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2020-08-07 Nathan Talbott 14 July 2020
Guide to Judicial Review, The Loan Charge Review and HMRC
Home / Knowledge base / Judicial Review, The Loan Charge Review and HMRC
Posted by Nathan Talbott on 14 July 2020
The loan charge >
The loan charge review >
The impact >
Real-life example >
What is Judicial Review? >
How does Judicial Review work? >
Possible outcomes >
In conclusion >
Nathan Talbott Partner
The Loan Charge review
Listen to "Loan Charge Review - have you been affected?" on Spreaker.
Have you repaid loans as a result of HMRC's guidance pre-loan charge review that you would no longer be liable for the loan charge for?
We are launching a Judicial Review against HMRC's decision to treat such taxpayers as committing new "relevant steps" if they now undo such repayments.
This guide sets out:
A brief summary of the loan charge;
What changed following the loan charge review; and
What Judicial Review is and how it works.
"City firm service, but from a regional firm - local, personable and cost-effective"
The loan charge
The loan charge was introduced in the Finance Act 2016 as a way for HMRC to recover unpaid taxes that it considered had been lost as a result of tax avoidance schemes where individuals had been paid in the form of a loan instead of salary. Most of these loans were provided by a trust structure, such as an Employee Benefit Trust (EBT), and were designed not to be repaid.
The loan charge was initially implemented to apply to any such loans taken since 1999 and still outstanding on 5 April 2019. Any loans outstanding at that point would be treated as income received in the 2019/20 tax year.
In the build-up to 5 April 2019, HMRC issued guidance proposing two ways to deal with these tax liabilities:
Declare all such loans to HMRC and settle the tax liabilities as if the loans had been taxable income in the relevant tax year; or
Repay the outstanding loans.
Following a lot of pressure from action groups, in September 2019 Parliament commissioned a review on the loan charge to consider "whether the loan charge is an appropriate response to tax avoidance by individuals who have directly entered into loan schemes; and whether the government's announced changes address the issues that have been raised".
The review, conducted by Sir Amyas Morse, finished in December 2019. Sir Morse's report, running to 83 pages, concludes (in brief):
The purpose of the loan charge is supported;
Elements of the loan charge "go too far in undermining or overriding taxpayer protections";
That the loan charge should "not apply to loans entered into by either individuals or employers before 9 December 2010"; and
That "taxpayers who made reasonable disclosure of their scheme usage, but for whom the relevant year is unprotected, should not have that unprotected year in the scope of the loan charge" for tax returns from 2010 to 2016.
Let's unpack numbers 3 and 4.
Number 3 is simple: where a loan was taken pre-9 December 2010, the loan charge should no longer apply.
Number 4 is a little more convoluted: where:
a loan was taken between 9 December 2010 and March 2016; and
that loan was reasonably disclosed to HMRC; and
HMRC has not opened an enquiry or taken some other steps to protect the relevant tax year, then the loan charge no longer applies.
The Government accepted Sir Morse's report, implementing numbers 3 and 4 via new legislation – the Finance Bill 2020 (at the date of writing currently before the House of Lords).
As an aside, for any loans relying on number 4 above, the question of what "reasonably disclosed" means is not straightforward. However, if the individual recipients and sums received can be identified on a tax return of some form, it will probably be sufficient.
The impact of the loan charge review
There can be no question that the loan charge review and the subsequent amendments to legislation are good things. However, while the Finance Bill 2020 deals with circumstances where settlements have been agreed with HMRC for loans no longer covered by the loan charge, it does not address situations where individuals have taken drastic steps to repay loans in reliance on HMRC's guidance and in fear of the loan charge.
An example (based on a real-life scenario):
Mr Smith runs ZYX Ltd - a marketing agency. In 2003/04 ZYX Ltd has a bumper year with profits of £5million. Mr Smith, on the advice of his accountants and tax advisers, pays the £5million to a trust and takes loans in the sum of £4million. This reduces his tax bill to zero.
Fast-forward 15 years. In 2018, following HMRC's guidance, Mr Smith chose to repay the loans. He no longer has £4million in cash, so re-mortgages his house and liquidates several investments. He then repays the £4million loan to the trust.
If the loan had been outstanding at 5 April 2019, Mr Smith would have had to declare it and would have been subject to the loan charge. However, following the loan charge review in December 2019 and subsequent legislation, he would have no longer been liable for the loan charge. He would not have re-mortgaged his house and would not have liquidated his assets.
