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Current Case Developments
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Join Fleeson
Recent Cases and Rulings Affecting Estate and Business Succession Planning
Thursday, April 28 2016 6:56 PM
The following article originally appeared in newsletter of the Kansas Bar Association Real Estate, Probate and Trust Law Section. It is reprinted here by permission.
By Mike Cannady
Steinberg v. Commissioner, 145 T.C. No. 7 (Tax Ct. Sept. 16, 2015) — Assumption of Liability Reduces Value of Gift to Donees
In Steinberg, the taxpayer entered into a binding net gift agreement with her daughters under which she agreed to make gifts to her daughters, and they agreed to assume and pay any Section 2035(b) estate tax liability resulting from the gift, if she passed away within three years. The agreement was the result of several months of negotiations between the taxpayer and her daughters, during which they were each represented by separate counsel.
On the taxpayer's gift tax return, the value of the property transferred to her daughters was reduced by the fair market value of an appraiser's valuation of the daughters' assumption of the Section 2035(b) liability. The IRS issued a notice of deficiency that disallowed the discount.
Under Section 2035(b), a decedent's gross estate is increased by the amount of any gift tax paid by the decedent or the decedent's estate on any gift made by the decedent during the three‑year period preceding the decedent's death. Gift tax paid by the decedent or the decedents estate during that three‑year period includes gift tax attributable to a net gift the decedent made during that period, even though the donee is responsible for paying the gift tax in that situation.
A transfer for less than an adequate and full consideration in money or money's worth is treated as a gift to the extent of the amount by which the value of the property transferred exceeds the value of the consideration pursuant to Section 2512(b). Thus, if a donor makes a gift subject to the condition that the donee pay the resulting gift tax, the gift amount is reduced by the gift tax amount (net gift).
The court said that the fundamental issue was the fair market value of the property rights transferred under the net gift agreement. The court determined that the daughters' assumption of the Section 2035(b) liability was a detriment to them because it might result in reductions in the values of the gifts they received if the taxpayer died within three years of the gifts. A hypothetical willing buyer of the properties would recognize that to obtain the properties transferred, he or she would need to assume both the gift tax and Section 2035(b) liability, and would demand that the price be reduced to account for both of the liabilities.
The IRS argued that the daughters' assumption of the Section 2035(b) liability did not create any new burden on the daughters or benefit for the taxpayer because the daughters would have had to bear the burden of the Section 2035(b) liability either under New York law or as beneficiaries of the taxpayer's residuary estate. The court disagreed, saying that when the gifts were made the taxpayer was alive and capable of changing her domicile. Thus, there was the possibility that another state's law would apply to her estate. Also, the taxpayer was entitled to change her will before her death, so it was not possible to determine that all four of her daughters would be beneficiaries in her will when she died.
Because the court found that the daughter'= assumption of liability should be considered in determining the gift's fair market value, it needed to decide what effect the promise had on the gift's fair market value. The taxpayer submitted an expert report that said the value of the daughters' assumption of the Section 2035(b) liability was approximately $5.8 million, while the IRS did not submit an expert report. The court rejected the arguments the IRS made in relation to the taxpayer's expert report, and said that its use of the mortality tables and the Section 7520 rates did not produce an unreasonable result.
Davis v. Commissioner, T.C. Memo 2015‑88 (Tax Ct. May 6, 2015) — Charitable Intent and a Bargain Sale to Charity
In Davis, the taxpayer engaged in a bargain sale of real estate to a Section 501(c)(3) charitable organization that builds, develops, and operates senior living centers. The purchase price by the charity for the real estate was $2.0 million, while the appraised value was $4.1 million. Because of the $2.1 million bargain‑sale element, the taxpayer claimed a charitable income tax deduction of $566,900 on his 2005 income tax return and carried over the remaining amounts to subsequent years.
The IRS issued a notice of deficiency, and advanced two arguments for disallowance of the entire charitable deduction. First, it asserted that the taxpayer lacked sufficient charitable intent when he sold the real estate to the charitable organization because he sought the tax benefits flowing from the bargain sale. The court rejected this argument and found instead that as of the time of the sale, the taxpayer believed that he was selling the real estate for less than its fair market value, and that he intended to transfer the excess value to the charitable organization as a charitable contribution. The court also rejected the argument of the IRS that the taxpayer lacked a charitable intent because he investigated the tax benefits of a bargain sale prior to the sale.
The second argument advanced by the IRS was that the value of the real estate did not exceed $2.0 million. The court found the appraisal by the taxpayer's appraiser to be more credible that the appraisal performed by the IRS's appraiser. However, the court did find some flaws in the appraisal of the taxpayer's appraiser and therefore reduced the value of the real estate slightly.
Estate of DiMarco v. Commissioner, T.C. Memo 2015‑184 (Tax Ct. Sept. 21, 2015) — No Estate Charitable Set-Aside Deduction Where Contribution Was Subject of Litigation
John DiMarco's will provided that, after the payment of expenses, his residuary estate was to go to the church that he regularly attended (he actually attended two churches regularly before his death). Pursuant to the will, the executor was to be the pastor at the church that he regularly attended, so the pastors of the two churches he attended were appointed as co‑executors. Several cousins of the decedent claimed that the will was ambiguous and asserted potential interests in the estate.
For the 2010 tax year, the estate reported $335,854 of total income and claimed a $314,942 charitable contribution deduction from gross income as an amount permanently set aside for charitable purposes. That return was untimely filed on or around April 19, 2012, and at some point in April 2012, the parties reached a settlement, under which the cousins would receive approximately one‑third of decedent's gross probate estate, to be divided equally among them, and that the two churches would equally split the remaining portion. A second settlement was later reached that also provided for payment of attorney's fees and co‑executors' commissions, which was approved by the court on or around January 28, 2013. In the end, the two churches received a total of $343,890 from the estate, which included the pastors' commissions for serving as co‑executors.
On October 25, 2013, IRS issued a notice of deficiency denying the $314,942 deduction and determining a deficiency in tax of $108,588. At issue was whether the contribution was "permanently set aside for a charitable purpose."
The estate argued that, as of March 22, 2012, it could determine and account for all of its final administrative expenses, pointing to a settlement meeting that occurred on that date as evidence that the possibility of prolonged legal controversies was "so remote as to be negligible."
IRS, however, argued that the "so remote as to be negligible" standard was not met, noting that the legal controversy was ongoing throughout the year at issue and through the time of filing and that made it likely that additional legal and other expenses would deplete estate assets. Furthermore, the funds were not segregated into a separate account, but rather were held in a general account that the estate used to pay all expenses.
The Tax Court concluded that, given that the estate was in the midst of an ongoing, unresolved legal controversy at the time the return was filed, the possibility that the amount set aside for the exempt beneficiaries could go to noncharitable beneficiaries was not "so remote as to be negligible."
The Tax Court found that the various parties involved, the conflicting claims asserted, and complications with respect to the will itself, all should have alerted the estate that a potential legal controversy was likely and that the "so remote as to be negligible" standard therefore was not met. The court also agreed with the IRS that, under Estate of Belmont, 144 TC No. 6 (2015), the presence of active litigation disqualified the funds from meeting the "permanently set aside" standard.
In Re Mosby, Pension Plan Guide (CCH) ¶ 24018P (D. Kan. Oct. 30, 2015) — Inherited IRA Not Exempt Under Kansas Law
In Mosby, the Debtor had claimed that a certain inherited IRA was exempt under K.S.A. 60‑2308(b). The Trustee objected to the exemption, and the Bankruptcy Court sustained the objection, ruling that the inherited IRA did not fall within the language of Section 60‑2308(b). The Debtor appealed the ruling.
Section 60‑2308(b) provides in relevant part as follows:
Except as provided in subsection (c), any money or other assets payable to a participant or beneficiary from, or any interest of any participant or beneficiary in, a retirement plan which is qualified under sections 401(a), 403(a), 403(b), 408, 408A or 409 of the federal internal revenue code of 1986, and amendments thereto, shall be exempt from any and all claims of creditors of the beneficiary or participant.
The Court stated that under the plain language of the statute, there must be a "retirement plan" and the retirement plan be "qualified" under certain sections of the federal tax code. The Court indicated that the Kansas courts have not construed that term as used in Section 60‑2308(b), but that the United States Supreme Court, in Clark v. Rameker, 134 S. Ct. 2242 (2014), had recently determined that an inherited IRA is not a "retirement plan", and the reasoning from that case applies here as well. In Clark, a unanimous Court held that funds in an inherited IRA do not qualify for the federal bankruptcy exemption because an inherited IRA does not contain "retirement funds." The holder of such an account may not make contributions to it and may withdraw funds at any time without penalty.
Although the Debtor argued that Clark was not controlling because it involved a different statute, using a different term, the Court held that Clark was nevertheless persuasive and indicated how the United States Supreme Court would construe K.S.A. 60‑2308(b). The Court also disagreed with the Debtor that use of the words "any money" in the statute meant that the funds need not be in a plan held for present retirement purposes. The Court stated that the Kansas exemption covers "any money" payable from or any interest in a retirement plan, and an inherited IRA is not a retirement plan.
Green v. United States, 116 A.F.T.R.2d 2015-6668 (W.D. Okla. Nov. 4, 2015) — Charitable Deduction for Trust for Full Value of Appreciated Real Property
In Green, the United States District Court for the Western District of Oklahoma has concluded that a trust that donated appreciated real property to charities could claim a charitable contribution deduction under Code Sec. 642(c)(1) based on the fair market value of those properties.
Under Code Sec. 642(c)(1), in computing its taxable income, a trust may deduct‑in lieu of the deduction allowed by Code Sec. 170(a) (dealing with a charitable contribution deduction)‑any amount of income, without limitation, which under the terms of the governing instrument is paid during the tax year for a charitable purpose (as specified in Code Sec. 170(c)). The charitable deduction is allowed to the trust only for contributions made out of gross income. A contribution made out of income accumulated in earlier years is deductible, but only if no deduction was allowed to the trust for any previous year for the amount currently contributed.
In this case, the taxpayer was a trust, the terms of which expressly authorized the trustee to distribute to charity such amounts from the gross income of the trust as the trustee determined appropriate. The trust also provided that a distribution could be made from the trust to a charity only when both the purpose of the distribution and the charity were described in Code Sec. 170(c).
The trust (through a single‑member limited liability company that was disregarded as an entity separate from the trust for federal income tax purposes) donated various properties that it had purchased to three charities. Each of those properties had a fair market value in excess of its basis.
The trustee filed the trust's income tax return claiming a charitable deduction in excess of $20 million, and later filed an amended income tax return increasing the trust's reported charitable deduction to almost $30 million, and claiming a refund. The IRS sent the trustee a Notice of Disallowance of the refund claim, stating that the charitable contribution deduction for the real property was limited to the basis of the real property contributed.
The trustee contended that a charitable deduction under Code Sec. 642(c)(1) for donated real property purchased out of gross income should be calculated based on the property's fair market value, arguing that the fair market value standard should apply to the charitable deduction because Congress did not specify a different valuation standard in Code Sec. 642(c)(1) .
On the other hand, IRS argued that: (1) Code Sec. 642(c)(1) limits a trust's deduction to the amount of gross income it contributed to charity; (2) gross income does not include unrealized appreciation; and (3) a liberal construction of the statute allowing fair market valuation would negate the requirement that the donation be traceable to gross income.
The district court concluded that the plain language of Code Sec. 642(c)(1) supported a construction in favor of the trustee. The court found that Congress sought in Code Sec. 642(c)(1) to authorize a deduction without limitation, and that the fair market value was the appropriate valuation standard for the donated properties. The court held that there was a notable distinction between Code Sec. 642 and Code Sec. 170 ‑the absence in Code Sec. 642 of the limiting language that was present in Code Sec. 170-, and that the IRS's strained interpretation sought to impose limitations where Congress clearly declined to do so.
Estate of Redstone v. Commissioner, 145 TC NO. 11 (Tax Ct. Oct. 26, 2015) and Redstone v. Commissioner, T.C. Memo 2015-237 (Tax Ct. Dec. 9, 2015) — Two Redstone Gift-Related Cases with Different Results
The two Redstone cases both arose from the same situation. Edward and Sumner Redstone were brothers who worked in the family business National Amusements, Inc. (NAI) with their father, Michael Redstone. Upon NAI's incorporation, the father had contributed a disproportionate amount of capital, but the three were each listed as registered owners of one‑third of NAI's shares. Edward was eventually forced out of the business, and upon his departure, he demanded all of his 100 shares of NAI stock. His father refused to deliver the stock to him, citing the disproportionate capital contributions he had made, and insisting that a portion of Edward's stock had been held in an oral trust for the benefit of Edward=s children. After lengthy negotiations and the filing of two lawsuits, the parties reached a settlement, pursuant to which Edward transferred one‑third of the disputed shares into trusts for his children, and Edward was acknowledged as outright owner of the other two‑thirds of the disputed shares. NAI then redeemed Edward's shares for $5 million.
