMA Telugu Movies
Isaimini, this website for illegally downloaded movies is run by a group that stays anonymous and works in the area. The main goal of this site is to get users the most recent leaked movies as soon as possible, preferably on the day they come out in theaters.
There are more than 5,000 Indian movies on this platform right now. At the same time, you can watch Hollywood movies online or download them. When it comes to the content, you will find Hindi, Tamil, Telugu, Malayalam, and English, among other languages. You will be able to download those movies.
The Tamil movie Kolanji was recently leaked on the website Isaimini. Dhanaram Saravanan is in charge of making this movie. Samuthirakani and Sanghavi, on the other hand, have had the most important parts in this movie.
disclaimer, This content is just for your reference, and Hindime doesn't claim any ownership over it. Hindime, on the other hand, does not support piracy in any way and does not promote it either.
Also Check Movierulz
Isaimini Let's find out what new links will be made in 2023. Now, let's look at the list of these sites.
Isaimini.co isaimini.in
isaimini.net Isaimini.dub
isaimini.ent Isaimini.any
isaimini.site Isaimini.live
isaimini.online Isaimini.in
Isaimini.maza Isaimini.run
Also Visit Moviezwap For Download Movie
Isaimini. vip is a pirate site like many others. Tamil movies are also made in a remote place with an IP that is hard to find. At the same time, it shares a lot of content from TamilRockers 2023 on its website. At first, their main goal was to leak Tamil movies. Now, however, they leak all of these movies.
As their popularity with visitors grew, however, their admin thought it would be a good idea to also leak movies from other domains, such as dubbed Hollywood movies, Telugu, Bollywood, and Malayalam films. On this platform, you can also download all of these movies for free.
A report says that Isaimini.vip now has its own local server where all of its movies are kept. But no one knows where this server is located at all.
When many filmmakers complained, search engines often blocked their domains. At the same time, their admins changed their domain names in a smart way and brought the site back online. Now that it has the new extension, it has started to work well.
Also Check filmyzilla Movie Download Site
Isaimini Tamil movie download is mostly only for mobile users, if we're talking about its main audience. Even more so, this is why the mobile wap framework was used to build the whole Isaimini website. So that it works on mobile devices.
When Jio made the cost of using the internet very low, people started looking for free ways to have fun that they could do at home. Because not everyone has enough money to see a movie at the theater. But he can easily get new movies like this from the internet. From the pirate website Isaimini.
When you download Isaimini Tamil movies, you can do so in a number of different ways. Since more people use this on their phones, there are a lot of different file sizes that can be downloaded. Such sizes are suitable for mobile devices.
On the day a new movie comes out, the first cam print of that movie is leaked on this site. The official HD print of that movie was uploaded to the website later.
In this, you will be able to download 360p, 480p, 720p, HD Prints, BRRip Prints, etc.
Also Check TamilYogi Movies download Site
isaimini.com 2020 movie download A site is on the internet, just like all the other sites that let people steal things. There are many sites like isaimini movies, which mostly focus on movies in regional languages.
Isaimini's niche audience is people who like to watch leaked Tamil movies, which is how she got started. Tamilrockers, tamilgun, and tamilyogi are some of the best sites that can be used instead of Isaimini.
The domain's database is stored locally and managed from a remote location, so the site owner is completely safe. Even if he is caught there, it is easy for him to destroy all the files.
Also Check Movierulz Tamilrockers
Jin no isaimini com Tamil is not allowed in any way. Totally against the law. According to the Government of India, it is against the law to watch or download any kind of movie on a piracy website. On the other hand, you can also go to jail for this.
It is okay to go to a movie theater and watch a movie. If you pay for a video series, however, you can still watch it or download it. But since these websites upload these movies without permission, they are called "pirated." Because of this, the filmmakers have a lot of trouble. That's why it's against the law.
Hindi never encourages this kind of theft, but we want to download movies the right way so that movie makers can also make money and make better movies.
Sony Liv
Sony Crunch
Big Flix
Customers like the Isaimini 2023 Telugu site so much because the www.Isaimini vip online site's features are great. Tell us about some of the best things about it.
Local languages like Malayalam, Hindi, Tamil, Telugu, and so on can be used to watch movies.
It gives the office the ability to download recordings in different classes.
This lets you download movies in different formats, like 480p, 720p, and 1080p.
It lets you download movies and watch them when you're not online.
There is a good reason why you should have to sign up to download movies.
On the web, you can stream any video from the site.
Movies Based on the Year You can also use the search office.
Isaimini is an illegal site where you can download movies. Here, you can watch a wide range of movies. Here, you can get copies of the many different films that are out there. Pilfered Variant is a term for this kind of copied content. Here, we'll talk about how to use Isaimini to download movies.
But before that, I need to warn you that this is just information about how to download the movie from Isaimini. If you are caught downloading a movie from this site, you could go to jail for a couple of years. Since everything here is illegal, the content here is also illegal. So we should know how to use Isaimini to download movies –
Importantly, you need to go online and use Google or another web search tool to find the live connection to the Isaimini site.
When you get a live connection with Isaimini, which is a site, you should then open the site.
On the home page of Isaimini VIP, there is a search bar where you can type in the name of the movie you want to watch.
After this, the movie you looked at will be in front of you.
Here, you can download a lot of information about the movie.
You can download the movie by tapping on any link that works for you and what you know.
When you click on the "Download" button, a bunch of pop-up ads will appear, which you will need to close.
Then, your movie will start to download.
Customers like the Isaimini 2023 Telugu site so much because the features of www.Isaimini VIPonline are great. Tell us about some of the best things about it.
Not even close! It is against the law to download anything or watch it online. Because all of the content that is uploaded to it is stolen and put there without the creator's permission, which is against the law.
Isaimini 2023 makes money when people click on pop-up ads from other sites. When a user goes to the site to download a movie, they see a lot of ads that take them to other websites. When millions of people go to these sites, they make a lot of money.
In the modern world of today, there is a lot of modern technology and the internet, which makes it easy to watch any Ismaili 2020 movies.
Major websites and mobile apps like Hotstar, Amazon Prime, Netflix, YouTube, Bigflix, and so on are all legal to use and can be found on the market.
You can watch and download hundreds of movies and TV shows for a small monthly fee. You can watch them both any time and any place.
Not only that, but if you want a free platform, you can use Hotstar and Youtube, where you can watch a lot of movies online for free.
On behalf of HindiMe, we ask that you always use legal ways to watch movies and don't be afraid to do so. With this, you should be doing your duty as a real Indian citizen. And never go to websites like this that have been stolen.
UWatchFree Movies Download 2023 [Bollywood, Hollywood]
7starhd Movies Download 2023 [Hindi,Tamil,telugu,720p,1080p]


"Over 50 million consumers already have signed up for the Do-Not-Call registry after Congress made it a priority to give consumers the right not to be bothered by telemarketers. The message is clear — consumers are sick and tired of having their lives interrupted by constant telemarketing calls, and they want it to stop now. Whatever real or perceived problems this court has with the registry doesn't change this fact.


. Mp3 Songs Music Video Download, Free . 3 movie telugu movie download Pul download . Amavas telugu movie mp4 download Aatankraj dual audio in .
Scribd is the world's largest social reading and publishing site.. Find Where Free Movies Is Available To Stream Now. Yidio is the premier streaming guide for TV Shows & Movies on the web, phone, tablet or smart tv.. . Full HD 720p Dual Audio Free Download In Hindi Movie Name . Released/Country: 1 May 2014 (India) Anamika (2014) Telugu Movie . You can also download movie .


This is the very first Canadian coin with a square hole in the middle. It was inspired by the square-holed coins that came into use in China after 523 B.C. These coins were cast from bronze and the holes enabled them to be strung on a cord - 1,000 coins forming the main purchasing unit in use at the time.
The reverse shows a stylized oriental design (reminiscent of the trade dollars of Great Britain) with Chinese characters along with the Queen's portrait, in frosted cameo, and the legend ELIZABETH II D. G. REGINA ("Elizabeth II, Queen by the Grace of God"). Artist is Susanna Blunt.