But the loan was not outstanding – because Mr Smith had repaid it (following HMRC's guidance). He, therefore, writes to HMRC, requesting confirmation that he can cancel his repayment of the loan without being subject to a new tax charge. HMRC respond, denying this request, and confirming that if Mr Smith were to cancel his repayment, this would be treated as a "relevant step" for the purposes of Part 7A of the Finance Act 2012, would be treated as income and taxed accordingly.
Mr Smith is just one example of many queries we have received. It cannot be right or fair that individuals who have tried to comply with tax legislation can be left in a significantly worse position following a change in the law that no one anticipated.
What can Mr Smith do? He can pursue a Judicial Review of HMRC's decision.
Judicial Review allows the courts to examine decisions taken by public bodies (in this instance, HMRC) to ensure that they act lawfully and fairly. On the application of a party with sufficient interest in the case (Mr Smith), the Court will conduct a review of the process which HMRC (or the public body) followed to reach its decision and assess whether or not that decision was validly made.
There are four grounds on which a Judicial Review can be pursued:
Illegality: the public body has misdirected itself in law, exercised its power wrongly or acted ultra vires (that is, beyond the scope of its remit);
Irrationality: where a decision is "so unreasonable that no reasonable authority could ever have come to it" or the decision-maker took account of irrelevant matters (or failed to consider relevant matters);
Procedural unfairness: where the public body has not followed relevant procedures (for example, a flawed redundancy consultation process); and
Legitimate expectation: where a public body fails to act in accordance with what the public could legitimately expect based on the public body's own statements or conduct.
How does Judicial Review work?
The procedure for Judicial Review is straightforward, but the timeframes are very short:
Follow the pre-action protocol for Judicial Review. The point of this is to avoid unnecessary litigation if parties can agree a way forward instead. The pre-action protocol for Judicial Review includes:
A preliminary notice and letter of claim as soon as possible;
A letter of response (within a reasonable timeframe); and
Negotiations (where possible).
Given the tight timeframes of Judicial Review proceedings, it is common for the pre-action protocol stage not to be fully complied with.
Issue proceedings. The claim form must be issued "as soon as practicable" after the relevant decision, and in any event not later than three months after the relevant decision. Numerous documents have to accompany the claim form, which take a significant amount of time to prepare.
Proceedings must then be served (in this case on HMRC) within seven days of the claim form being issued.
Acknowledgement of service from the respondent. This is due 21 days after service of the claim form and sets out a summary of the respondent's grounds for opposing the Judicial Review.
The Court will then consider and assess the Judicial Review and decide whether to permit or refuse the claim. This can take place without a hearing. Where the claim is refused, that is the end (subject to any right of appeal). Where a claim is permitted, any opposing party must file and serve detailed grounds for opposition (together with evidence in support) within 35 days.
Directions will then be given by the Court setting out any steps required to be taken by the parties before the final hearing.
The final hearing will then be listed. There will be oral submissions by the parties, following by a judgment.
What are the possible outcomes?
If a Judicial Review is successful, there are three remedies specifically available in Judicial Review proceedings:
A quashing order – that is an order setting aside the decision being challenged;
A mandatory order – that is an order requiring the public body to retake the decision following the Court's judgment; and
A prohibiting order – that is an order prohibiting the public body from acting beyond its powers.
The most common approach is to seek both a quashing and a mandatory order.
Other remedies available can be a declaration (confirming the rights or legal position of the parties), a stay or injunction (to prevent a decision being acted upon) and damages (in rare circumstances where there is a corresponding claim for damages).
The loan charge review is a good thing. It has rightly reduced the extensive remit of the loan charge to remove loans taken pre-December 2010. It has protected taxpayers who had such loans but had settled with HMRC.
But it has not protected taxpayers who had such loans who have repaid their loans.
Taxpayers who have repaid their loans are now in a worse position. The money is stuck in their trust; trust fees are being incurred, and any attempt to re-withdraw the money will be treated as taxable income.
That is what HMRC has decided. That is what our Judicial Review is challenging.
Tags: Financial services disputes Tax disputes Commercial litigation
Nathan Talbott
Nathan is a member of our tax and financial services litigation team dealing with disputes relating to investments, tax schemes, pensions and HMRC enquiries and negotiations.


Sweet, it is great to hear about your day. Your neighborhood sounds lovely. Like a vacation home. The poem is nicely woven, I enjoyed the honoring of your day.
we have the good and the not so good in nature, that must have not been very pleasant on your runs. running by the beach is so exhilarating!
Paradise! Thanks for showing us the beautiful landscape you enjoy each day.
Thanks V.J. 🙂 Yes, I really do live in Paradise. Beauty in my surroundings.
Boats, flowers, birds…a lovely journey you take. Been a long time since I have lived in Florida, brought back memories.
Thanks Dorianna. 🙂 How long have you been gone?