Three weeks after the settlement agreement was signed, Sumner had one‑third of the NAI shares that were registered in his name re‑issued to two trusts he created for his two children. Sumner did not file a gift tax return.
IRS claimed that the transfers to trusts for Edward's children, were taxable gifts made by Edward, and that the transfers to trusts for Sumner's children, were taxable gifts made by Sumner.
In the case against Edward Redstone, the Tax Court concluded that the stock transfers were the result of a settlement of a dispute over the taxpayer's ownership of stock. The transfer was made in the ordinary course of business and for full and adequate consideration, namely recognition by Edward's father and brother that he was the outright owner of two‑thirds of the disputed share. The Court found that the evidence clearly showed that Edward Redstone transferred stock to his children, not because he wished to do it, but because his father demanded that he do it. At the time of the settlement, Edward had no desire to transfer stock to his children, but was forced to accept this transfer in order to placate his father, settle the family dispute, and obtain a $5 million payment for the remaining shares.
In the case against Sumner Redstone, however, the Tax Court found that Sumner's transfer of stock to trusts for his children was "actuated by love and affection." Sumner was not required to take this action by the settlement agreement that resolved Edward's lawsuits, and was not made in the ordinary course of business within the meaning of Reg. ' 25.2512‑8. Therefore, the transfers made by Sumner were taxable gifts for Federal gift tax purposes.
Estate of Pulling v. Commissioner, T.C. Memo 2015‑134 (Tax Ct. July 23, 2015) — No Assembling of Land for Valuation Required
In Estate of Pulling, the decedent owned three parcels of real estate and also owned at the time of his death a 28% interest in a land trust that owned two adjacent parcels of real estate. All five parcels of real estate were contiguous and were zoned for agricultural purposes. Due to the size, boundaries, and locations of the parcels, residential development of the decedent's parcels was not economically feasible unless the parcels were developed together with the property owned by the land trust. The appraisers for both the IRS and the estate agreed that if the estate's property could be assembled with the property owned by the land trust, then residential development of all five parcels would be the highest and best use of the parcels. The appraisers also agreed that if assemblage was not possible, then residential development of the estate's property would not be economically feasible.
The IRS argued that assemblage was reasonably likely because of the economic benefits that would be derived by the estate and the land trust from assemblage. The court stated that the fact that the greatest economic benefit for both the estate and the land trust would be derived from an assemblage of the property does not establish that such an assemblage was reasonably likely to occur. Evidence presented at trial showed that the owners of the land trust had previously rejected an offer to sell its property as part of a residential development. The court stated that this fact tends to show that the owners of the land trust were not interested in selling the property just because it would have been in their economic interest.
In addition, at trial, the appraisers for both the IRS and the estate testified that they would not recommend to a hypothetical buyer of the estate's property that he purchase the land as a possible investment because assemblage was not certain enough. Therefore, the court rejected the first argument of the IRS.
The IRS's second argument was that assemblage was reasonably likely because the decedent held a large minority interest in the land that when combined with the interests of the other owners of the land trust would result in a majority vote enabling the land trust to combine its property with the estate's property. However, without any evidence regarding the intent of the other owners of the land trust or details as to their relationship with the decedent, the court believed that the IRS's position essentially attributed ownership of the property of the land trust to the decedent solely on the basis of those relationships. The court concluded that the mere fact that the other owners are related to the decedent was not enough.
Therefore, the court having rejected both arguments of the IRS, held that it was not proper to combine the estate's property with that of the land trust for purposes of valuation. Instead, each parcel must be valued separately for estate tax purposes.
RECENT STATUTORY AND REGULATORY
DEVELOPMENTS, AND IRS RULINGS
Memorandum No. 20152201F (May 29, 201) — Failure to Adequately Describe Gifts Leaves Limitations Period Open
In a memorandum from the Office of Chief Counsel, IRS has concluded that a taxpayer failed to disclose gifts (a transfer of interests in two partnerships) to his daughter in a manner adequate to apprise IRS of the nature and amount of the gifts. As a result, the period of limitations for the gift tax was held open indefinitely under Code Sec. 6501(c)(9).
The Donor (taxpayer) in this case filed a Form 709 on which he claimed two gifts, both of which went to his daughter. He attached a one‑paragraph supplement to the return with the heading "Valuation of gifts." The supplement stated that partnership interests were given in two partnerships and provided their taxpayer identification numbers (although only 8 of the 9 digits were listed for one of the partnerships). The supplement stated that the assets of the partnership were primarily farm land and that the land was independently appraised by a certified appraiser. The statement indicated that percentage discounts were taken for "minority interests, lack of marketability, etc." to obtain a fair market value of the gifts.
The IRS concluded that Donor's Form 709 failed to adequately disclose his transfer of interests in two partnerships because it failed to sufficiently identify one of the partnerships, and it failed to adequately describe the method used to determine the fair market values of both partnership interests. Accordingly, the IRS could assess gift tax based upon those transfers at any time.
While the return accurately identified the percentages of the interests that Donor transferred, the descriptions of the interests transferred were incomplete. The return and statement provided an incomplete taxpayer identification number for one of the partnerships, used incorrect, abbreviated names for both partnerships (omitting the "LP" and "LLP" designations), wrongly implying that the partnerships were traditional partnerships under state law, and describing the transferred property as partnership interests without explaining whether the donor transferred general, limited, or limited liability interests.
The IRS also found that the valuation description did not include a detailed description of the method used to determine the fair market value of the property transferred, including any financial data utilized in determining the value of the interests. There was no explanation of the method (e.g., comparable sales) used to determine the value, nor any explanation of either how the percentage discount broke down between different discount types or the basis for the discounts taken. There was also no statement regarding the 100% value of either partnership, even though both entities appeared to be valued based upon their net assets.
PLR 201550005 and PLR 201550012 (Dec. 11, 2015) — Transfers to Directed Trust are Incomplete Gifts
In PLR 201550005 and PLR 201550012, the IRS stated that transfers to an irrevocable trust were not completed transfers for gift tax purposes, and that the trust was not a grantor trust. The trusts were directed trusts for the benefit of the grantor, her stepchildren, her children, and their issue. During the grantor's lifetime, the trustee must distribute net income and principal to and among the beneficiaries as follows: (a) pursuant to the direction of a majority of the distribution committee, with the grantor=s written consent; (b) pursuant to the direction of the unanimous distribution committee members, other than the grantor; and (c) pursuant to the grantor's sole decision, to beneficiaries other than the grantor, for their health, maintenance, support, and education. The IRS stated that, as long as there was a distribution committee, the trust was not a grantor trust, contributions of property to the trust were not completed gifts by the grantor, distributions of property by the distribution committee from the trust to the grantor were not completed gifts by any member of the distribution committee, and distributions of property by the distribution committee from the trust to any beneficiary, other than the grantor, were not completed gifts by any member of the distribution committee, other than the grantor.
Proposed Regulations Redefine Code'S Marriage‑Related Terms to Include Same-Sex Spouses
Following the Supreme Court's decisions on same‑sex marriage in U.S. v. Windsor, 133 S.Ct. 2675 (2013) and Obergefell v. Hodges, 135 S. Ct. 2584 (2015), the IRS has issued proposed regs that would amend the current income, estate, gift, generation‑skipping, employment, and procedure regs under Code Sec. 7701.
Because of the holdings in Windsor and Obergefell, the IRS has determined that, for federal tax purposes, marriages of same‑sex couples should be treated the same as marriages of couples of the opposite sex and that, for reasons set out in Rev. Rul. 2013‑17, terms indicating sex, such as "husband," "wife," and "husband and wife," should be interpreted in a neutral way to include same‑sex spouses as well as opposite‑sex spouses. Accordingly, the proposed regs would provide that, for federal tax purposes, the terms "spouse," "husband," and "wife" mean an individual lawfully married to another individual, and the term "husband and wife" means two individuals lawfully married to each other. These definitions would apply regardless of sex. (Prop. Reg. § 301.7701‑18(a))
In addition, the proposed regs would provide that a marriage of two individuals will be recognized for federal tax purposes if that marriage would be recognized by any state, possession, or territory of the U.S. Under this rule, whether a marriage conducted in a foreign jurisdiction will be recognized for federal tax purposes depends on whether that marriage would be recognized in at least one state, possession, or territory of the U.S. (Prop. Reg. § 301.7701‑18(b))
The proposed regs would not treat registered domestic partnerships, civil unions, or similar relationships that are not denominated as marriage under state law, as marriage for federal tax purposes. (Prop. Reg. § 301.7701‑18(c)).
IRS Account Transcript Take the Place of Estate Tax Closing Letters
The IRS has announced that, for estate tax returns filed on or after June 1, 2015, it would only issue estate tax closing letters upon request by the taxpayer. However, on its website, the IRS has now announced that, for all estate tax returns filed on or after June 1, 2015, account transcripts, which reflect transactions including the acceptance of Form 706 and the completion of an examination, and which are in many cases an acceptable substitute for an estate tax closing letter, are available to tax professionals. The transcripts are available online to registered tax professionals using the Transcript Delivery System (TDS) or to authorized representatives making requests using Form 4506‑T, Request for Transcript of Tax Return.
IRS provides detailed instructions on its website for how tax professionals register for transcripts and how they request and receive them. The instructions discuss the "Transaction Code" and note that Transaction Code 421, "Closed examination of tax return," indicates that an estate tax return has been accepted as filed or that the examination is complete. If Transaction Code 421 is not present, then the tax return remains under review, and the tax professional should allow additional time before checking again.
IRS notes that, with respect to both the TDS and Form 4506‑T, its decision to audit a Form 706 is typically made four to six months after the filing date and that, therefore, tax professionals should wait four to six months after filing Form 706 before submitting a request for an account transcript.
Protecting Americans From Tax Hikes (PATH) Act — H.R. 2029, 114th Cong., 1st Sess. (Dec. 18, 2015)
On December 18, 2015, Congress passed and the President signed into law the Protecting Americans From Tax Hikes (PATH) Act of 2015 (P.L. 114‑113). That Act contains several charitable and gift tax related provisions.
The Act reinstates and makes permanent the rule that otherwise‑taxable IRA distributions are excluded from gross income to the extent they are "qualified charitable distributions." IRA owners who have reached the age of 702 are allowed to make tax‑free charitable contributions of up to $100,000 directly out of their IRAs, and they can be counted as IRA required minimum distributions. The Act makes this tax break permanent so that it is available in tax years 2015 and beyond.
The Act reinstates and makes permanent several expiring tax incentives for charitable contributions of conservation easements. Liberalized deduction rules applied through 2014 that increased the maximum write‑off for these contributions, and the Act makes these liberalized rules permanent.
The Act establishes a new rule for valuing NICRUT and NIMCRUT remainder interests in an early termination. Effective for the termination of trusts after December 18, 2015, the remainder interest is valued using rules similar to the rules for valuing the remainder interest of a charitable remainder trust when determining the amount of the grantor's charitable contribution deduction.
The Act exempts from gift tax gratuitous transfers to certain non‑charity exempt organizations, including social welfare organizations exempt under Code Sec. 501(c)(4), labor or similar organizations exempt under Code Sec. 501(c)(5), and trade associations and business leagues exempt under Code Sec. 501(c)(6).
The Act makes permanent and expands the income tax deduction for certain business contributions of food inventory, increasing the amount of deductible food inventory contributions that taxpayers other than C corporations may make in any taxable year from 10% to 15% of their aggregate net income, and limiting the amount for a C corporation to 15% of its taxable income.
The Act retroactively restores and makes permanent the favorable shareholder basis rule for stock in S corporations that make charitable donations of appreciated assets. For such donations, each shareholder's tax basis in the S corporation's stock is only reduced by the shareholder's pro rata percentage of the company's tax basis in the donated assets. Without this tax break, a shareholder's basis reduction would equal the passed‑through write‑off for the donation (a larger amount). The provision is taxpayer‑friendly because it leaves shareholders with higher tax basis in their S corporation shares.
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The Politechnika Warszawska PW-4 Pelikan was a motor-glider variant of the two seat Polish PW-3 Bakcyl glider. Only one flew.