The obverse features a Chinese dragon, well known as a symbol of power in Chinese folklore and art. Perhaps this is Fucanglong, the Dragon of Hidden Treasures who guards precious metals and jewels. Also featured are a bat and a deer, all executed by well-known Canadian artist Harvey Chan (HC). The unusual denomination of 8 DOLLARS (a lucky number) is also on the obverse.


text:
High Net Worth Family Tax Report, Vol. 6, No. 3
Client Alerts/Reports December 2011
Congressional Super Committee Fails to Agree on Deficit Reduction Measures
Supreme Court to Resolve Statute of Limitations for Overstatements of Tax Basis
IRS Rules That Gift to Charity of Non-voting Stock Is Not a Prohibited Split-Interest Transfer
Court of Appeals Affirms Tax Court on Fifteen-Year Amortization of Covenant Not to Compete
Family Limited Partnerships: The Litigation Continues
IRS Issues New Proposed Regulations on Bundled Trustee Fees
IRS Voluntary Worker Classification Settlement Program
Some Developments of Interest to Our New York Readers
Tax Court Disallows Special Allocation and Imposes Self-Employment Tax on Law Firm Limited Liability Partnership
California Board of Equalization Determines Source of Income from Non-qualified Stock Options
California Reminds Taxpayers That Not All Charges on Real Property Tax Bills Are Deductible
IRS Provides Filing Information for Registered Domestic Partners and Same-Sex Spouses
Two Cases Previously Reported Are Affirmed by the Ninth Circuit
Tax Court Allows Estate Tax Deduction for All Interest That Will Be Due on a Loan to Pay Estate Taxes
Daughter Allowed Deduction for Her Medical Expenses That Were Paid by Her Mother
A couple of weeks ago we reported to you about rumors then circulating that the Congressional Joint Select Committee on Deficit Reduction ("Super Committee") might recommend reducing the estate and gift tax exemption to $1,000,000 as early as November 23, 2011. That did not occur and, in fact, the mandate of the Super Committee expired on November 23 with no deficit reduction proposals being agreed upon by the Super Committee.
As of this time, the $5,000,000 lifetime exemption from estate and gift taxes will remain in effect through December 31, 2012. For 2012, the exemption has been inflation adjusted to $5,120,000. On January 1, 2013, the exemption will revert to $1,000,000 and the maximum estate and gift tax rates will increase from 35% to 55%. Similarly, the current $5,000,000 exemption from generation-skipping transfer ("GST") tax is currently scheduled to remain in effect through December 31, 2012, and revert to $1,000,000 (adjusted for inflation since 2001) on January 1, 2013, with the GST tax rate being equal to the highest estate and gift tax rate.
Over the next couple of weeks you may read of proposals being introduced in Congress to accelerate the date of those changes and make other changes to the estate, gift, and GST taxes. At this time, there is no reliable information that would justify decision-making on the basis of rumor and speculation. We will closely monitor all such proposals and alert you promptly if any appears to be gaining traction. Most experts consider that highly unlikely given how heavily divided Congress is currently.
We have previously reported on several cases where courts have addressed the amount of time the Internal Revenue Service ("IRS") has to assess a tax deficiency if the taxpayer overstates the income tax basis of an asset that he has sold. Normally, the IRS has 3 years from the date on which a tax return is filed to assess additional tax with respect to the tax year covered by the return. If the taxpayer omits an amount of gross income from his tax return, however, that is more than 25% of the amount of gross income reported on the return, the IRS has 6 years within which to assess additional tax.
A number of tax-advantaged transactions that were popular in the late 1990s and early 2000s resulted in the income tax basis of an asset being increased before the asset was sold. These transactions have led to considerable litigation over whether the overstatement of tax basis is the same thing as an understatement of gross income. Over time, a split has developed among the various circuits of the United States Court of Appeals. In our last edition, we reported on two recent cases where the Court of Appeals upheld a regulation the government issued to help its own position on this issue.
When different circuits of the Court of Appeals take different positions on the same issue, the Supreme Court often accepts one of the cases to resolve the split and that is what has happened here. On September 27, 2011, the Supreme Court agreed to hear the case Home Concrete Supply LLC v. United States, where the Court of Appeals for the Fourth Circuit held in favor of the taxpayer that an overstatement of basis was not the same thing as an understatement of gross income. The Supreme Court will answer that question and will also determine the validity of the government's self-help regulation which says that an overstatement of basis is an omission of gross income. We will report on the outcome when the Supreme Court renders its decision.
If a donor transfers an income interest in property to a charity and retains the underlying property or transfers such property and retains the income interest, the donor does not receive any income tax deduction unless the interest that goes to the charity is in the form of a qualified remainder interest in a charitable remainder trust or a qualifying income interest in a charitable lead trust.
In PLR 201129033, the donor owned both voting and non-voting shares of stock of a corporation. He wanted to give a portion of his non-voting shares to a charity and asked the IRS for a ruling that the transfer of the non-voting shares would not be considered a prohibited transfer of a partial interest in property. The IRS ruled in favor of the taxpayer, finding that the voting shares and non-voting shares constituted separate and distinct property interests, rather than being fractional parts of a single property interest. The donor did arrange for the corporation to agree to pay an annual dividend on the non-voting shares so that the charity would receive some clear economic benefit. This may have assisted the taxpayer in getting the favorable ruling.
In our August 2010 edition (Vol. 5, No. 2), we reported on the Tax Court case Recovery Group, Inc. The taxpayer had redeemed the stock of a 23% shareholder and separately paid him for a one-year covenant not to compete. The taxpayer deducted the cost of the covenant since its benefit was limited to one year. Historically, the cost of a covenant not to compete has been amortized over the term for which it is in force and the taxpayer's deduction would have been appropriate. In 1993, however, Congress enacted IRC Section 197 which provides that if intangible assets, such as a covenant not to compete, are acquired as a part of the acquisition of a trade or business, the intangible assets must be amortized over 15 years regardless of their useful life. The Tax Court held that the redemption of the shares of a corporation that is engaged in a trade or business constitutes the acquisition of a trade or business, so the 15 year rule applies.
The taxpayer appealed the Tax Court's decision to the United States Court of Appeals for the First Circuit. That court agreed with the Tax Court. Both the Tax Court and the First Circuit held that the percentage of the corporation's shares that are acquired in the transaction is not relevant. As long as the corporation is engaged in a trade or business, any covenant not to compete acquired in connection with any acquisition of its stock is subject to the 15 year amortization rule of IRC Section 197. This rule presents a potential trap for taxpayers and their advisors because the result is counter-intuitive. Of course, students of the tax law know all too well that many tax results are counter-intuitive.
The litigation over valuation discounts associated with family limited partnerships and limited liability companies shows no signs of abating. Additional cases have been decided since we last wrote to you in August. In Estate of Clyde W. Turner, Sr. (August 30, 2011), the taxpayer formed a family limited partnership funded with investment assets and cash. Stock of Regions Bank made up 60% of the total assets of the partnership. The taxpayer retained $2 million of assets outside of the partnership. Gifts of limited partnership interests were made to the taxpayer's children.
Upon Clyde's death, the IRS took the position that the partnership's assets should be included in Clyde's gross estate for estate tax purposes under IRC Section 2036(a)(1) which includes assets that the decedent had transferred during his life but with respect to which he retained an interest. The court found that the decedent retained an interest in the assets because he paid himself excessive management fees from the partnership and he had stated that the Regions Bank shares should never be sold. The court also said that the assets would be includible in his estate under Section 2036(a)(2), which includes property where the decedent retains the right to determine who shall enjoy or possess the property. The decedent was the general partner and had discretion to determine when and if distributions would be made from the partnership. The decedent also had the right to amend the partnership agreement without any vote on the part of the limited partners. Even as to matters that did require a majority vote of the limited partners, Clyde and his wife retained more than 50% of the limited partnership interests.
The second case was Estate of Paul H. Liljestrand (November 2, 2011). Again, the issue was whether assets transferred to a family limited partnership should be included in the transferor's gross estate for estate tax purposes pursuant to IRC Section 2036(a)(1). In this case, it was easy for the court to conclude that the taxpayer had retained an interest in the property that he transferred to the partnership. He retained a preferred return that was high enough to consume all of the partnership's income, he did not retain sufficient assets outside of the partnership to pay his bills, and he received non-pro rata distributions from the partnership.