I remember it was getting crowded but had a pretty beach…about all I remember now.
I love the detail you give us – I particularly enjoyed seeing the cormorants. Your neighbour head sounds beautiful, and you have the gift of appreciating it.
Daily and routine can be a time for thinking and thanking.
The rhythm of the poem makes it seem as if I'm running along beside you, Christine! I especially love the glimpse of cormorants on marker posts, 'Wings outstretched / Drying from the currents' and the 'pelican sunning himself'.
Wow, I'd definitely run in this place any day.
Your run offers some refreshing sights. I felt like I was there with you.
Florida is beautiful. I wish I saw more of it. Nice description of your run/commute through your neighborhood.
This sounds like a paradise… I bicycle to work every day, but no palmtrees or cormorants… not it's dark and often rainy.
Too bad. Reminds me of growing up in England 😐.


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 * https://github.com/facebook/react-native
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import RNWildDreamApp from './app/root';

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redpajama_set_name: RedPajamaGithub


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    <title>dc.js - Sunburst Chart Example with equally sized rings</title>
    <meta charset="UTF-8">
    <link rel="stylesheet" type="text/css" href="../css/bootstrap.min.css">
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Two Chicago lawyers, from different backgrounds, meet during what turns out to be the worst day of their lives. Motivated by the same ambition and a little pushed by fate, the two men befriended each other and decided to join forces. This collaboration will require them to balance their differences of perspective, both professionally and personally.


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Video: Cast and Crew Explains How 'Selma' Comes at an Appropriate Time
http://bcove.me/qif2w54i
Movies	 3 PM 12.23.2014
Melissa Unger
Martin Luther King Jr. has never been portrayed in a main role in a major motion picture before. Director Ava DuVernay figured that was long overdue, which is how the idea for her upcoming film "Selma" came to be.
Little did DuVernay, or anyone else for that matter, know that upon the film's release (January 9, to be exact), the United States would find itself amidst a period of racial tensions in the US. It only makes it more relevant to revisit the life of Dr. King, especially a particular three-month period in which he led a campaign against voting inequality. We were able to catch up with DuVernay, as well as Oprah Winfrey, David Oyelowo, and other stars from the film, who described what releasing a film like "Selma" means in the present day.
Posted to BDCWire, Movies
Song of the Week: Bastille "World Gone Mad"
Bright: The Album releases on Friday. More
'IT' composer Benjamin Wallfisch
Golden Globe and Emmy nominee Benjamin Wallfisch is the composer responsible for the score of the hit movie IT. I talked to Ben about his approach to scoring the new version of this iconic story and his thoughts on film and music overall. Some very insightful commentary; listen in. More
Wonder Woman composer Rupert Gregson-Williams
Rupert Gregson-Williams is an award-winning film composer. He just so happened to compose the score for this summer's big blockbuster Wonder Woman. We talked about his beginnings in film scoring, film scores that move and inspire him and, of course, Wonder Woman. More
Jeff Rapsis adds sound to silent films
Jeff Rapsis is a New England-based composer and performer. Lately, he's been creating live musical scores for silent film screenings. I talked to him about his process and a few of his upcoming performances at The Capitol Theatre in Arlington and the Somerville Theatre. You can keep track of where else Jeff is scoring silent films here. More
Paul Driscoll's spoiler-free Rogue One review
Planning on seeing Rogue One: A Star Wars Story when it opens this weekend? I joined Adam 12 to give you an idea of what to expect. But don't worry, I didn't give anything away. More
Star Wars crashes The Brink
To celebrate the opening of 'The Force Awakens,' I had some very special guests in studio to start the Thursday, December 17 edition of The Brink. Listen. More
Two More Star Wars Clips You'll Want To Watch
Watching the new Star Wars trailer a million times gave us all sorts of feels. And one of those feels was nostalgia. More
Watch this adorable four-year-old kid fight off Jaws in his living room
Looks like this kid is gonna need a bigger couch.
A trailer for the new Pixar movie is out. Yes, it might make you cry.