Design and development
The Pelikan's structure and general layout was based on that of the PW-3 Bakcyl trainer glider. Both had fibreglass-epoxy structures, with a high wing, a tailboom with a conventional tail and a forward fuselage with two seats in tandem under a long canopy. Their differences stemmed from the pusher engine and its propeller, together with new landing gear to enable self-powered take-offs.

Both aircraft had two-part wings built around a single spar with a glassfibre-covered D-box ahead of it and fabric covering behind. Unlike the Bakcyl, no forward sweep was necessary because the weight of the engine moved the centre of gravity rearwards to the passenger's seat, allowing the Pelikan to be flown with that seat occupied or empty, so the central section of the wing was rectangular in plan and the long tips straight-tapered on both leading and trailing edges. As on the Bakcyl, ailerons were on the outer sections and  spoilers inboard, just behind the spars. The wings were braced from the lower fuselage with a single, faired strut to the spar on each side.

Forward of the wing the two aircraft were similar but the pod of the Pelikan ended ahead of the trailing edge of the wing. Its flat four, air-cooled,  Limbach L2000 engine was mounted on the wing and drove a pusher propeller, requiring the slender, rounded tailboom to be lowered from the wing, on the Bakcyl, to the bottom of the pod. The tail was similar to that of the Bakcyl, with a tall, broad fin and smaller, fabric covered rudder, together trapezoidal in profile, and a smaller, low set, fin-mounted, rectangular plan horizontal tail at the extreme end of the tailboom, its one-piece elevator aft of the rudder.

The Pelikan had fixed tricycle gear with mainwheels, equipped with brakes, on arched, cantilever, fibreglass-epoxy/spring legs from the lower fuselage (though one photograph shows an additional drag strut) and a smaller, steerable nosewheel.

Two airframes were built but only one flew, with the other used for stress-testing. The first flight was on 23 December 1990.

Operational history
A very long series of testing followed, only concluding on 29 July 1995. It was decided that the  Pelikan would not sell well, so no more were built. The prototype was operated by the Institute of Aeronautics and Applied Mechanics of Warsaw University of Technology. It displayed at the 16th Meeting of Amateur Aviation Structures in Oleśnica in June 1997 and remained active until seriously damaged in an accident on 11 November 2012. In that period it logged 800 hours of flight.

It never flew again but was restored to display condition by 2015 and can be seen in the Polish Aviation Museum,  Kraków.