In the case of Knight v. Commissioner (January 16, 2008), the Supreme Court held that investment advisory fees paid by an estate or non-grantor trust are subject to the 2% of adjusted gross income floor on miscellaneous itemized deductions imposed by IRC Section 67. In general, IRC Section 67(e) provides that the adjusted gross income of an estate or non-grantor trust is computed in the same manner as it is for an individual. Deductions for expenses that an estate or non-grantor trust incur, however, that would not be incurred by an individual, are not treated as itemized deductions. This means that these expenses are deductible in full without regard to the 2% floor. An example of a deduction incurred by a trust that would not be incurred by an individual is for the fee charged by the trustee to administer the trust. Investment advisory fees, however, are incurred both by individuals and by trusts.
The Supreme Court did say that if the trust incurs investment advisory fees that are higher than those that would be incurred by an individual, the excess portion of the fee is deductible without regard to the 2% of floor of Section 67. A trust might incur higher fees because it has an unusual investment objective or it incurs extra fees to balance the interests of the various beneficiaries of the trust. The IRS has now proposed regulations that acknowledge this aspect of the Supreme Court's opinion. The regulations also provide that where the trustee bundles its fee and the fee is not charged on an hourly basis, only the portion of the bundled fee attributable to investment advice is subject to the 2% floor. The entire balance of the fee may be deducted in full.
A constant source of friction between the IRS and taxpayers is over the classification of workers. Are the workers employees or independent contractors? If they are employees, the employer must withhold income and payroll taxes from their wages and pay the employer's share of the applicable payroll taxes. The IRS has developed a new program, the Voluntary Classification Settlement Program (the "VCSP"), that allows employers to prospectively reclassify workers as employees instead of independent contractors or other non-employees. The VCSP provides partial relief from past employment taxes by requiring eligible taxpayers to pay only 10% of the employment tax liability that would otherwise have been due on compensation paid for the most recently closed tax year as determined by reduced rates. According to the IRS, employers accepted into the program will pay an effective amount equal to just over one percent of the wages paid to the reclassified workers for the past year. If a taxpayer chooses to reclassify certain of its workers as employees, it must also reclassify all workers in the same class as employees for employment tax purposes.
A taxpayer is eligible to participate in the program if: i) the taxpayer has consistently treated the workers as non-employees; ii) has filed all required Forms 1099 for the workers for the prior three years; iii) is not currently under audit by the IRS; and iv) is not currently under audit concerning the classification of the workers by the Department of Labor or by a state government agency. A taxpayer that was previously audited by the IRS or Department of Labor concerning the classification of workers will be eligible for the VCSP if the taxpayer has complied with the results of that audit. Exempt organizations and government entities may participate in the VCSP if they satisfy the above requirements and are not undergoing a Form 990 series audit.
A taxpayer who participates in the VCSP will agree to prospectively treat the class of workers as employees and to extend the statute of limitations on employment taxes to six years for the first three years under the VCSP closing agreement. In exchange, the taxpayer will: i) pay 10% of the employment tax liability that may have been due on compensation paid to the workers for the most recent tax year as determined under reduced rates; ii) avoid liability for any interest and penalties on such amount; and iii) avoid any employment tax audit with respect to the classification of the workers for prior years.
To apply for the VCSP, the taxpayer must submit an Application for Voluntary Classification Settlement Program at least 60 days before the taxpayer wants to begin treating the workers as employees. If the IRS accepts the application, the taxpayer will enter into a closing agreement with the IRS to finalize the terms of the VCSP and will simultaneously pay any amount due under the closing agreement.
Changes to New York Offer in Compromise Program. The New York State Department of Taxation and Finance recently enacted legislation that expands the eligibility of taxpayers to participate in New York's Offer in Compromise Program and provides the Commissioner with more flexibility with respect to amounts that can be accepted in compromise of a tax liability. In addition to previously eligible taxpayers that have been discharged in a bankruptcy proceeding or are proven to be insolvent, eligible taxpayers now include individuals who can demonstrate that a full collection of any tax liability will cause the taxpayer undue economic hardship. An undue economic hardship occurs when a taxpayer is unable to pay reasonable basic living expenses. In determining whether an undue economic hardship exists, the Department of Taxation and Finance will look to the IRS's Collection Financial Standards to help determine a taxpayer's allowable basic living expenses and will consider other factors that can impact an individual's financial condition, e.g., age, employment status, illness or disability, obligations to dependents, or extraordinary circumstances.
The amount that the Commissioner previously could have accepted in compromise of a tax liability could not have been less than the amount recoverable through legal proceedings. The new law generally permits the Commissioner to accept amounts in compromise that reasonably reflect collection potential or are otherwise justified by the proof offered by the taxpayer.
The new law retains the requirement of a New York State Supreme Court justice's approval for fixed and final liabilities where the amount to be compromised is over $100,000 (excluding penalties and interest), but raises the threshold from $25,000 to $50,000 (including penalties and interest) before requiring an opinion of counsel to finalize offers for liabilities that are not fixed and final.
New York Statute of Limitations for Collection of Tax Liabilities. New York recently amended the law that imposes a 20 year statute of limitations to collect tax liabilities to clarify that such 20 year period begins from the first date the Commissioner could have filed a warrant (a legal action against a taxpayer that creates a lien against the taxpayer's real and personal property), without regard to whether the warrant is actually filed. Where there is no right to a hearing, the first date the Commissioner could have filed a warrant is the day after the last day specified for payment by the Notice and Demand and where there is a right to a hearing, such date is the day the opportunity for a hearing or review has been exhausted. In addition, the taxpayer's payment or acknowledgment of a debt in writing no longer extends the 20 year statute of limitations; however, the Commissioner and the taxpayer can agree to a longer statute of limitations. This new law applies to all tax liabilities that could have been warranted before August 17, 2011, and that can be warranted on or after such date.
Change in Filing Requirements for New York Same-Sex Couples. The Marriage Equality Act, signed into law on July 24, 2011, provides that all marriages will be treated equally under all laws of New York state, including the tax laws.
Effective for tax years ending on or after July 24, 2011, same-sex married couples (including those who were married outside of New York) must file New York personal income tax returns using a married filing status (i.e., married filing jointly or married filing separately), even though their marital status is not recognized for federal tax purposes (see article on federal law in this edition) and they may have filed as a single or head of household status on their federal returns. To compute their New York tax, such married couples must re-compute their federal income tax as if they were married for federal purposes.
In addition, the New York taxable estate of an individual in a same-sex marriage must be computed in the same manner as if the deceased individual were married for federal estate tax purposes. The estate of an individual married to a same-sex spouse must begin by computing the gross estate on a pro forma federal return as if the marriage were recognized for federal estate tax purposes, including certain deductions and valuations.
Same-sex married employees may want to file new withholding certificates with their employer informing them of their married status and provide proof of their married status to have the employer stop withholding New York tax on the value of certain benefits (e.g., health care coverage of their spouse).
Out-of-State Investment Company Limited Partner Lacked Nexus with New Jersey. The Superior Court of New Jersey held that a foreign investment corporation whose only connection with New Jersey was a 99% limited partnership interest in a limited partnership that does business in New Jersey does not give rise to sufficient nexus with New Jersey to subject the foreign limited partner to New Jersey's corporation business tax. The foreign limited partner had no place of business, property, employees, agents, or representatives in New Jersey.
New Jersey argued that the foreign limited partner had a unitary relationship with the business conducted by the limited partnership in New Jersey. The Court held that the foreign limited partner and the limited partnership did not have a unitary relationship and the partner did not have sufficient nexus with New Jersey because (1) unanimous consent of both partners was required to admit additional partners, merge or consolidate the partnership with another entity and consent to the sale or transfer of either partner's interest and the non-selling partner had the right of first refusal in a sale of a partner's interest and the general partner controlled the ongoing business activities of the limited partnership, (2) there was no indication that the foreign limited partner had a New Jersey address, (3) the sharing of some officers and office space is insufficient to show a unitary business, (4) the foreign limited partner's right to inspect books, records, reports and returns do not show that it controlled the limited partnership, and (5) the foreign limited partner was not in the same line of business as the partnership.
A recent Tax Court case, Renkemeyer, Campbell & Weaver, LLP v. Commissioner, disallowed a special allocation of a law firm limited liability partnership's net business income and held that income generated from the firm's legal practice that was allocated to the attorney partners was subject to self-employment tax.