If you've finally finished crying over Inside Out — or Lava, the short that ran before it — Pixar is readying another assault on your tear ducts with The Good Dinosaur, if its newly released trailer is any indication. More

redpajama_set_name: RedPajamaCommonCrawl


text:
Explore Search Results: author: Lisa A. Conboy
Adequate Relief in a Treatment Trial With IBS Patients: A Prospective Assessment (Journal Article)
Anthony J. Lembo,
Lisa A. Conboy,
Ted J. Kaptchuk,
Mary T. Quilty,
Catherine E. Kerr,
Eric E. Jacobson,
Douglas A. Drossman
OBJECTIVES: Adequate relief (AR) of irritable bowel syndrome (IBS) symptoms (IBS-AR) has been used as a primary end point in many randomized controlled trials of IBS and is considered by the Rome III committee to be an acceptable primary end point. However, controversy exists on whether baseline severity confounds the effect of the treatment outcome. The aim (1) is to compare a subjective report of IBS-AR with global assessment of improvement (IBS-GAI), change in IBS symptom severity scale (IBS-SSS), and IBS quality of life (IBS-QOL); (2) to explore whether initial IBS symptom severity influences the ability of these outcome measures to detect differences post treatment; and (3) to determine whether psychological symptoms influence the sensitivity of these measures, in a randomized controlled treatment trial. METHODS: A total of 289 adult IBS patients were recruited to a treatment trial. Baseline IBS-SSS scores were used to classify IBS severity as mild (<175), moderate (175–300), or severe (>300). Questionnaires were completed at baseline and after 3 weeks of treatment with sham acupuncture or wait-list control. RESULTS: IBS baseline severity (IBS-SSS) significantly affected the proportion of patients who reported IBS-AR at 3 weeks (mild, 70%; moderate, 49.7%; severe, 38.8%) (P<0.05). However, once the patients who reported IBS-AR at baseline (28.0%) were excluded from the analysis, baseline severity no longer affected the proportion of patients reporting IBS-AR. Baseline severity did not have a significant effect on patients reporting moderate or significant improvement on the IBS-GAI (mild, 30%; moderate, 25.3%; severe, 18.8%) (P=NS). Psychological symptoms had no significant correlations with responders after adjusting for baseline severity. CONCLUSIONS: These data suggest that IBS-AR as an end point is inversely related to baseline symptom severity. However, if patients who report AR at screening were excluded from study participation, baseline symptom severity was no longer confounded with a report of AR at the study end point.
Kerr lab
Components of placebo effect: randomised controlled trial in patients with irritable bowel syndrome (Journal Article)
John M. Kelley,
Roger B. Davis,
Irving Kirsch,
Rosa N. Schyner,
Bong Hyun Nam,
Long T. Nguyen,
Min Park,
Andrea L. Rivers,
Claire McManus,
Efi Kokkotou,
Douglas A. Drossman,
Peter Goldman,
Anthony J. Lembo
Objective To investigate whether placebo effects can experimentally be separated into the response to three components—assessment and observation, a therapeutic ritual (placebo treatment), and a supportive patient-practitioner relationship—and then progressively combined to produce incremental clinical improvement in patients with irritable bowel syndrome. To assess the relative magnitude of these components. Design A six week single blind three arm randomised controlled trial. Setting Academic medical centre. Participants 262 adults (76% women), mean (SD) age 39 (14), diagnosed by Rome II criteria for and with a score of ≥150 on the symptom severity scale. Interventions For three weeks either waiting list (observation), placebo acupuncture alone ("limited"), or placebo acupuncture with a patient-practitioner relationship augmented by warmth, attention, and confidence ("augmented"). At three weeks, half of the patients were randomly assigned to continue in their originally assigned group for an additional three weeks. Main outcome measures Global improvement scale (range 1-7), adequate relief of symptoms, symptom severity score, and quality of life. Results At three weeks, scores on the global improvement scale were 3.8 (SD 1.0) v 4.3 (SD 1.4) v 5.0 (SD 1.3) for waiting list versus "limited" versus "augmented," respectively (P<0.001 for trend). The proportion of patients reporting adequate relief showed a similar pattern: 28% on waiting list, 44% in limited group, and 62% in augmented group (P<0.001 for trend). The same trend in response existed in symptom severity score (30 (63) v 42 (67) v 82 (89), P<0.001) and quality of life (3.6 (8.1) v 4.1 (9.4) v 9.3 (14.0), P<0.001). All pairwise comparisons between augmented and limited patient-practitioner relationship were significant: global improvement scale (P<0.001), adequate relief of symptoms (P<0.001), symptom severity score (P=0.007), quality of life (P=0.01).Results were similar at six week follow-up. Conclusion Factors contributing to the placebo effect can be progressively combined in a manner resembling a graded dose escalation of component parts. Non-specific effects can produce statistically and clinically significant outcomes and the patient-practitioner relationship is the most robust component. Trial registration Clinical Trials NCT00065403.