Specifications

References

Single-engined pusher aircraft
Motor gliders
 aircraft first flown in 1990
1990s Polish ultralight aircraft
High-wing aircraft

redpajama_set_name: RedPajamaWikipedia


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It was a chance for the Kitchener Rangers to knock off a team that loaded up for a title run.
It was also a chance to avenge an 8-4 drubbing delivered by the Guelph Storm last week at the Aud.
But, perhaps most importantly, Sunday's clash was a chance for Kitchener to send a message to Guelph as the two rivals seem destined to meet each other in the Ontario Hockey League Western Conference quarter-finals in about two weeks.
And the Rangers made good on all three tasks.


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Howard Huskies of Ohio Join GDFL
by Gridiron Media
Cleveland,OH-The State of Ohio has been a staple for football and has had a presence in the Gridiron Developmental Football League (GDFL) since our inception.
On today we are pleased to announce the continuance of this tradition with the addition of the Howard Huskies Football Organization based in Cleveland, Ohio.
The Howard Huskies, formerly the Cleveland Patriots was founded four years ago by Dennis Briggs. Enter Mrs. Veronica Howard who step in mid-season of the teams first season of existence and has been an instrumental part of Patriots success. Since the tragic death of her son in 2011 she has taken her organization in a new direction and has become a platform for the young men in her community to escape the violence that plaques their streets.
The objective of the organization is to promote sponsor and advance national developmental football competition among young men with a focus towards individuals who have experienced distress, poverty and barriers to societal re-entry.
Mrs. Howard stated,"it is our Mission to Build Character while saving lives".
Mrs. Howard has developed a quality program under the coaching direction of her husband of 31 years Coach James Howard.
Coach Howard coached at Lake Erie College and Normandy High School. He coached Travis and Jason Kelce at Cleveland Heights High School. Travis would go on to play tight end for the Kansas City Chiefs of the National Football League. He was drafted by the Chiefs in the third round of the 2013 NFL Draft. He is a three-time Pro Bowler, two-time All-Pro, and was ranked 26th by his fellow players, and second among tight ends, on the NFL Top 100 Players of 2017. Jason, went on to sign with the Philadelphia Eagles of the National Football League. He plays center. Jason was drafted by the Eagles in the sixth round of the 2011 NFL Draft. Jason is a Super Bowl champion, two-time Pro-Bowler and was selected to the 2017 First Team All-Pro.
Coach Howard is supported by assistant Coach Zack Fitch who also acts as Offensive Coordinator, he has been loyal and dedicated to the Huskies Organization for 3 years
The Gridiron Developmental Football League is pleased to welcome the Howard Huskies to the GDFL family.
City: Euclid,OH
Stadium: Hawkens Upper Campus
Colors:Blue,Silver and White
Ownership: Veronica Howard
ABOUT THE GDFL
The Gridiron Developmental Football League is a Professional Developmental Football League based in Memphis, Tennessee. This League was established to provide the community with high quality sports entertainment and to provide athletes the opportunity to participate in professional sports. We are looking at partnering with national and local area businesses in our pursuit of excellence and commitment to our community. Our commitment, dedication, and vision are set on building a firm foundation for professionalism and quality. The Gridiron Developmental Football League continues to strive to provide a quality minor professional level of football throughout the United States and beyond giving area athletes and fans the opportunity be a part of history. Our organization would like to thank you for your support. We are excited about the upcoming season and look forward to "Making AN IMPACT" in our Community.
Fans can visit our website at www.gdfl.org for upcoming announcements, ticketing info, and player tryouts.
The GDFL Communications Office contributed to this article.

redpajama_set_name: RedPajamaCommonCrawl


Studienarbeit aus dem Jahr 2007 im Fachbereich Elektrotechnik, be aware: 1,0, Universität Karlsruhe (TH) (Elektrotechnisches Institut (ETI)), eight Quellen im Literaturverzeichnis, Sprache: Deutsch, summary: In der vorliegenden Studienarbeit wurde aufbauend auf bestehender Umrichterhardware und einem U/f-Kennlinien Programm zunächst eine Rampenregelung abhängig vom Motorstrom und der Zwischenkreisspannung entwickelt. Der Aussteuergrad der Motorsteuerung wird dynamisch an die Zwischenkreisspannung angepasst. Damit ist eine reine Steuerung ohne Drehzahlrückführung möglich.
Eine Inkrementalgeberauswertung mit dem Ziel der Minimierung des Quantisierungsfehlers wurde realisiert.
wurde eine schnelle Schlupfausregelung erreicht.
Die Mikrocontroller software program wurde mit dem Ziel möglichst hoher Modularität erstellt.
Dadurch stehen nun alle entwickelten Module auch für andere Arbeiten auf PIC foundation mit einer einfachen Integrationsmöglichkeit zur Verfügung.
laufenden Betrieb wurde entwickelt und während der assessments ausgiebig verwendet.
Es wurden Umfangreiche Dynamik- und Belastungstests durchgeführt und ausgewertet. Die erreichte Dynamik ist intestine, die Kühlung der Leistungshalbleiter ist für einen Dauerbetrieb an der Leistungsgrenze allerdings ungenügend.
Umrichter mit PC-Messwertanzeige und Parametrisiermöglichkeit zur Verfügung.
The Climate Change Educational Partnership: Climate Change, by Rachelle D. Hollander,Frazier F. Benya,Cameron H.
Societies improve engineered platforms to handle or mediate climate-related difficulties, similar to drought, sea-level upward push or wildfire keep watch over; the mediation comprises public belief, public engagement, and governance. In those efforts, societies additionally come to a decision - deliberately or implicitly - questions of justice and sustainability, akin to what components will obtain mediation measures, what kinds of measures should be used, and what degrees and types of neighborhood affects are tolerated.
In September 2010, the heart for Engineering, Ethics, and Society on the nationwide Academy of Engineering all started operating with 4 different companions on a weather switch academic Partnership part I making plans furnish from the nationwide technological know-how beginning. The undertaking fascinated with defining and characterizing the societal and pedagogical demanding situations posed by way of the interactions of weather swap, engineered platforms and society, and picking the academic efforts community may use to let engineers, academics, scholars, policymakers, and the general public to fulfill the demanding situations. The undertaking additionally aimed to construct understanding of the complexities between a various set of groups plagued by weather switch and engineered structures and to have interaction the groups in addressing those challenges.
The weather swap academic Partnership is the precis of 3 workshops convened over the process the supply at the interactions of weather swap with engineered structures in society and the tutorial efforts had to tackle them. the 1st workshop supplied the companions with an advent to the numerous social and technical dimensions present in the relationships between weather, engineered platforms, and society. the second one workshop outfitted at the universal language built within the first. It allowed the companions to extend involvement within the undertaking to incorporate representatives from neighborhood and tribal schools, expert societies and enterprise. It tested the possibilities and demanding situations for formal and casual schooling, really in engineering study rooms and technology museums, to organize scholars and electorate to handle those matters. The 3rd workshop allowed the companions to develop additional the dialogue and the viewers. It solicited participation from govt officers, local American tribal representatives, expert society leaders, in addition to educators, artists, scientists, and engineers who're constructing courses which could deal with swap and teach scholars and electorate in ways in which foster their management talents. The weather swap academic Partnership may be an invaluable source to engineers, educators, company leaders, neighborhood and neighborhood officers, contributors societies, and others of their efforts to appreciate and tackle the demanding situations of weather switch and its societal impacts.
An access point creation to valuation method, this booklet supplies a simple narrative therapy to the subject material with a large number of examples and illustrations, contained in a simple to learn format.
Construction is likely one of the greatest and such a lot people-intensive commercial sectors. in lots of international locations, although, building is usually the most hugely criticized when it comes to its employment practices and commercial family. humans and tradition are too frequently obvious as variables that needs to be manipulated within the explanation for more suitable productivity.
This very important new paintings offers an important corrective to the present literature via targeting humans and tradition instead of region potency. It provides the most recent considering from a variety of views derived from an immense ESRC seminar sequence and invited contributions from major researchers. Its interdisciplinary strategy attracts jointly and study and is foreign in its relevance.
investigates tips to tackle the talents shortfall presently affecting the industry's performance.
Der Band liefert die Grundlagen der Unternehmensorganisation und macht mit den strategischen und operativen Prozessen des erfolgreichen Unternehmensmanagements in der Bauwirtschaft vertraut. Der Autor beschreibt die Modelle zur Unternehmensgestaltung und gibt Empfehlungen für die zukunftsorientierte Strukturierung der Unternehmensprozesse. Dabei nimmt er neue Managementkonzepte auf, u. a. Sustainable Balanced Scorecard, Bildung strategischer Geschäftseinheiten und Leistungsangebote für Lebenszyklusmanagement, und wendet sie auf Bauunternehmen an.