The partnership originally consisted of three attorneys and an S corporation that was owned by an Employee Stock Ownership Plan of which the three attorneys were the beneficiaries. The partners shared profits and losses as follows: 30% each to the three attorneys and 10% to the S corporation. The law firm specially allocated 87.5% of its net business income to the S corporation. The law firm did not report any of its business revenues from its law practice on its partnership return as net earnings from self-employment.
The IRS reallocated the partner's distributive shares of the firm's net business income in accordance with the profit and loss sharing percentages. The law firm argued that the special allocation was proper because it was made pursuant to the partnership agreement; however, the firm could not produce a partnership agreement to support such an allocation. As a result, the Tax Court looked at the partners' capital contributions, interests in profits and losses, cash flow and other non-liquidating distributions, and the partners' rights to capital on liquidation to determine the partners' interests in the partnership. In making such determination, the Court found that there was no indication that the S corporation ever made any capital contributions to the partnership, the S corporation only held a 10% profit and loss interest, there was no indication that the S corporation received any distributions from the partnership and there was no indication regarding the partners' rights to distributions of capital upon liquidation of the partnership.
The IRS determined that the attorneys' shares of such income were subject to self-employment tax. The law firm argued that the partners did not have to include their distributive share of partnership income in calculating net earnings from self-employment because they were limited partners in a limited partnership and the distributive share of an item of income or loss of a limited partner (other than certain guaranteed payments) is excluded from such calculation. The exception does not define the term limited partner so the Court looked to the legislative history for guidance. The legislative history indicates that the intent of the exception was to ensure that individuals who simply invested in a partnership and were not actively participating in the partnership's business operations would not receive credits toward Social Security coverage.
The legislative history does not support a finding that Congress contemplated excluding partners who performed services for a partnership in their capacity as partners from liability for self-employment taxes. The Tax Court determined that the partners' distributive shares of the law firm's income did not arise as a return on their investment and were not earnings of an investment nature. Thus, the distributive shares of the law firm partners arising from the legal services performed in their capacity as partners in the law firm were subject to self-employment taxes.
In Appeal of Eddie C. Davis and Cynthia L. Davis, the taxpayer had received non-qualified stock options from her employer. During 2005, she exercised a number of the options and also moved from California to Texas while continuing to work for the same employer. At issue in the case was how much of the income from the options is attributable to her period of California residency. The taxpayer argued that only the period between the time the options vested and were exercised should be taken into account and the portion attributable to California should be based on the number of days she was a California resident during this period, compared to the total number of days in the period. Before the California State Board of Equalization, the Franchise Tax Board argued and the Board found that the counting of days should begin with the dates the options were granted, not the dates on which they vested. This resulted in a much larger share of the income having a California source and being taxable by California.
The California Franchise Tax Board ("FTB") has reminded taxpayers that only the portion of real property taxes that is based on the assessed value of the property may be deducted as an itemized deduction. Other charges added on to the real property tax bill may not be deducted. These include non-ad-valorem special assessments, Mello-Roos taxes, direct levies, fees and other charges. You can identify the non-deductible amounts on your real property tax bill as those charges that do not include a tax rate percentage. Beginning with the 2012 tax year, the FTB will revise Schedule CA of Form 540 to request specific information related to the itemized deduction for real property taxes.
This limitation only applies to real property taxes that are deductible as itemized deductions, such as your home or other personal use real property. If you own real property that is used in a business or held for the production of rental income, these other charges are still deductible on the schedule for business or rental income. Additional information is available on the FTB website at http://www.ftb.ca.gov/aboutFTB/newsroom/Schedule_CA_Real_Estate_Tax_Deduction.shtml.
In a series of questions and answers, the IRS has provided tax return filing information for registered domestic partners in California, Nevada and Washington and same-sex spouses in California. These are all community states.
Federal tax law respects the state law characterization of income as community property. Therefore, registered domestic partners and same-sex spouses in these states must each report one-half of all community property income on their federal income tax return. Each partner receives a credit for one-half of any tax that is withheld on wages that are treated as community property under state law. Reporting of community income in this manner is mandatory beginning with the 2010 tax year. If taxpayers wish to do so, they may amend prior years' returns to report in accordance with these new guidelines; however, amending is not mandatory. California has recognized the community property rights of registered domestic partners since 2007, so returns filed for that year or any later year could be amended if the statute of limitations has not closed.
While the IRS requires each partner to report one-half of the community income, the partners are not permitted to file either joint returns or married filing separate returns. These filing categories are determined under federal law, which pursuant to the Defense of Marriage Act ("DOMA"), currently does not recognize either registered domestic partners or same-sex marriages. DOMA, however, is under attack on constitutional grounds in several courts. In April (Vol. 6 No.1), we reported that the United States Department of Justice issued a statement in February that it would no longer defend the constitutionality of DOMA in the courts. We will keep you apprised of the status of DOMA as it affects tax planning.
The questions and answers contain information on a variety of related subjects including the availability of the dependency exemption for a partner or a child of a partner. The partners are also permitted to make different choices on itemizing deductions versus claiming the standard deduction. IRS Publication 555 also contains tax information for registered domestic partners.
Gift formula valuation clause. In December 2009 (Vol. 4. No.3), we reported on the Petter case, where the taxpayer made sales and gifts of limited liability company units to trusts for her daughters and to a charity. The terms of the transfer provided that the number of units that were to go to the daughters' trusts was the number of units whose value, as finally determined for tax purposes, was not in excess of a fixed sum that would not cause the taxpayer to become liable for gift taxes. The entire balance of the units went to the charity. Upon audit, the IRS established a higher value for the units than was used by the taxpayer. The taxpayer claimed an additional charitable contribution deduction for a larger gift to the charity and the IRS disallowed that deduction. The Tax Court held in the taxpayer's favor.
The Tax Court's decision has now been affirmed by the United States Court of Appeals for the Ninth Circuit. This is important because cases of taxpayers residing in California are appealed to the Ninth Circuit. In these cases, the IRS always argues that formula clauses violate public policy because such a clause insures that a gift tax will never be paid on this kind of transfer. Neither the Tax Court nor the Ninth Circuit agreed with the IRS on this point, although the Ninth Circuit did invite the IRS to amend its regulations if it wishes to change this result.
In August (Vol. 6 No. 2), we reported on the Hendrix case, where the Tax Court once again approved the use of a formula valuation clause. Similar to the facts of Petter, any excess value above a stated amount was to go to a charity. So far, taxpayers are prevailing where the excess valuation amount goes to a charity (McCord, Petter, Hendrix). The IRS, however, has prevailed where the excess value amount is returned to the donor (Procter, Ward).
Personal goodwill. Personal goodwill has become an important asset for tax planning purposes. In August 2010 (Vol. 5 No. 2), we reported on the case of Larry E. Howard v. United States. Dr. Howard was a dentist who practiced through a professional corporation. When he sold his practice, the corporation received $47,100 for its assets while Dr. Howard individually received $549,000 for personal goodwill and $16,000 for a covenant not to compete.
Corporations are not tax efficient in sale transactions because the buyer always wants to purchase the assets of the corporation so that it can allocate the purchase price to assets that can be depreciated or amortized for tax purposes. The sale of assets by a C corporation, however, results in both corporate level tax on the sale, as well as a second tax at the shareholder level when the corporation distributes the after-tax sales proceeds to the shareholders. It is more efficient for the shareholders simply to sell their stock and pay a single capital gain tax on the proceeds.
Tax advisors have attempted to get around this problem by claiming that the selling shareholder is possessed of "personal goodwill;" an intangible asset owned by the selling shareholder, but critical to the business of the corporation. An example might be relationships with key clients or customers that are important to the business. In Dr. Howard's case, the goodwill was his personal relationship with his patients.
The District Court held that the goodwill was an asset of the corporation which should be treated as though it sold the goodwill and then distributed the proceeds to Dr. Howard. The Ninth Circuit has now affirmed the District Court. In the view of the Ninth Circuit, Dr. Howard was tripped up by the employment agreement he had with the corporation. The agreement required Dr. Howard to render his full-time dental services to the corporation and prohibited him from competing with the corporation for three years after his employment terminated. The corporation retained full control over the acceptance of new patients and ownership of patient records. The court held that Dr. Howard had transferred the economic value of his patient relationships to the corporation.