Development of a Chinese Medicine Assessment Measure: An Interdisciplinary Approach Using the Delphi Method (Journal Article)
Rosa N. Schnyer,
Eric Jacobson,
Patrick McKnight,
Thomas Goddard,
Francesca Moscatelli,
Anna T.R. Legedza,
Catherine Kerr,
Peter M. Wayne
Background: The diagnostic framework and clinical reasoning process in Chinese medicine emphasizes the contextual and qualitative nature of a patient's illness. Chinese medicine assessment data may help interpret clinical outcomes. Objectives: As part of a study aimed at assessing the validity and improving the inter-rater reliability of the Chinese diagnostic process, a structured assessment instrument was developed for use in clinical trials of acupuncture and other Chinese medical therapies. Study design: To foster collaboration and maximize resources and information, an interdisciplinary advisory team was assembled. Under the guidance of two group process facilitators, and in order to establish whether the assessment instrument was consistent with accepted Chinese medicine diagnostic categories (face validity) and included the full range of each concept's meaning (content validity), a panel of Traditional Chinese Medicine (TCM) expert clinicians was convened and their responses were organized using the Delphi process, an iterative, anonymous, idea-generating and consensus-building process. An aggregate rating measure was obtained by taking the mean of mean ratings for each question across all 10 experts. Results: Over three rounds, the overall rating increased from 7.4 (SD = 1.3) in Round 1 to 9.1 (SD = 0.5) in Round 3. The level of agreement among clinicians was measured by a decrease in SD. Conclusions: The final instrument TEAMSI-TCM (Traditional East Asian Medicine Structured Interview, TCM version) uses the pattern differentiation model characteristic of TCM. This modular, dynamic version was specifically designed to assess women, with a focus on gynecologic conditions; with modifications it can be adapted for use with other populations and conditions. TEAMSI-TCM is a prescriptive instrument that guides clinicians to use the proper indicators, combine them in a systematic manner, and generate conclusions. In conjunction with treatment manualization and training it may serve to increase inter-rater reliability and inter-trial reproducibility in Chinese medicine clinical trials. Testing of the validity and reliability of this instrument currently is underway.
Effectiveness of recruitment in clinical trials: An analysis of methods used in a trial for irritable bowel syndrome patients (Journal Article)
Siu Ping Chin Feman,
Joyce P. Singer,
Roger B. Davis
A successful clinical trial is dependent on recruitment. Between December 2003 and February 2006, our team successfully enrolled 289 participants in a large, single-center, randomized placebo-controlled trial (RCT) studying the impact of the patient-doctor relationship and acupuncture on irritable bowel syndrome (IBS) patients. This paper reports on the effectiveness of standard recruitment methods such as physician referral, newspaper advertisements, fliers, audio and video media (radio and television commercials) as well as relatively new methods not previously extensively reported on such as internet ads, ads in mass-transit vehicles and movie theater previews. We also report the fraction of cost each method consumed and fraction of recruitment each method generated. Our cost per call from potential participants varied from $3–$103 and cost per enrollment participant varied from $12–$584. Using a novel metric, the efficacy index, we found that physician referrals and flyers were the most effective recruitment method in our trial. Despite some methods being more efficient than others, all methods contributed to the successful recruitment. The iterative use of the efficacy index during a recruitment campaign may be helpful to calibrate and focus on the most effective recruitment methods.
Irritable bowel syndrome,
Patient–physician relationship,
Kerr lab,
Investigating placebo effects in irritable bowel syndrome: A novel research design (Journal Article)
Rachel H. Wasserman,
Anna T. R. Legedza,
Elizabeth B. Morey,
Louis Lasagna,
Catherine E. Kerr
Little is known about placebo effects with scientific precision. Poor methodology has confounded our understanding of the magnitude and even the existence of the placebo effect. Investigating placebo effects presents special research challenges including: the design of appropriate controls for studying placebo effects including separating such effects from natural history and regression to the mean, the need for large sample sizes to capture expected small effects, and the need to understand such potential effects from a patient's perspective. This article summarizes the methodology of an ongoing NIH-funded randomized controlled trial aimed at investigating whether the placebo effect in irritable bowel syndrome (IBS) exists and whether the magnitude of such an effect can be manipulated to vary in a manner analogous to "dose dependence." The trial also uses an innovative combination of quantitative and qualitative methods.