text:
Telecom Web Services Case Study
A cloud-based implementation of the GSMA's OneAPI written in Java and OSGi
'Telecom Web Services' platform is a cloud-based implementation of the GSMA's OneAPI specification - a set of REST/SOAP APIs built over telecom capabilities such as SMS, MMS, Terminal Location (TLX), etc.
Instil was initially hired back in 2006 to build out a few API services, but our team quickly became responsible for architecting, designing and developing the entire platform.
More than just a collection of cloud-based APIs, the platform was designed around a core set of services that are now considered an essential part of any cloud infrastructure: monitoring, metrics, auditing, load balancing, reporting, auto-scaling, etc - all built from the ground up using a highly modular architecture of Java, OSGi and SpringDM. This modularity extended all the way down to the APIs which were designed as microservices (long before microservices became a thing).
Developed over 3 years, backed by 10000+ automated unit tests, the system is capable of handling thousands of concurrent users and processing many more thousands of transactions per second.
When Instil first got involved in this project, the existing code was packaged as a single project and built into a single Enterprise Archive file (EAR). Deployed to JBoss, the project surfaced a bunch of web services that basically interacted with the underlying gateways through a C++ bridge. As such:
The software was prototypical but already becoming monolithic and therefore needed to be completely overhauled so that it could be onward developed sustainably.
The software was not designed for extensibility. For example, it was not possible for the professional service team to make vendor-specific modifications without changing the core product.
Web services could not be scaled independently from other services.
The software was missing many of the features that would make it a viable product: monitoring, reporting, provisioning, etc.
The majority of the encumbent team were new to Java having mostly worked in C++. The team needed to be mentored and guided on how to write and test robust enterprise scale systems.
The new platform was designed around a core runtime of Java and OSGi. Web services became OSGi bundles - essentially independent projects that could be reasoned about in isolation from other web services - and dependencies were specified and glued together using Spring DM.
The live system made extensive use of OSGi services to provide pluggable cross-cutting capabilities to each web service e.g. normalising supplied telephone numbers in E164 format so that black-listed numbers could be rejected. OSGi services were also used to plug alternative vendor specific behaviour into the system (without having to change the core product code).
The system was designed as a collection of distributed processes that could be scaled independently from each other. In effect each web service was deployed in its own process with its own database table(s), which meant each service could be scaled and monitored independently from other services.
Not quite finally (as we affected a lot more change than this), but the Instil team also introduced a culture of clean code and rigourous unit testing across the entire client organisation, Belfast and Sri Lanka, as well as providing training on OSGi, Java and engineering discipline.
Java, OSGi, Spring, Microservices, Web Services, Cloud, IoT, Telecoms
Have a Project vision?
Give us a call and let's chat about your needs. You will be in safe hands.


text:
Sweta Khandelwal
Immigration Implications of the DOMA Ruling
The Supreme Court of the United States came out with a flurry of exciting decisions last week, including the decision on the Defense of Marriage Act ("DOMA").
The Supreme Court of the United States came out with a flurry of exciting decisions last week, including the decision on the Defense of Marriage Act ("DOMA"). Although it was technically a tax case, the Supreme Court's finding that DOMA was unconstitutional has widespread implications, including in immigration.
Specifically, section 3 of DOMA limited federal recognition of marriage to opposite-sex marriages only. The immigration consequence of section 3 prevented same sex couples from sponsoring their partner for legal permanent residence (a "green card"). Prior to the Supreme Court ruling, there was much litigation and a stubborn policy by USCIS to refuse recognition of same sex marriages. One of the most recent cases is a class action by a lesbian couple from the Philippines, alleging a residency waiver was denied because of DOMA section 3. The implications also run to obtaining United States citizenship, or "naturalization," given that a green card holder spouse could obtain citizenship after three years.
Although the DOMA ruling isn't an affirmative statement, it at the very least gives USCIS one less leg to stand on in denying family-based green card petitions for the estimated 36,000 same-sex couples. And just days after the ruling, Secretary of Homeland Security Janet Napolitano stated that any legally valid marriage to a U.S. Citizen would be recognized. If the Comprehensive Immigration Reform bill passes, which looks more and more likely given the huge approval by the Senate, it would affirmatively allow for same-sex couples to petition for their significant others for immigration benefits.
At the AILA National Conference in San Francisco, USCIS Director and keynote speaker Alejandro Mayorkas also announced that USCIS will re-open all Immigrant Visa petitions for same sex couples that were denied since February 2011. If you have questions about how the DOMA ruling could affect your or someone else's ability to obtain a green card to citizenship, contact our office to speak with an attorney about your case.
4 Traits All Mentors Have in Common
What will be the impact of blockchain on the legal industry?
Introverts: Strategies For A Successful Job Search
The H-1B Visa Explained
L-1A Guidelines Clarified, USCIS Gets Reprimanded
New I-9 Form for Employers
5 Tactics To Help Inspire Your Legal Team


text:
Q: What is the issue with my classpath? (Java) I've been using NetBeans to do all the compilation/classpath work for me, but I wanna give it a go:
Below is what I was typing into command prompt. Can somebody point out why java cannot find the class and how do I help it find the class?
C:\Users\Dziugas>set CLASSPATH=C:\Users\Dziugas\Desktop\Project\path;

C:\Users\Dziugas>cd desktop\Project\path

C:\Users\Dziugas\Desktop\Project\path>dir
 Volume in drive C has no label.
 Volume Serial Number is D89C-971F

 Directory of C:\Users\Dziugas\Desktop\Project\path

26-Nov-14  11:27    <DIR>          .
26-Nov-14  11:27    <DIR>          ..
26-Nov-14  11:27               420 Path.class
26-Nov-14  11:25               161 Path.java
               2 File(s)            581 bytes
               2 Dir(s)  264,542,785,536 bytes free

C:\Users\Dziugas\Desktop\Project\path>java Path
Error: Could not find or load main class Path

I read in the oracle docs that my classpath should be set to the main package. My class is in a package called path:
Desktop > Project > path > Path.class
Path.java straight from notepad++ as requested:
package path;

public class Path {

    public static void main(String[] args) {

        System.out.println("It's Working!");

    }

}

A: Set your class path upto the project level not at the package level.
c:\>set CLASSPATH=C:\Users\Dziugas\Desktop\Project

Then type the following command to execute the program,
c:\>java path.Path

redpajama_set_name: RedPajamaStackExchange


The XS3 is another entry level pistol for target shooting and plinking which uses a traditional break barrel operation. Made from an all weather synthetic material means it can stand up to some bangs and scrapes with ease. The open sights are fitted with fibre optic insets for fast and easy aiming on targets and adjustable for windage and elevation. The action is grooved to accept optics via a dovetail so a red dot or scope can be fitted.


Matson, ReOrder, Manuel Rocca, Andrew Candid & John Dopping, Timmy Rise and more.
Trance For Runners is a series of mixes dedicated to the lovers of trance music, which, in addition to dance, it is very suitable for physical activity in general.
The first mixes are shorts and softs as songs selection, we say for beginners, when the ears and the legs will be more trained, the mixes will become longer and faster.
Great mix, a real pleasure to listen you DJ DEBLIN !!!


text:
Celebrity Cruises resumes cruises to the Galapagos summer 2021
NEWS + 12 PHOTOS: Celebrity Cruises announced its summer 2021 return of cruises to the Galapagos Islands on one of the new luxury brand's three stunning ships that offer itineraries in this unique part of the world.
Beginning July 4, the luxurious, state-of-the-art mega yacht, Celebrity Flora®, will be the first to resume cruises to the Galapagos, the extraordinary archipelago, followed by the award-winning Celebrity Xpedition® and intimate 16-passenger Celebrity Xploration® on July 24, and September 18, respectively.
All ships will offer cruises to the Galapagos with vaccinated crew and will be available to vaccinated adult guests and children under the age of 18 with a negative PCR test result. In addition, all guests should review and comply with local requirements for entry to Ecuador and the Galapagos.
For a limited time, Celebrity is also including airfare in the purchase of a Galapagos vacation package, carefully curated 7-night Celebrity Cruises itineraries combined with all-inclusive land-based accommodations and activities to create 10- to 16-night unforgettable vacation experiences.
The offer is valid for roundtrip economy or business class airfares departing from US or Canadian gateways and valued at up to $750 per person including air taxes and fees on applicable vacation packages on sail dates departing between July 3, 2021 – December 31, 2023. Flights must be booked via Flights by Celebrity by June 30, 2021.
Each ship offers a unique experience for this must-see location. For those looking to explore the Galapagos' spectacular wonders in ultimate luxury, Celebrity Flora, a mega-yacht built specifically to navigate the waters of this natural paradise, is ideal. Inspired by the islands and built with natural materials, including the latest environmental technologies, the ship merges seamlessly with the surroundings.
And, to fully immerse travellers in this extraordinary landscape, certified naturalists from the Galápagos National Park are on board to guide the journey.
Celebrity Xpedition and Celebrity Xploration will both equally offer cruises to the Galapagos with Northern and Southern Loop itineraries, while offering the ultimate individual indulgences.
In this extraordinary destination, every island offers its own unique experiences, from hiking otherworldly volcanic landscapes to snorkelling alongside sea turtles in their natural habitat.
Guests can also partake in twice-daily shore excursions on cruises to the Galapagos guided by Galapagos National Park certified naturalists or stay onboard to relax and be treated to locally-sourced cuisine crafted by a Michelin-starred chef.
From the history and culture of Quito, to the charm and beauty of Lima, to the historical significance of the extraordinary flora and fauna visible everywhere, guests can check multiple items off their bucket list with Celebrity Cruises' sailings to the spectacular Galapagos Islands.
As with all Celebrity Cruises sailings, everything has been thought of for guests for cruises to the Galapagos including unlimited Wi-Fi, drinks, and tips; and vacation packages add luxury hotel stays and flights between Ecuador and the islands.
Source: Celebrity Cruises
Cruise Direct is a Cruiseguru Affiliate and Cruiseguru may earn a small commission at no additional cost to you if you book a cruise
celebrity, CelebrityCruises, celebrityflora, expedition, galapagos, luxurycruise
Norwegian Cruise Line's new Prima cruise ship sails in summer 2022
Norwegian Cruise Line reveals more details about Norwegian Prima cruise ship


text:
package com.bar.foo.tree.test;

import java.util.ArrayList;
import java.util.HashMap;
import java.util.List;
import java.util.Map;

import com.bar.foo.tree.BasicTree;
import com.bar.foo.tree.iterator.TreeIterationOrder;