It is interesting to think about whether Dr. Howard could have put himself in a better position. Suppose his employment had provided that he owned and retained the rights to any patient relationships he developed during the course of his employment? Since he was the only shareholder of the corporation, there was little economic risk in having such a provision in the employment agreement. While a provision of this nature may enhance the shareholder's position with respect to personal goodwill, it may also provide the IRS with a good argument that the income being received is really being earned by the shareholder and the corporation should simply be disregarded.
Estate of Vincent J. Duncan (October 31, 2011), illustrates the successful use by the taxpayer of what estate tax lawyers refer to as a Graegin loan, named after one of the first cases to approve the technique. The expenses incurred in administering the estate of a decedent may be deducted from the amount of the gross estate to determine the taxable estate upon which the estate tax is imposed. If an estate can demonstrate that it must borrow money in order to pay the estate taxes that it owes, then the full amount of the interest that will be due over the term of the loan can be deducted from the gross estate as an administration expense.
In the Duncan case, the estate demonstrated that its assets were illiquid and could not be sold to pay the estate tax due. The estate (held through a trust that was revocable up to the time of the taxpayer's death) borrowed $6,475,515 from an irrevocable trust that had been set up for the decedent by his father. Northern Trust was the trustee of both trusts and following the decedent's death his children were the beneficiaries of both trusts. Interest on the loan was accrued and compounded and all principal and interest were payable in a single installment after 15 years. The loan prohibited the prepayment of interest or principal. The interest rate was set at 6.7% per annum at a time when the applicable federal rate was 5.02% and the prime rate was 8.25%. The interest rate was recommended by Northern Trust's banking department as being a market interest rate for this type of loan in October of 2006 when the loan was made. On its estate tax return, the estate deducted $10,653,826 for the interest that would be due on the loan at the end of its 15 year term.
The IRS raised several objections to the loan including that it was not bona fide because the lender was a trust with the same trustee and beneficiaries as the borrower. The Tax Court rejected this argument because under applicable state law the trustee had a duty to administer each trust individually and without regard for the fact that the two trusts were essentially related. This meant that both the lending and borrowing trusts would be obligated under the law to recognize and enforce the terms of the loan.
The IRS next argued that the term was longer than needed because the borrower generated enough income in 3 years to pay off the loan. The court declined to second guess the judgment of the borrower's advisors who recommended the 15 year term because the trust's revenue stream was tied to oil and gas prices, which were unpredictable. The court also found that the loan was necessary because without the loan the trust would have to sell illiquid assets at depressed prices in order to pay the estate taxes. The cost incurred to protect against a forced sale is a reasonable expense of estate administration.
The IRS also challenged the interest rate. It argued that because the trust that was the lender and the trust that was the borrower had the same beneficiaries, the interest rate should not be higher than the applicable federal rate. The court rejected this argument as well, finding that the trust's cost of borrowing should objectively be higher than the applicable federal rate, which reflects the government's cost of borrowing.
The IRS then argued that the total amount of interest that would be paid over 15 years was uncertain because the loan could be prepaid. The IRS acknowledged that the note prohibited prepayment, but argued the restriction had no significance because the trustee and beneficiaries of both trusts were the same. The court rejected this argument as well, again noting the trustee was required to administer the trusts separately and in each case in the best interests of the beneficiaries of that particular trust. The court found that the two trusts had opposing interests regarding prepayment. If interest rates increased, it would not be in the best interest of the borrowing trust to prepay the loan. If interest rates decreased, it would not be in the best interest of the lending trust to accept prepayment.
The key to successfully deducting all of the interest that will accrue on a loan obtained to pay estate taxes is being able to show that without such a loan, assets would need to be sold at artificially depressed prices in order to raise funds to pay the tax.
We thank one of our clients for bringing this case to our attention. In Judith Lang v. Commissioner (December 10, 2010), a mother paid medical expenses that had been incurred by her adult daughter. She made direct payment to the providers of the medical services, for which she had no legal obligation. The daughter deducted the medical expenses on her own federal income tax return and, upon audit, the IRS disallowed the deduction on the basis that the daughter had not paid the expenses for which she was claiming a tax deduction. The Tax Court held in favor of the daughter. The court construed the transaction as though the mother had made a gift to her daughter and the daughter then used the proceeds of the gift to pay her medical expenses.
A second benefit that the parties enjoyed here was that the mother did not incur any gift tax liability as a result of paying her daughter's medical expenses, even though the court characterized the payment as a gift from the mother to her daughter. IRC Section 2503(e)(2)(B) provides a gift tax exemption for the direct payment of medical expenses on behalf of another individual.
This report is a publication of Loeb & Loeb LLP and is intended to provide information on recent legal developments. This report does not create or continue an attorney client relationship nor should it be construed as legal advice or an opinion on specific situations. For further information, feel free to contact us or other members of the firm. We welcome your comments and suggestions regarding this publication.
Circular 230 Disclosure: To assure compliance with Treasury Department rules governing tax practice, we inform you that any advice (including in any attachment) (1) was not written and is not intended to be used, and cannot be used, for the purpose of avoiding any federal tax penalty that may be imposed on the taxpayer, and (2) may not be used in connection with promoting, marketing or recommending to another person any transaction or matter addressed herein.
Click here to download a PDF of the report.
Announcements/Press Releases Loeb Advises TransUnion in Definitive Agreement to Sell Three Companies to Stellex Capital Management
Experience Represented the Buffalo Bills in a Monumental Stadium Agreement
Announcements/Press Releases Loeb Represents the Buffalo Bills in a Monumental Stadium Agreement
Speaking Engagements University of Texas Law's 40th Annual Nonprofit Organizations Institute


After considerable fan push-back (and the wake of the big Battlefront II controversy), Bungie admits they messed up by using the Curse of Osiris expansion to lock gamers out of Destiny 2 content they previously had access to. Some things are getting "fixed," but mostly Bungie is reverting to the old original Destiny 1 temporary lock-out model.
I still remember when Bungie did this in the original Destiny: when the first expansion hit, daily and weekly activities were often locked behind expansion-only maps or areas. So if you didn't buy the latest expansion there would always be a chance that key activities were simply not available to you. As I predicted, Bungie did the same thing with Destiny 2. But now they're doing something different: fixing some of the issues while doing more of the same.
Over the past few months Destiny 2 players have felt quite jaded. The game's progression system isn't so rewarding, and the Eververse is frustrating people. Many are questioning why they still play. The game's latest Curse of Osiris expansion, which Activision affirms will be the first of many content/expansion updates, was a big deal to many and seen as a way to add more value to the game. But alas Bungie actually ended up taking away from non-expansion owners (again), this time the Prestige-level Raids and Nightfalls, as well as the Trials of the Nine game mode.
Both of these will return soon, says Bungie, but there's a catch: since normal Nightfall activities and Trials of the Nine rotate in and out of certain maps and areas, they can still be unavailable to non-expansion owners for a week at a time, just like in the original Destiny (Bungie and Activision really want you to buy the expansion if you hadn't noticed).
Trials of The Nine will only require Curse of Osiris when it features a Curse of Osiris map. For all other weeks, it will be available to all players.
The Prestige Leviathan Raid will be brought back down to Power 300, and its rewards will drop down to match the new Power Level. All players will regain access to the Prestige Raid.
The Prestige Nightfall will remain a pinnacle activity, at the new 330 Power cap; This means Prestige Nightfall will require ownership of Curse of Osiris.
Normal Nightfall will only require Curse of Osiris when it features a Curse of Osiris map. For all other weeks it will be available to all players.
Time limited events - Iron Banner, Faction Rally, and The Dawning, will be made available to all players.
With Curse of Osiris now live, it's clear that we've made some mistakes with how we have handled content access. We would like to talk through the reasoning behind our decisions so far and what we are committed to changing moving forward.
The Destiny endgame features a variety of activities and playlists that we want to remain relevant to players as they grow more powerful. In Destiny 1, as your character grew more powerful throughout each expansion, some of our best content, like Vault of Glass, was left behind and lost its relevance for players. We wanted a better solution for Destiny 2, where all of our Endgame activities could stay relevant as each Expansion causes your Guardian to grow more and more powerful.