Patient–practitioner relationship,
Placebo effect,
Placebo run-in,
Qualitative methods,
Randomized clinical trial,
Japanese-Style Acupuncture for Endometriosis-Related Pelvic Pain in Adolescents and Young Women: Results of a Randomized Sham-Controlled Trial (Journal Article)
Peter M. Wayne,
Jacqueline Savetsky-German,
Monica H. Shields,
Julie E. Buring,
Ellen Highfield,
Barbara Parton,
Phaedra Thomas,
Marc R. Laufer
Study Objective To assess feasibility, and collect preliminary data for a subsequent randomized, sham-controlled trial to evaluate Japanese-style acupuncture for reducing chronic pelvic pain and improving health-related quality of life (HRQOL) in adolescents with endometriosis. Design Randomized, sham-controlled trial. Settings Tertiary-referral hospital. Participants Eighteen young women (13–22y) with laparoscopically-diagnosed endometriosis-related chronic pelvic pain. Interventions A Japanese style of acupuncture and a sham acupuncture control. Sixteen treatments were administered over 8 weeks. Main Outcome Measures Protocol feasibility, recruitment numbers, pain not associated with menses or intercourse, and multiple HRQOL instruments including Endometriosis Health Profile, Pediatric Quality of Life, Perceived Stress, and Activity Limitation. Results Fourteen participants (out of 18 randomized) completed the study per protocol. Participants in the active acupuncture group (n = 9) experienced an average 4.8 (SD = 2.4) point reduction on a 11 point scale (62%) in pain after 4 weeks, which differed significantly from the control group's (n = 5) average reduction of 1.4 (SD = 2.1) points (P = 0.004). Reduction in pain in the active group persisted through a 6-month assessment; however, after 4 weeks, differences between the active and control group decreased and were not statistically significant. All HRQOL measures indicated greater improvements in the active acupuncture group compared to the control; however, the majority of these trends were not statistically significant. No serious adverse events were reported. Conclusion Preliminary estimates indicate that Japanese-style acupuncture may be an effective, safe, and well-tolerated adjunct therapy for endometriosis-related pelvic pain in adolescents. A more definitive trial evaluating Japanese-style acupuncture in this population is both feasible and warranted.
Endometriosis,
Inflammatory cytokines,
Pelvic pain,
Sham acupuncture
"Maybe I Made Up the Whole Thing": Placebos and Patients' Experiences in a Randomized Controlled Trial (Journal Article)
Jessica Shaw,
Eric E. Jacobson
Patients in the placebo arms of randomized controlled trials (RCT) often experience positive changes from baseline. While multiple theories concerning such "placebo effects" exist, peculiarly, none has been informed by actual interviews of patients undergoing placebo treatment. Here, we report on a qualitative study (n = 27) embedded within a RCT (n = 262) in patients with irritable bowel syndrome. Besides identical placebo acupuncture treatment in the RCT, the qualitative study patients also received an additional set of interviews at the beginning, midpoint, and end of the trial. Interviews of the 12 qualitative subjects who underwent and completed placebo treatment were transcribed. We found that patients (1) were persistently concerned with whether they were receiving placebo or genuine treatment; (2) almost never endorsed "expectation" of improvement but spoke of "hope" instead and frequently reported despair; (3) almost all reported improvement ranging from dramatic psychosocial changes to unambiguous, progressive symptom improvement to tentative impressions of benefit; and (4) often worried whether their improvement was due to normal fluctuations or placebo effects. The placebo treatment was a problematic perturbation that provided an opportunity to reconstruct the experiences of the fluctuations of their illness and how it disrupted their everyday life. Immersion in this RCT was a co-mingling of enactment, embodiment and interpretation involving ritual performance and evocative symbols, shifts in bodily sensations, symptoms, mood, daily life behaviors, and social interactions, all accompanied by self-scrutiny and re-appraisal. The placebo effect involved a spectrum of factors and any single theory of placebo—e.g. expectancy, hope, conditioning, anxiety reduction, report bias, symbolic work, narrative and embodiment—provides an inadequate model to explain its salubrious benefits.
Anthropology,
Anxiety reduction,
Clinical Psychology,
Conditioning,
Embodiment,
Expectancy,
Placebo,
Placebo controls,
Psychiatry,
Public Health/Gesundheitswesen,
Report bias,
Ritual,
Patient expectations in placebo-controlled randomized clinical trials (Journal Article)
David A. Stone,
Lisa A. Conboy ScD,
Ted J. Kaptchuk
Objective To explore participants' experience in placebo-controlled randomized clinical trials (RCTs) specifically in relationship to their expectations. Background Aspects of being in RCTs, such as informed consent, perception of benefit and understanding of randomization, have been examined. In contrast, little is known concerning the formation of patient expectations before and during trials. Methods Qualitative methods using in-depth interviews with a semi-structured interview guide of nine patients from four different RCTs. Data analysis was conducted using a codebook format arranging participant responses under broad analytical headings. The interviewer used a semi-structured interview guide to direct the conversation from one broad topic to the next within the context of the ongoing conversation. A checklist of topics encouraged participants to describe their experiences in RCTs. Narratives concerning expectation, blinding and placebo were compared to identify common themes. Results Patient anticipatory processes were influenced and modified both before and during the trial from multiple inputs. Such factors as past experiences in RCTs, past experiences of ineffective treatment, stress of being off regular medications, fear of being a 'placebo responder', input of non-study doctors or other health professionals, the experience of other participants, measurements of health parameters made during the trial and the presence or absence of side-effects all affected patient expectation. Conclusion Expectations in RCTs are not fixed and instead may be viewed as continuously shaped by multiple inputs that include experience and information received both before and during the trial. Variability in placebo response observed in previous studies may be related to the fluid nature of expectations. Trying to control and equalize expectations in RCTs may be more difficult than previously assumed.