/**
 * A simple extension of BasicTree (which cannot be instantiated directly due to
 * being abstract and due to its generic class arguments) that adds one string
 * property to the mix.
 *
 * @author Jordan
 *
 */
public class BasicTestTree extends BasicTree<BasicTestTree> {

	/**
	 * A simple string property.
	 */
	public String property = null;

	/**
	 * The map of expected tree iteration orders. This is only initialized for
	 * the root node of the test tree.
	 */
	private Map<TreeIterationOrder, List<BasicTestTree>> expectedOrders;

	/**
	 * Required.
	 */
	@Override
	public BasicTestTree getValue() {
		return this;
	}

	/**
	 * Overrides the node equals method to factor in the {@link #property}.
	 */
	@Override
	public boolean equals(Object object) {
		boolean equals = super.equals(object);
		if (equals && this != object && object instanceof BasicTestTree) {
			BasicTestTree tree = (BasicTestTree) object;
			// Compare the string property.
			equals &= (property == null ? tree.property == null
					: property.equals(tree.property));
		}
		return equals;
	}

	/**
	 * Overrides the node hash method to factor in the {@link #property}.
	 */
	@Override
	public int hashCode() {
		int hash = super.hashCode();
		hash = hash * 31 + (property == null ? 0 : property.hashCode());
		return hash;
	}

	/**
	 * Creates a tree for testing purposes. This is intended for use with the
	 * iterator tests. The structure of the tree is shown below (assume
	 * insertion order is top-to-bottom):
	 *
	 * <pre>
	 * A1
	 * |--B1
	 * |  \-C1
	 * |
	 * \--B2
	 *    |--C2
	 *    |--C3
	 *    |  |--D1
	 *    |  \--D2
	 *    |
	 *    \--C4
	 *       |--D3
	 *       |--D4
	 *       \--D5
	 * </pre>
	 *
	 * @return A tree with 4 layers and several children per layer.
	 */
	public static BasicTestTree createTestTree() {

		BasicTestTree a1;
		BasicTestTree b1, b2;
		BasicTestTree c1, c2, c3, c4;
		BasicTestTree d1, d2, d3, d4, d5;

		// The root node is labeled A for top level and 1 for first "A".
		a1 = new BasicTestTree();
		a1.property = "A1";

		// The first sub-tree is B1 with a child C1.
		b1 = new BasicTestTree();
		b1.property = "B1";
		a1.addChild(b1);
		c1 = new BasicTestTree();
		c1.property = "C1";
		b1.addChild(c1);

		// The second sub-tree is B2. It has 3 C children and 5 D grandchildren.
		b2 = new BasicTestTree();
		b2.property = "B2";
		a1.addChild(b2);

		// C2 is a child of B2 but has no children.
		c2 = new BasicTestTree();
		c2.property = "C2";
		b2.addChild(c2);

		// C3 is a child of B2 and has children D1 and D2.
		c3 = new BasicTestTree();
		c3.property = "C3";
		b2.addChild(c3);
		// C3's children...
		d1 = new BasicTestTree();
		d1.property = "D1";
		c3.addChild(d1);
		d2 = new BasicTestTree();
		d2.property = "D2";
		c3.addChild(d2);

		// C4 is a child of B2 and has children D3, D4, and D5.
		c4 = new BasicTestTree();
		c4.property = "C4";
		b2.addChild(c4);
		// C4's children...
		d3 = new BasicTestTree();
		d3.property = "D3";
		c4.addChild(d3);
		d4 = new BasicTestTree();
		d4.property = "D4";
		c4.addChild(d4);
		d5 = new BasicTestTree();
		d5.property = "D5";
		c4.addChild(d5);

		// Set up the map of expected tree iteration orders.
		a1.expectedOrders = new HashMap<TreeIterationOrder, List<BasicTestTree>>();

		// pre-order: A1 B1 C1 B2 C2 C3 D1 D2 C4 D3 D4 D5
		a1.expectedOrders.put(TreeIterationOrder.PreOrder,
				createList(a1, b1, c1, b2, c2, c3, d1, d2, c4, d3, d4, d5));

		// post-order: C1 B1 C2 D1 D2 C3 D3 D4 D5 C4 B2 A1
		a1.expectedOrders.put(TreeIterationOrder.PostOrder,
				createList(c1, b1, c2, d1, d2, c3, d3, d4, d5, c4, b2, a1));

		// breadth-first: A1 B1 B2 C1 C2 C3 C4 D1 D2 D3 D4 D5
		a1.expectedOrders.put(TreeIterationOrder.BreadthFirst,
				createList(a1, b1, b2, c1, c2, c3, c4, d1, d2, d3, d4, d5));

		return a1;
	}

	/**
	 * Creates a list from the nodes specified in the arguments. No error
	 * handling is performed.
	 */
	private static List<BasicTestTree> createList(BasicTestTree... nodes) {
		List<BasicTestTree> list = new ArrayList<BasicTestTree>(nodes.length);
		for (BasicTestTree node : nodes) {
			list.add(node);
		}
		return list;
	}

	/**
	 * Gets the expected ordering of nodes based on the desired tree iteration
	 * order.
	 *
	 * @param order
	 *            The desired order of nodes.
	 * @return The expected order of nodes.
	 */
	public List<BasicTestTree> getExpectedOrder(TreeIterationOrder order) {
		return (expectedOrders != null ? expectedOrders.get(order) : null);
	}
}

redpajama_set_name: RedPajamaGithub


text:
Stories from Wednesday, August 12, 2009
Joseph Yates (Obituary ~ 08/12/09)
Joseph "Tuffy" Yates, 86, of Marshall, died Saturday, Aug. 8, 2009, at The Living Center in Marshall. Funeral services will be held at 11 a.m. Saturday, Aug. 15, 2009, at Campbell-Lewis Chapel in Marshall, with William W. Harlow officiating. Visitation will be held from 10 to 11 a.m. Saturday at the funeral home. Burial with military rites will be in Slater City Cemetery. Memorials may be made to family choice. Friends may sign the online register book at www.campbell-lewis.com...
Marshall Municipal Band wraps up season with special state fair performance, local concert (Local News ~ 08/12/09)
The 88th season of the Marshall Municipal Band will come to a close Thursday evening, Aug. 13, on the east lawn of First United Methodist Church. But before band members play their final concert, they will first travel to Sedalia, where they will perform for the opening ceremonies of the 107th Missouri State Fair...
Courthouse renovation work picks up momentum (Local News ~ 08/12/09)
Marshall swimmers win seven races in Division II East meet (Community Sports ~ 08/12/09)
Swimmers from Marshall won seven blue ribbons during the Missouri Valley Division II East Championships, July 24-26 at Lawrence, Kan. Against stiffer competition the following week at the Division I meet in Lenexa, Kan., awards were harder to come by...
The Shepherd's Heart: Releasing Some Pressure (Column ~ 08/12/09)
A week or two ago, our family vacationed on the banks of the Gasconade River, at a small private campground just across the river from Boiling Spring, a cold water spring that bubbles up near the east bank, pouring more than 42 million gallons of fresh water into the river each day. ...
In Print: Stories in today's print and e-edition August 12 (Local News ~ 08/12/09)
Interesting news and features published in our print edition and e-edition August 12. On page 2: News of the Weird from columnist Chuck Shepherd. Warranty deeds. On page 3: Advice from Annie's Mailbox and the calendar of events. A report from a recent meeting of Marshall Optimist Club...