The Normal Leviathan Raid and Normal Nightfall would always stay at a Power level that was accessible to all players.
Prestige difficulty would always rise to the new Power cap. It could be the pinnacle of challenge, with the most prestigious rewards, but it therefore would require you to own the latest Expansion and be at the new Power cap.
Additionally, the game provides Seasonal, time-limited PvP playlists - Trials of The Nine and Iron Banner. These activities and their rewards are meant to evolve each Season, and they utilize new maps, so they would require you to own the latest content. To play the latest season of Iron Banner or Trials, and earn the new rewards, players would need to own Curse of Osiris.
We've heard from the community that both of these plans aren't working. The Prestige Raid was a novel experience that players value, even if they don't own Curse of Osiris, and it was a mistake to move that experience out of reach. Throughout the lifetime of the Destiny Franchise, Trials has always required that players owned the latest Expansion. However, for Destiny 2, Trials of The Nine launched as part of the main game, so it's not right for us to remove access to it.
To make matters worse, our team overlooked the fact that both of these mistakes disabled Trophies and Achievements for Destiny 2. This was an unacceptable lapse on our part, and we can understand the frustration it has created.
This will allow access to "The Prestige" Achievement/Trophy for all players.
This will also allow all players ability to complete the final step for the Legend of Acrius Exotic Shotgun.
This will allow access to "Lest Ye Be Judged" Achievement/Trophy for all players.
Trials of The Nine rewards that launched with Destiny 2 will still be accessible to all players.
New Seasonal Rewards that launched with Curse of Osiris, such as the new Seasonal Armor Ornaments, will require ownership of Curse of Osiris to acquire.
The Prestige Nightfall will remain a pinnacle activity, at the new 330 Power cap.
This means Prestige Nightfall will require ownership of Curse of Osiris.
Because of this, we will update "The Prestige" Achievement/Trophy to only reference The Prestige Raid.
Moving forward, we are investigating adding a 3rd difficulty to all Prestige activities, so that we can provide both a challenge that stays relevant with each new Expansion, and a Prestige version that is available to all players.
We will be postponing tomorrow's Faction Rally, to ensure all of our players can access the activity and the appropriate rewards.
Iron Banner and Faction Rally rewards that launched with Destiny 2 will still be accessible to all players.
New Seasonal Rewards that launch with Curse of Osiris, such as the new Seasonal Armor Ornaments, will require ownership of Curse of Osiris to acquire.
We expect these changes to go live tomorrow at the end of scheduled maintenance to deploy Update 1.1.1.1. Moving forward, we are also looking to improve on Heroic Strikes, with new challenges, new Modifiers, and free access for all players.


text:
Jim Rookes
Dr Jim Rookes
Senior Lecturer In Biological Sciences
Faculty of Sci Eng & Built Env
School of Life & Env. Sciences
Doctor of Philosophy, Deakin University, 2004
Bachelor of Science (Biological Science), Deakin University, 1999
james.rookes@deakin.edu.au
From an initial interest in Cell Biology and Plant Pathology, my research has expanded in recent years to encompass studies in the areas of Agricultural Biotechnology, Nanotechnology, Materials Science and Biomedicine.
During my PhD studies at Deakin University I investigated signal transduction pathways and defence responses triggered in plants when challenged by pathogens. To facilitate this, I constructed genetically modified plants to enable real time tracking of plant defence induction through the development of a green fluorescent protein-reporter system. Following this, I spent the next three years of my career at the University of Queensland studying the role Heterotrimeric G proteins in plants. Interestingly, amongst other findings, we discovered that G protein-coupled signalling is in fact very important for the mounting of plant defence responses.
In 2006 I returned to Deakin University to take up a Research Fellow position investigating plant interactions with the pathogen Phytophthora cinnamomi. This pathogen poses a major threat to the biodiversity of natural ecosystems across Australia and is listed by the Australian Government (Department of Environment) as a 'key threatening process'. This project investigated how plants defend themselves against this pathogen, using model plant species such as Arabidopsis thaliana and also Australian native plants.
In 2009 I became a lecturer within the School of Life & Enviro Sci. Since then my role his had a strong focus on teaching and I have taught across a range of disciplines including Biotechnology, Cell biology, Biomedicine, Molecular Biology and of course, Plant Biology. I have also been involved in the coordination of the Master of Biotechnology Postgraduate Course since 2009.
Read more on Jim's profile
Cell Biology, Biotechnology, Nanotechnology and Plant Science
Biotechnology, Biomedical and Plant Sciences
Units taught
SLE141, SLE346, SLE704, SLE712 & SLE713
School of Life & Enviro Sci - Award for Teaching Excellence; 2010, 2011, 2012 & 2013.
Deakin University - Commendation for Excellence in Teaching; 2010.
Publications year
Publications type
Vanillin mediated green synthesis and application of gold nanoparticles for reversal of antimicrobial resistance in Pseudomonas aeruginosa clinical isolates
S Arya, M Sharma, R Das, J Rookes, D Cahill, S Lenka
(2019), Vol. 5, pp. 1-11, Heliyon, Amsterdam, The Netherlands, C1
Nanoapplication of a resistance inducer to reduce phytophthora disease in pineapple (Ananas comosus l.)
X Lu, D Sun, J Rookes, L Kong, X Zhang, D Cahill
(2019), Vol. 10, pp. 1-14, Frontiers in Plant Science, Lausanne, Switzerland, C1
Transcriptome analysis, using RNA-seq, of Lomandra longifolia roots infected with Phytophthora cinnamomi reveals the complexity of the resistance response
M Islam, H Hussain, J Rookes, D Cahill
(2018), Vol. 20, pp. 130-142, Plant biology, Chichester, Eng., C1
Delivery of abscisic acid to plants using glutathione responsive mesoporous silica nanoparticles
D Sun, H Hussain, Z Yi, J Rookes, L Kong, D Cahill
(2018), Vol. 18, pp. 1615-1625, Journal of nanoscience and nanotechnology, Valencia, Calif., C1
The influence of ascorbic acid on root growth and the root apical meristem in Arabidopsis thaliana
Noura Kka, James Rookes, David Cahill
(2018), Vol. 129, pp. 323-330, Plant physiology and biochemistry, Amsterdam, The Netherlands, C1
Enhanced polycyclic aromatic hydrocarbons degradation in rhizosphere soil planted with tall fescue: bacterial community and functional gene expression mechanisms
Meixia Guo, Zongqiang Gong, Renhui Miao, Chunyun Jia, James Rookes, David Cahill, Jie Zhuang
(2018), Vol. 212, pp. 15-23, Chemosphere, Amsterdam, The Netherlands, C1
Plant-pathogen interactions: toward development of next-generation disease-resistant plants
N Nejat, J Rookes, N Mantri, D Cahill
(2017), Vol. 37, pp. 229-237, Critical reviews in biotechnology, Abingdon, Eng., C1
Quantitation of ascorbic acid in Arabidopsis thaliana reveals distinct differences between organs and growth phases
N Kka, J Rookes, D Cahill
(2017), Vol. 81, pp. 283-292, Plant growth regulation, Dordrecht, The Netherlands, C1
Polycyclic aromatic hydrocarbons bioavailability in industrial and agricultural soils: linking SPME and Tenax extraction with bioassays
M Guo, Z Gong, X Li, G Allinson, J Rookes, D Cahill
(2017), Vol. 140, pp. 191-197, Ecotoxicology and environmental safety, Amsterdam, The Netherlands, C1
Active defence by an Australian native host, lomandra longifolia, provides resistance against phytophthora cinnamomi
M Islam, J Rookes, D Cahill
(2017), Vol. 44, pp. 386-399, Functional plant biology, Clayton, Australia, C1
Microbial mechanisms controlling the rhizosphere effect of ryegrass on degradation of polycyclic aromatic hydrocarbons in an aged-contaminated agricultural soil
M Guo, Z Gong, R Miao, J Rookes, D Cahill, J Zhuang
(2017), Vol. 113, pp. 130-142, Soil biology and biochemistry, Amsterdam, The Netherlands, C1
Nanostructured liquid crystalline particle assisted delivery of 2,4-dichlorophenoxyacetic acid to weeds, crops and model plants
P Nadiminti, J Rookes, Y Dong, C Sayer, B Boyd, D Cahill
(2016), Vol. 82, pp. 17-29, Crop protection, Amsterdam, The Nethelands, C1
Mesoporous silica nanoparticles enhance seedling growth and photosynthesis in wheat and lupin.