RCTs,
blinding,
expectation,
patient experience,
placebo effects
Placebo acupuncture as a form of ritual touch healing: A neurophenomenological model (Journal Article)
Jessica R. Shaw,
Evidence that placebo acupuncture is an effective treatment for chronic pain presents a puzzle: how do placebo needles appearing to patients to penetrate the body, but instead sitting on the skin's surface in the manner of a tactile stimulus, evoke a healing response? Previous accounts of ritual touch healing in which patients often described enhanced touch sensations (including warmth, tingling or flowing sensations) suggest an embodied healing mechanism. In this qualitative study, we asked a subset of patients in a singleblind randomized trial in irritable bowel syndrome to describe their treatment experiences while undergoing placebo treament. Analysis focused on patients' unprompted descriptions of any enhanced touch sensations (e.g., warmth, tingling) and any significance patients assigned to the sensations. We found in 5/6 cases, patients associated sensations including "warmth" and "tingling" with treatment efficacy. The conclusion offers a "neurophenomenological" account of the placebo effect by considering dynamic effects of attentional filtering on early sensory cortices, possibly underlying the phenomenology of placebo acupuncture.
Attentional filtering,
Healing,
Neurophenomenology,
Phenomenology,
Placebo acupuncture,
Qualitative,
Sensory processing,


Business continuity describes the planning procedures required to ensure that an organisation can continue to operate in the event of any incident that threatens it's daily operations for any significant period of time. The recommended approach for business continuity is one that allows the organisation to prepare in advance for any likely incidents that might happen, and then plan for what can be done in those circumstances.
It won't happen to us", "we will cope – we always do", are frequent responses made by organisations when questioned about their lack of preparedness. It is surprising that many organisations think that they don't have time to plan for something that they assume will not happen. However, something as simple as a power outage can result in thousands of man hours lost, a lack of electricity can mean that there is no way to access the corporate network or a desktop PC.
Whereas disaster recovery may primarily be about an organisation's IT systems, Business Continuity is far wider and has to encompass how employees gain access to the information they need to continue working and providing service to customers when, for example, the office building has been flooded.
Identify and document all the critical resources needed to run the business. These will include both physical and electronic documents and files. The organisation must understand where they are stored and which are 'business critical' – that is, essential to continued daily operations. If access to resources was restricted temporarily, how long could the business continue before emergency action would be required?
Think about all the potential threats or points of weakness in the working environment and the impact that they might have. These should include physical infrastructure factors such as whether is a fire detection system and what could be affected by flooding. Business continuity also needs to take account of information access. Where is vital information stored? Is it backed-up regularly? Are there redundant copies of the information held elsewhere that can be accessed remotely?
Remember that Business Continuity can be threatened by weaknesses outside the organisation itself. What happens if a corporate laptop is lost or stolen? Is there adequate security to protect confidential information on the laptop?
Consider the actions that will need to be taken if the organisation is affected by an incident. The business has to decide in advance what happens next. You will need a plan to assess the extent of the disruption, and decide the response procedures. How will customers and partners contact and communicate with the organisation? Who needs to be informed? How can employees access the information they need to continue to be productive? Can employees work from home? Is there alternative office accommodation available?
Detailed contingency plans are needed to help manage an emergency or disruptive situation. From the perspective of Information Governance, planning revolves around identifying the most important information needed to continue operations, prioritising the information that will be needed straightaway and ensuring that the information is backed up regularly and is available from more than one source should the primary information resource by unavailable. This may require building redundancy into the corporate information storage infrastructure. For example, could a Cloud-based storage provider provide a degree of information resilience and availability that would be a challenge to an office-based LAN? Information Governance policies need to closely manage how corporate information is transferred and stored in the Cloud but as services such as Dropbox become more popular they can begin to be considered as part of a Business Continuity strategy.
This is a really important step for making sure that everything has been considered. Visualise a number of different scenarios that could happen, but keep them realistic. Everyone is familiar with carrying out a fire drill – Business Continuity should be thought of in the same way.