[artist id="3080429"]David Archuleta[/artist], last year's [news id="1588037"]"American Idol" runner-up[/news], will be guest starring on [artist id="2408193"]Miley Cyrus[/artist]' hit Disney show, "Hannah Montana," sometime in the near future. Although the details surrounding his appearance — including when it will air — aren't concrete, he did share with his fans how enthusiastic he is about the opportunity.
Archuleta, who already filmed his guest stint, revealed on his blog that at first he was nervous to make an appearance on the show. "It was another thing I was really nervous about and wasn't really sure about at first," he said of the experience.
"Miley was a cool person to hang out with," Archuleta said, adding that "once I got there I had a great time! Everyone there was fun. She has a lot of energy and is really funny haha. Getting to watch how they rehearsed the scenes for the show was really cool too."
Although Archuleta admitted that he's never watched "Hannah Montana" before, he described the scenes he got to see taped as "funny." Archuleta previously did a guest spot on Nickelodeon's "iCarly," starring Miranda Cosgrove, where he appeared as himself. No word if he's playing himself on "Hannah Montana" as well.
"I think it'll be fun to see how the whole show runs [all together], because it was just cool to see how great of actors the other kids were," he said. Other than racking up cameo appearances on tween comedies, Archuleta will also be keeping busy this spring on a European tour.


text:
FinCEN Launches Pilot to Enable International SAR Intelligence Sharing
Regulators & Key Institutions Latest News
Insights FinCEN Launches Pilot to Enable International SAR Intelligence Sharing
The US Treasury's Financial Crimes Enforcement Network (FinCEN) has proposed new measures to allow banks to share suspicious activity reports (SARs) more easily with foreign branches, subsidiaries and affiliates.
In a Notice of Proposed Rulemaking (NPRM) FinCEN has asked for public comment on plans to create a two year pilot program enabling banks to share SARs outside the US. The program aims to improve firms' ability to counter money laundering and illicit finance risks, subject to approval and conditions set by FinCEN.
FinCEN says the sharing of information will be limited by the requirements of federal and state law enforcement, take into account the concerns of the intelligence community, and is subject to standards and requirements regarding data security and confidentiality.
"We urge stakeholders to provide input to assist us in developing a program that will help combat illicit finance risks and promote enterprise-wide risk management, while ensuring adequate safeguards are in place to protect SAR confidentiality," said FinCEN Acting Director Himamauli Das.
Under previous guidance, banks with US operations were allowed to share SARs only with their foreign head offices, controlling companies or affiliates that also filed SARs — this did not include foreign bank branches or affiliates.
FinCEN expects around 100 banks to sign up for the program – but some may consider the cost and capacity issues related to its requirements to be too arduous, or be apprehensive about sharing information across regions.
Participants need to complete an application and file quarterly reports – including information on possible legal and compliance issues with their own anti-money-laundering programs. FinCEN may also require additional internal controls to ensure banks are meeting data security and confidentiality requirements.
There would also be geopolitical restrictions. Banks could not share information with branches in China, Russia, or any country subject to US sanctions, any identified as a primary money laundering concern pursuant to Section 311 of the US Patriot Act, or designated a state sponsor of terrorism.
FinCEN's new program was mandated in accordance with Section 6212 of the Anti-Money Laundering Act 2020, which came into force in January 2021. Comments on the NPRM should be submitted by March 28, 2022.
Regulatory Innovation: A Key Trend for 2022
FinCEN's announcement reflects the increasingly borderless nature of financial crime, and regulators' efforts to innovate in order to help firms effectively manage the risks they face. Cybercrime, and ransomware in particular, is a growing international threat. Its borderless nature, and the pace at which hostile actors – including many in North Korea – can operate, means that rapid information sharing and the ability to develop a holistic picture of a person or entity's activity is critical.
The Monetary Authority of Singapore (MAS), Hong Kong Monetary Authority (HKMA), and Australian Transaction Reports and Analysis Centre (AUSTRAC) have all introduced innovative new approaches. This announcement from FinCEN is the latest sign that others are following suit.
In November 2021, HKMA launched an Anti-Money Laundering (AML) Regtech Lab (AMLab) to encourage the use of regulatory technology as part of its Fintech 2025 strategy. It followed a January report 2021 – AML/CFT Regtech: Case Studies and Insights – which showed the country's progress in the field of regtech. The report showed 60% of banks had introduced tools such as robotic process automation, natural language processing, and no-code workflow automation to optimize AML/CFT work, between 2019-2021.
The AMLab series aims to provide a collaborative platform for ongoing peer group sharing in Hong Kong, strengthening the 'gatekeeper' role of banks in the AML ecosystem, protecting banks and customers from threats and losses from fraud and financial crime, and encouraging further collaboration.
Meanwhile, MAS is set to introduce an information sharing platform to fight money laundering. MAS's Collaborative Sharing of ML/TF Information and Cases (COSMIC) platform will enable firms to digitally warn each other about unusual activity in customers' accounts – a gap currently exploited by criminals to make illegal transactions through a web of different entities with accounts in different FIs.
Firms will be able to share information securely through the platform – due to be introduced in early 2023 – when 'material risk thresholds' are breached, 'red flagging' transactions to enable easier tracking and faster responses to criminal behavior.
AUSTRAC also recently praised Australian banks for improved collaboration and improvement of their compliance programs, to more effectively tackle money laundering, organized crime, tax evasion, and welfare fraud.
Firms with operations in the US looking to take part in the program should explore and assess the information sharing protocols necessary to supply SAR information securely. This may include deciding when requests are necessary, how the information is handled, and how it is stored. National regulations on data handling will need to be complied with, alongside the terms stipulated by FinCEN.
Find out more about the state of financial crime in 2022 by pre-registering for this year's report.
Originally published January 28, 2022, updated May 6, 2022
Monaco's AML System Deemed "Inadequate" in MONEYVAL Report
Ex-FBI Agent Charged with Violating Russia Sanctions and Money Laundering
Thai Banks Prepare for New Central Fraud Registry
New FinCEN Alert: Red Flag Indicators of Human Smuggling


The first season of Hell on Wheels largely centers around Cullen Bohannon's quest for vengeance in seeking out those who murdered his family. This quest is his singular focus during the season, particularly early in the season. As Durant's right-hand man, The Swede is prominently featured maintaining strict security while continuing to undermine Cullen.
Moral and identity struggles are common themes throughout the season… stemming from Cullen's personal vendetta, Elam's struggle with equality, and Lilly's independent struggle with establishing her own identity separate that of her dead husband.


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Storager® can either operate in combination with existing Renewable Energy plants and/or Sunfold®, another Tiger Power Solution. Thanks to Tiger Power's proprietary EnergyManagement System which is predictive and self-learning you can enjoy worriless 100% clean energy day and night all through the year, up to 20 years long.
What does Storager® do for you?
Storager® is a modular energy storage concept that suits your storage and inlet/outlet power requirements. Storager® can accept up to 25kW inlet power and can power a continuous AC or DC-load of up to 10kW.
Typically, the energy storage capacity based on self-generated hydrogen can vary between 100kWh and 300kWh. Additionally, Storager® is standard equipped with an integrated back-up facility that provides an additional 200kWh autonomy. For example, in case of a continuous load of 3kW the total autonomy is ± 5 days! For larger sites or for higher storage capacities multiple Storagers can easily work in parallel.
As Storager® is designed to operate in remote and harsh locations where no supervisory manpower is available, each unit is equipped with a reliable control unit that acts as a local energy dispatcher.
Storager® will also control the energy production and short-term storage by Sunfold® or by a 3rd party Energy plant. Storager® is managed by Tiger Power's cloud based predictive and self-learning energy Management System with associated user interfaces and apps.
Each Storager® houses a complete hydrogen cycle whereby the energy is stored as a pressured gas. Storager® collects, stores and prepares rain water before it is separated noxygen and hydrogen. The hydrogen is stored in highpressure vessels and is converted into electricity by letting it react again with oxygen. As such, renewable energy can be stored for longer periods making use of nothing else than rainwater. And as the hydrogen is stored in conventional pressure vessels this unique energy storage concept, unlike batteries, does not suffer from self-depletion.
As the storage and transport of hydrogen within the process is based on differential pressures, Storager® has no moving parts e.g. pumps which makes the system much less prone to failures. Storager® is designed for over 10.000 storage cycles with not more than one maintenance intervention per year.


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Suicide Prevention Australia / Media Release / Annual Closing the Gap statement focuses on Aboriginal and Torres Strait children
Annual Closing the Gap statement focuses on Aboriginal and Torres Strait children
Prime Minister Scott Morrison has delivered the annual Closing the Gap statement to Parliament, announcing a $1 billion plan to reduce disadvantage among Indigenous Australians.
There was a strong focus on supporting Aboriginal and Torres Strait Islander children with $160 million for the Healthy Mums and Healthy Bubs program, the Community Child Care Fund, the Connected Beginnings Program and the Early Years Education Program.
Our member Gayaa Dhuwi, the new national Aboriginal and Torres Strait Islander social and emotional wellbeing, mental health and suicide prevention leadership body welcomes the investment.
Gayaa Dhuwi Patron, Professor Tom Calma AO said, "We welcome the investment in Closing the Gap to improve Aboriginal and Torres Strait Islander wellbeing. Early childhood is particularly important to building strong, resilient, young people, and assists the future Closing the Gap suicide prevention target."
Suicide Prevention Australia CEO, Nieves Murray said, "Resilience and self-determination is an important protective factor against suicide risk for Aboriginal and Torres Strait Islander people.
"We know the rate of suicides for Aboriginal and Torres Strait Islander peoples is double the rate of the rest of the Australian population. We need to work across government and the community to close this gap."
"It's pleasing to see a commitment around integrating Indigenous social and emotional wellbeing and suicide prevention approaches across Commonwealth and state governments. The language in the plan includes strong support for the role of Aboriginal Community Controlled Health Organisations and an acknowledgement of the role of intergenerational trauma," said Ms Murray.
Read our Aboriginal and Torres Strait Islander Suicide Prevention Policy Position here: https://www.suicidepreventionaust.org/wp-content/uploads/2021/01/Aboriginal-and-Torres-Strait-Islander-Policy-Position-1.pdf.
Further information: Media release Prime Minister Scott Morrison: https://www.pm.gov.au/media/commonwealths-closing-gap-implementation-plan
December Member of the Month: Australian Institute for Suicide Research and Prevention
Insight: Nothing short of a paradigm shift
National Cabinet provides in-principle endorsement of National Mental Health and Suicide Prevention Agreement
Young minds critical to shaping suicide prevention solutions for their peers
South Australia leading the way as first state to adopt a Suicide Prevention Act


These women's Havaianas x Star Wars flip flops are now available at the Disney Store. The blue toned flip flops (or jandals, as we call them here in NZ) feature Kylo Ren and First Order Stormtroopers printed on the footbed.
Kylo Ren and two First Order Stormtroopers add a dark side to these Star Wars: The Force Awakens Flip Flops for Women by Havaianas. A raised Havaianas logo on the straps completes this fan-favorite look.
Available in women's sizes 6 to 12, the flip flops are priced at US$26.00 per pair – the Disney Store can ship internationally.
Photos sourced from and belong to the Disney Store.