(2016), Vol. 152, pp. 81-91, Chemosphere, Amsterdam , The Netherlands, C1
Ethephon increases rubber tree latex yield by regulating aquaporins and alleviating the tapping-induced local increase in latex total solid content
A Feng, J Rookes, G Xie, D Cahill, X Cai, Z Zou, L Kong
(2016), Vol. 35, pp. 701-709, Journal of plant growth regulation, New York, N.Y., C1
Sub-lethal UV-C radiation induces callose, hydrogen peroxide and defence-related gene expression in Arabidopsis thaliana
S Mintoff, J Rookes, D Cahill
(2015), Vol. 17, pp. 703-711, Plant biology, London, Eng., C1
Confocal laser scanning microscopy elucidation of the micromorphology of the leaf cuticle and analysis of its chemical composition
P Nadiminti, J Rookes, B Boyd, D Cahill
(2015), Vol. 252, pp. 1475-1486, Protoplasma, Berlin, Germany, C1
Latex dilution reaction during the tapping flow course of Hevea brasiliensis and the effect of Ethrel stimulation
F An, X Cai, J Rookes, G Xie, Z Zou, D Cahill, L Kong
(2015), Vol. 38, pp. 211-221, Brazilian journal of botany, New York, N. Y., C1
Transcriptomics-based analysis using RNA-Seq of the coconut (Cocos nucifera) leaf in response to yellow decline phytoplasma infection
N Nejat, D Cahill, G Vadamalai, M Ziemann, J Rookes, N Naderali
(2015), Vol. 290, pp. 1899-1910, Molecular genetics and genomics, New York , N. Y., C1
Regulation of HbPIP2;3, a latex-abundant water transporter, is associated with latex dilution and yield in the rubber tree (Hevea brasiliensis Muell. Arg.)
F An, Z Zou, X Cai, J Wang, J Rookes, W Lin, D Cahill, L Kong
(2015), Vol. 10, pp. 1-21, PLoS one, San Francisco, Calif., C1
Functionalized mesoporous silica nanoparticles with redox-responsive short-chain gatekeepers for agrochemical delivery.
Z Yi, H Hussain, C Feng, D Sun, F She, J Rookes, D Cahill, L Kong
(2015), Vol. 7, pp. 9937-9946, ACS Applied Materials & Interfaces, United States, C1
A new insight into growth mechanism and kinetics of mesoporous silica nanoparticles by in situ small angle x-ray scattering
Z Yi, L Dum�e, C Garvey, C Feng, F She, J Rookes, S Mudie, D Cahill, L Kong
(2015), Vol. 31, pp. 8478-8487, Langmuir, Washington, DC, C1
Variation of phloem turgor pressure in Hevea brasiliensis: an implication for latex yield and tapping system optimization
F An, W Lin, D Cahill, J Rookes, L Kong
(2014), Vol. 58, pp. 182-187, Industrial crops and products, Amsterdam, Netherlands, C1
Real-time measurement of phloem turgor pressure in Hevea brasiliensis with a modified cell pressure probe
F An, D Cahill, J Rookes, W Lin, L Kong
(2014), Vol. 55, pp. 1-11, Botanical Studies, London, Eng., C1
Nanostructured liquid crystalline particles as an alternative delivery vehicle for plant agrochemicals
P Nadiminti, Y Dong, C Sayer, P Hay, J Rookes, B Boyd, D Cahill
(2013), Vol. 5, pp. 1818-1826, ACS Applied Materials and Interfaces, C1
Transcriptional profiling of Zea mays roots reveals roles for jasmonic acid and terpenoids in resistance against Phytophthora cinnamomi
J Allardyce, J Rookes, H Hussain, D Cahill
(2013), Vol. 13, pp. 217-228, Functional and Integrative Genomics, C1
Mesoporous silica nanoparticles as a biomolecule delivery vehicle in plants
H Hussain, Z Yi, J Rookes, L Kong, D Cahill
(2013), Vol. 15, Journal of Nanoparticle Research, C1
Defining Plant Resistance to Phytophthora cinnamomi: A Standardized Approach to Assessment
J Allardyce, J Rookes, D Cahill
(2012), Vol. 160, pp. 269-276, Journal of Phytopathology, C1
Analysis of global host gene expression during the primary phase of the Arabidopsis thalianaPlasmodiophora brassicae interaction
A Agarwal, V Kaul, R Faggian, J Rookes, J Ludwig-M�ller, D Cahill
(2011), Vol. 38, pp. 462-478, Functional Plant Biology, C1
Use of high resolution digital multi-spectral imagery to assess the distribution of disease caused by Phytophthora cinnamomi on heathland at Anglesea, Victoria
R Hill, B Wilson, J Rookes, D Cahill
(2009), Vol. 38, pp. 110-119, Australasian Plant Pathology, C1
Heterotrimeric G proteins-mediated resistance to necrotrophic pathogens includes mechanisms independent of salicylic acid-, jasmonic acid/ethylene- and abscisic acid-mediated defense signaling
Y Trusov, N Sewelam, J Rookes, M Kunkel, E Nowak, P Schenk, J Botella
(2009), Vol. 58, pp. 69-81, Plant Journal, C1-1
Elucidation of defence responses and signalling pathways induced in Arabidopsis thaliana following challenge with Phytophthora cinnamomi
J Rookes, M Wright, D Cahill
(2008), Vol. 72, pp. 151-161, Physiological and Molecular Plant Pathology, C1
Turner review no. 17. Phytophthora cinnamomi and Australia's biodiversity: Impacts, predictions and progress towards control
D Cahill, J Rookes, B Wilson, L Gibson, K McDougall
(2008), Vol. 56, pp. 279-310, Australian Journal of Botany, C1
Heterotrimeric G protein ? subunits provide functional selectivity in G?? dimer signaling in Arabidopsis
Y Trusov, J Rookes, K Tilbrook, D Chakravorty, M Mason, D Anderson, J Chen, A Jones, J Botella
(2007), Vol. 19, pp. 1235-1250, Plant Cell, C1-1
Heterotrimeric G proteins facilitate arabidopsis resistance to necrotrophic pathogens and are involved in jasmonate signaling
Y Trusov, J Rookes, D Chakravorty, D Armour, P Schenk, J Botella
(2006), Vol. 140, pp. 210-220, Plant Physiology, C1-1
A PAL1 gene promoter-green fluorescent protein reporter system to analyse defence responses in live cells of Arabidopsis thaliana
J Rookes, D Cahill
(2003), Vol. 109, pp. 83-94, European Journal of Plant Pathology, C1
Microtubule dynamics in compatible and incompatible interactions of soybean hypocotyl cells with Phytophthora sojae
D Cahill, J Rookes, A Michalczyk, K McDonald, A Drake
(2002), Vol. 51, pp. 629-640, Plant Pathology, C1
Funded Projects at Deakin
Other Public Sector Funding
Monitoring the control and spread of Phytophthora cinnamomi in the fire affected areas of Brisbane Ranges National Park
Prof David Cahill, Dr Jim Rookes
2008: $4,000
Analysis of Phytophthora cinnamoni decontamination procedures in the Brisbane Ranges National Park
Dr Jim Rookes, Prof David Cahill
2012: $10,000
Evaluation of Phytophthora cinnamomi at the Eumeralla Mountain Bike Park, Anglesea, Victoria
Industry and Other Funding
Nufarm Contract Testing Agreements
Deakin-Phenoxy NG Screen 2
Deakin-Star - 2,4-D and Deakin Star - MCPA Screen 2011
Deakin - Flurox NG Prescreen 2011
Deakin Tebcaps & Bromngxscreen 2011 and Flurox NG Screen 2012
NUF-TEBCAPS-NOV2012
Project Star Leaf Screen 2012
Phytophthora soil testing for the Warby Ovens National Park
Piclorum Range Finding Experiment
Sampling and analysis of the presence of Phytophthora cinnamomi at Cape Sir William Grant Wind Farm
Warby-Ovens National Park vegetation and Phytophthora cinnamomi monitoring.
Co-supervisor
Dequan Sun
Thesis entitled: Mesoporous Silica Nanoparticles as a Biomolecule Delivery System in Plants
Doctor of Philosophy (Biol & Chem), School of Life and Environmental Sciences
Noura Masseh Ellya Kka
Thesis entitled: Plant Ascorbate Influence on Cell Division, Growth and Seed Production of Arabidopsis thaliana
Arjun Challagulla
Thesis entitled: Precision Engineering of the Chicken Genome for Disease Control
Pavani Nadiminti
Thesis entitled: Nanostructured liquid crystalline particles as next generation agrochemical delivery vehicles
Sharl Mintoff
Thesis entitled: RESPONSES OF ARABIDOPSIS THALIANA TO UV-C RADIATION AND HYALOPERONOSPORA ARABIDOPSIDIS
Associate Supervisor
Xinhua Lu
Thesis entitled: Mesoporous Silica Nanoparticle Delivery of Biomolecules into Plants
Doctor of Philosophy (Life & Env), School of Life and Environmental Sciences
Md Tohidul Islam
Thesis entitled: Interactions of Phytophthora cinnamomi with Model and Native Plant Species
Yuanyuan Guo
Thesis entitled: Development of Novel High Performance Protein Materials as Bioadhesives
Doctor of Philosophy (Engineering), Institute for Frontier Materials
Zhifeng Yi
Thesis entitled: Functionalised Mesoporous Silica Nanoparticles for Smart Agrochemical Delivery System
Feng An
Thesis entitled: Role of aquaporins and phloem-turgor-pressure in Hevea yield: mechanism of Ethrel stimulation
Doctor of Philosophy (Biol & Chem), Institute for Frontier Materials
Jane Alisa Allardyce
Thesis entitled: Defence Mechanisms of a Resistant Monocot Model to Phytophthora Cinnamomi


text:
var express = require('express'),
    app = express();

app.use('/', express.static(__dirname + '/'));
app.use('/scratch', express.static(__dirname + '/scratch'));

app.get('*', function (req, res) {
    res.sendfile('index.html');
});

app.listen(3333);
console.log('\n----------------------------------------\n' +
            ' Magic happns on http://localhost:3333/' +
            '\n----------------------------------------\n\n');


Mondo is dropping four new Teenage Mutant Ninja Turtle prints today, each focusing on a different TMNT universe.
1XRUN will be dropping some new work from artist Shark Toof today including prints and original artwork.
Guzu Gallery has a new show up right now thru August 30, 2014 featuring a ton of great art from the decadent 80's!
The Turtle's documentary for any fan highlighting the history of the Teenage Mutant Ninja Turtle franchise from comics to film!
There has been a ton of new work coming out for the Teenage Mutant Ninja Turtles with their 30th anniversary and the movie release only weeks away. There is some cool art available now!


I don't believe that STK Orlando offers lunch anymore and seeing a mostly empty restaurant at noon on a Monday (I believe there was only one or two other tables of guests plus a few people seated at the bar) I can understand why. As of April 2017 they do offer brunch (with many of the same items on the menu) on the weekends though.
Seeing that these were $15.00 I refrained from ordering a cocktail. However, since it was the last sit-down meal of our trip, I allowed the kids to each get one.
Both of these cocktails were good but probably not worth $15.00.
As you can see from the photo, this was "soupy" and more like a corn chowder. Also it was super sweet…too sweet for me.
This came with one sauce, but since we couldn't agree on one, I requested a second (blue butter, which was very good) and paid $2.00 for it. While this steak was good, I thought it was a bit overpriced. For $36.00 we got a small piece of meat, one sauce, and no sides. This same situation holds true at another high-end steakhouse in the Disney World area, Shula's at the Dolphin Resort. Like STK, Shula's steaks are served a la carte, with (shareable) sides costing $10 each, but at Shula's you can get (and share) the Steak Marianne for $48. This includes two 5 oz. filets, so you are paying $4.80 per ounce of beef rather than $6.00 per ounce at STK. However, if you are not interested in sharing and want a 10 oz. of filet all to yourself, then STK is actually a little better deal…$46.00 compared to $53.00 at Shula's. To me the quality of the beef seems equal at the two restaurants. I would though say that the sides that I've tried at Shula's were better, as was the service there. Not that the service at STK was not good, but during my two visits to Shula's I've experienced top-notch service.
She said this was very good. She really liked the combination of the grilled chicken, bacon, avocado and egg. Sadly though this sandwich is not on their brunch menu and on their current dinner menu it is just listed as a grilled chicken sandwich on a pretzel bun…no bacon, egg, or avocado (all the things she really liked about this sandwich).
On a positive note, STK Orlando did accept my Tables of Wonderland card for a 20% discount on our total bill.
And that just leaves the ratings. Yelp reviewers have rated STK Orlando 3 1/2 stars and we would probably agree with them. The mac & cheese and the chicken club sandwich (which they no longer serve) were very good but the rest of our food ranged from disappointing to good, but nothing special. Trip Advisor reviewers though rated STK a bit higher, giving it 4 stars and ranking it #224 of the nearly 3,000 Orlando area restaurants reviewed there.


text:
CordovaCann completes acquisition of cannabis retail assets
Oliver Gray Markets Reporter [email protected] 09 April 2020 11:04 (EST)
CEO, Taz Turner
Source: CannabisFn
CordovaCann (CSE:CDVA) has, through its subsidiary Cordova Investments Canada, completed the acquisition of several cannabis retail assets
The assets, including intellectual property, were purchased from Starbuds International
The acquisition will allow CordovaCann to establish a cannabis retail platform and open a range of dispensaries in Western Canada
As consideration, the company has issued an initial 12,500,000 common shares for the acquisition
CordovaCann (CDVA) is currently steady at C$0.19 per share
CordovaCann (CSE:CDVA) has, through its subsidiary Cordova Investments Canada, completed the acquisition of several cannabis retail assets.
Pursuant to a letter of intent dated March 25 this year, the acquisition will allow the company to establish a cannabis retail platform under which it will open up to five recreational and four medical dispensaries in Western Canada.
The assets were purchased from British Columbia-based Starbuds International, and will continue to operate under the Starbuds brands for the time being.
The outlets will open over the next few months and will leverage Starbuds existing brand recognition and business model, which has seen considerable success in its US operations.
Starbuds USA currently operates 20 retail stores in three states, generating more than C$83.7 million in annual revenue.
As consideration for the acquisition, CordovaCann has issues an initial 12,500,000 common shares to Starbuds International.
A further 3,000,000 common shares will be issued for each additional Alberta-based lease assignment, up to a maximum of 6,000,000 shares.
The vendors will also receive 3,000,000 shares for the opening of each retail store, up to a maximum of 15,000,000 shares. However, the openings must be completed by April 8, 2021, in order to be eligible.
Taz Turner, CEO of CordovaCann, said that the acquisition is a significant milestone.
"The purchase of these assets is an exciting development in Cordova's growth strategy, as it gives the company exclusive rights to leverage Starbuds' exceptional brand name and operational expertise, developed in the US, into certain Canadian markets.
"Starbuds is a very successful cannabis retail operator in the US, and our plan for opening Starbuds stores in Canada is very attractive given the expected revenue and cash flow generation per store," he added.
Separately, CordovaCann announced the appointment of seasoned cannabis industry veterans, Jakob Ripshtein and Ben Higham, to the company's Board of Directors.
CordovaCann (CDVA) is currently steady at $0.19 per share at 10:44am EST.
" HEXO (TSX:HEXO) delineates its path forward
HEXO (HEXO) has announced cost-saving initiatives to carry the company into the future.
" Tinley's (CSE:TNY) makes production announcement, closes first tranche of private placement
The Tinley Beverage Company (TNY) will begin making Green Monké products at its Long Beach facility.
" Tinley (CSE:TNY) announces first product clearance under California distribution license
The Tinley Beverage Company (TNY) has released an update regarding products manufactured at its Long Beach facility.
" CENTR Brands (CSE:CNTR) grows retail distribution
CENTR's (CNTR) retail distribution has increased to 2,100 U.S. locations as of December 2021.