Jono and I have recently been working to incorporate the [Parser The Next Generation] into Ubiquity proper, and this of course involves the process of [retooling the standard commands with semantic roles]. The first step, however, is to come up with a list of universal semantic roles which the verbs will be rewritten to use and individual languages' parsers will be built to identify. Today I have just such a proposal.
A quick test for such cases is "would these markers translate to the same markers in a different language?" It's easy to find a language where the two different "with"s and the two different "in"s are expressed using different words. With semantic roles in Parser TNG, it's okay for multiple semantic roles to share the same delimiters/markers.
Here is a set of semantic roles which I would like to propose. Keep in mind that these roles should map to morphological features in languages, not necessarily to the type of content in the argument (which is why we also will keep the noun types).
example: in English, arguments marked by "to", "into", "toward", etc.
example: in English, arguments marked by "from", "by", etc.
position: refers to a (metaphorical) location which defines the scope of an action, in contrast to goal and source.
example: in English, arguments marked by "in", "at", "near", etc.
Note that all three locational roles, goal, source, and location may be used for both times and places as the morphological marking of temporal and spacial expressions are often conflated in language. The appropriate type of referent (time or space) can then be specified with the noun type.
The only problematic standard command, then, is the share-on-delicious command which can take both tags and a title, both of which would most naturally correspond to the alias role. If you have a suggestion for how best to deal with this type of case, I'd love to hear your suggestions!
The Filmore (1971) semantic role of "result" may also be lumped into this.


But there was also an overriding sense of relief at a thought no sensible South Floridian can deny: It easily could have been a lot worse.
Florida Gov. Rick Scott, fresh off surveying Irma's damage from a U.S. Coast Guard HC 144 Ocean Sentry aircraft that flew from Naples south along Florida's Gulf Coast to Key West and then back north to Opa-locka, said he saw homes without roofs, downed trees and power lines and sand in the road from storm surge.
But, outside of the hard-hit Florida Keys, it wasn't quite as bad as he had feared.
That's not to say there was not some real physical damage in places in Miami-Dade or Broward, though those instances seemed to be isolated, nor some real desperation — especially among frustrated, anxious Keys residents waiting vainly in the heat on U.S. 1 in South Miami-Dade to be allowed back in by the Florida Highway Patrol. Some hadn't heard from friends and relatives who had stayed behind on the islands. (Residents and business owners from the Upper Keys — including Key Largo, Tavernier and Islamorada — will be allowed to return beginning at 7 a.m. Tuesday, according to a Monroe County Facebook post).
But one Miami-Dade resident just back from Bonita Springs, just north of Naples, said what Irma wrought there makes the impact at home seem light by comparison. Irma, which struck the Florida mainland as a Category 3 storm after making landfall in the Keys as a Cat 4, was at one point late last week forecast to bring that terrifying fury on a beeline to far more densely populated South Florida instead.
Lesley Lanza wound up at a Bonita motel after leaving her North Beach apartment in response to evacuation orders last week. But she said what she saw there was devastating — flooding, roofs gone and trees down and broken glass everywhere.
"I think we would have been better off staying," she said after getting back to Miami-Dade, where she was trying to cross the 79th Street Causeway on foot after being told she could not drive home.
Still, Irma did leave a catalogue of damage in Miami-Dade.
The roof of a building in Miami's Edgewater neighborhood peeled off. So did the roof of the Keys Gate charter school in Homestead. Three construction cranes, two in Miami and one in Fort Lauderdale, crumpled. At the Miami Marlins' stadium in Little Havana, Irma's winds peeled the facing off a portion of the retractable sliding roof.
Across Miami-Dade, though, much of the storm's fury appeared concentrated not on concrete, but on green.
Across Coral Gables, residential neighborhoods saw dense tree canopies trashed even as most homes seemed largely unscathed. But countless large specimen trees that had survived previous storms were toppled over in yards, swales and across streets, often blocking in residents.
The scenic tree canopy was also shredded at the quaint, historic shopping village of Cauley Square in South Miami-Dade, though the collection of century-old cottages that make it up were largely intact.
Meanwhile, along the picturesque Coconut Grove waterfront, sailboats were sent to the bottom at Dinner Key Marina, their masts jutting skyward from the sea. Luxury fishing yachts were tossed onto piers or half-submerged next to Monty Trainer's restaurant. Biscayne Bay washed up on Brickell Avenue, downtown Miami and over much of North Bay Village. In Broward, which appears to have suffered less damage than Miami-Dade, water-main breaks prompted boil-water orders in Pembroke Pines and Hollywood, among other places.
While Broward lifted a countywide curfew at 10 a.m. Monday, a 7 a.m.-to-7 p.m. curfew remained in place across Miami-Dade. Several municipalities were also shut off to allow crews to clear streets and inspect bridges and causeways to ensure they're safe for vehicular traffic.
That included Miami Beach, where some 90 percent of traffic signals were out. The causeways to the Beach were scheduled to open at 8 a.m. Tuesday. There was no access to Key Biscayne, which sits at the end of the Rickenbacker Causeway, until further notice.
For some evacuees, that left no good options.
Ronald Rodriguez said he might end up pitching a tent on the 79th Street Causeway for him and his wife, mother and infant son after being told he can't go home to South Beach yet. The family spent four days at a shelter at South Miami High School, but left Monday after being told it would be closing.
With nowhere to go, the family — including 8-month-old Antony — spread out a blanket in a parking lot near the water next to Shuckers Waterfront Grill and enjoyed the breeze.
But for most South Floridians, the highest degree of misery, and the most pressing concern, was associated with electrical power, or the lack of it — and the discouraging prospect of a long wait to get it back.
By Monday afternoon, Florida Power and Light had restored power to 200,000 customers in Miami-Dade. But that left 800,000 more to go, said FPL spokeswoman Florencia Contesse. In Broward County, electricity had been restored to 168,000 customers, but another 630,000 were still in the dark, Contesse said.
Efforts to restore power started even while the storm was battering South Florida, with workers venturing out between bands of weather, Contesse said. Some Miamians could have electricity back in a matter of days. But others might have to wait weeks, she said.
In Homestead, where most residents get power from a city utility, about 90 percent of the city was without electricity as officials prioritized re-powering Homestead Hospital, police stations, nursing homes and elderly facilities.
Though there were two confirmed fatalities in Florida directly attributed to Irma, neither was in Miami-Dade or Broward. That toll, however, is expected to rise once officials further assess damage in the Keys and other hard-hit areas.
Some areas of Miami-Dade seemed to have gotten off lightly. In the Homestead area, most mobile parks — usually among the first victims in high winds — somehow were spared, according to the city.
Betty Alexander, who waited out the storm in the Goldcoaster mobile home park near Florida City, said her home "is a champ" and that the park experienced minimal damage.
Some restaurants, stores and supermarkets were beginning to reopen Monday across Miami-Dade. But with most still closed Monday evening, more than 50 people waited in line at Bay Supermarket in North Beach.
Marco Hildago rode his bicycle to the neighborhood store and waited in line for two hours for cold beer and wine, hot commodities to celebrate what, thankfully, did not happen.


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Timelines offer a great way to represent defining features that happened in your campaign, locations or characters over longer periods of time.
There is no limit to the number of timelines a campaign can have. This allows you to create the timelines of an important character, a family's story, an empire's rise and fall, or the creation legends of your world.
Timelines are split into any number of eras to group things that happened in a specific timeframe. For example, a character's eras could be their childhood, early adulthood, and adulthood. For an empire, that could be the founding years, the expansion period, the golden age, and its ultimate decline and destruction.
Eras are then composed of elements. These can be quick scribbles, or linked to entities. A user of the campaign will only see elements linked to entities they can view. This means you can include potential spoilers and be still sure your players won't find out when viewing a timeline.
Boosted Campaigns have the ability to customise the element icons and colours, allowing them to increase the visual clarity of their timelines.
For Worldbuilders For RPG Campaigns
Create fully custom calendars with the weeks and months you want. Add seasons, weather, moons for flavour and knowing how the world is. Attach entities to the calendar as a reminder with control on how long they last, and how often they occur.
Learn more about this feature
Manage Secrets
Every entity can have several secrets attached to them in the form of posts. These can have permissions to control who sees them, and are visible on the entity's main view to quickly access them at a glance.
Kanka v1.39 - Copyright © 2023 Owlchester SNC - Server time: January 30th 2023, 1:07 am


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Methodist Hymn 1
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Losing Faith In Islam