The highly anticipated opening of a futures market for trucking freight contracts is drawing interest from far outside of the shipping and logistics industry. K-Ratio, a subsidiary of Chicago-based K and L Freight Management, was specifically created to serve the needs of the logistics company's clients by hedging risk for both shippers and carriers in a market that is notoriously volatile. Since its inception in November of 2018, the company has quickly attracted talent from a diverse array of backgrounds including NASA scientists, investment bankers, PhDs in mechanical engineering, and the former Chief Information Officer of online travel pioneer, Orbitz.
At $726 billion, trucking is one of the largest industries in the United States. However, contracts between businesses that need to transport freight ("shippers") and the businesses that actually move the cargo ("carriers") are notoriously susceptible to volatility. Factors such as weather, road construction, government regulations, driver shortages, consumer spending, oil prices and more can play havoc with the supply-and-demand economics of the industry. With too much week-to-week and even day-to-day variability in freight rates, many contracts are simply canceled by the parties and renegotiated at "spot rates" which can account for hundreds of millions of dollars annually. Beginning on March 29, 2019 all of that could change affecting businesses of all sizes and in every industry all across the country.
40% of S&P 500 companies say that transportation costs are the most substantial risk to their earnings.
B2B, B2C.... Does it Matter?


MILPITAS, Calif., Nov. 16, 2017 (GLOBE NEWSWIRE) -- Nanometrics Incorporated (NASDAQ:NANO), a leading provider of advanced process control systems, today announced that company management will participate in the 6th Annual NYC Investor Summit, taking place December 6, 2017 at Le Parker Méridien Hotel, New York City.
The presentation material utilized during the NYC Summit will be made accessible on the investor page of the company's website at www.nanometrics.com.
The NYC Summit is hosted by executive management from participating companies and will feature a "round-robin" format consisting of small group meetings, each 30 minutes in duration. During the event, investors and analysts will have the opportunity to meet with up to 10 of the 15 management teams during the 30-minute group meeting sessions, as well as opportunities to meet with additional management teams during the breakfast and lunch networking sessions.
The 15 management teams collectively hosting the 2017 NYC Summit include: Aehr Test (AEHR), Axcelis (ACLS), BE Semiconductor Industries (BESI.AS), Brooks (BRKS), Camtek (CAMT), Cohu (COHU), Electro Scientific (ESIO), FormFactor (FORM), Ichor Systems (ICHR), Intermolecular (IMI), inTEST (INTT), Intevac (IVAC), Kulicke & Soffa (KLIC), Nanometrics (NANO), and Rudolph Technologies (RTEC). Cowen is sponsoring the networking luncheon.
The NYC Investor Summit is by invitation only and is open to accredited investors and publishing research analysts. As space is limited, please RSVP early. Hosts reserve the right to limit attendance as necessary. Last day for registration is November 27, 2017.
To RSVP for the NYC Summit, please contact either of the Summit's co-chairs.


Update-Stacey is a military wife, and she and her family have moved on to other adventures out of state.
Are you looking to do spring mini sessions with your cute kiddos in their Easter best? Or maybe it's time for a family pic or senior pictures?
I'm super excited to tell you that Stacey Mitchell is again offering great spring mini sessions. Readers loved working with her over the holidays, and seriously-what a value! Check our her super reasonable pricing!
You can get in touch with her and see examples of her work on her Facebook page!


text:
Home Bollywood Movie Reviews
Asia's Strongest Passport 2023: Japan on Top, Pakistan, Afghanistan at the Bottom of the List- Check India, China's Rank Here
in Movie Reviews
New Delhi: Do you realise that you may hold the most powerful passport in the world without even realising it? Global unrest during the past several years, brought on by the Covid-19 pandemic and Russia's war on Ukraine, has changed the status of many nations worldwide. Naturally, this has had a big impact on how much information our passports can hold as well as where and how we can travel. As 2023 has just begun Henley & Partners, a global citizenship and residency consultancy company with offices in London, has released the Henley Passport Index for the year 2023 based on special data provided by the International Air Transport Association. The index includes 199 passports and 227 travel destinations, giving users the most extensive and reliable information about their global access and mobility. Each passport is scored on the total number of destinations that the holder can access visa-free.
Here's how the passport score is calculated
The Henley Passport Index compares the visa-free access of 199 different passports to 227 travel destinations. If no visa is required, then a score with value = 1 is created for that passport. The same applies if you can obtain a visa on arrival, a visitor's permit, or an electronic travel authority (ETA) when entering the destination.
Where a visa is required, or where a passport holder has to obtain a government-approved electronic visa (e-Visa) before departure, a score with value = 0 is assigned. This also applies if you need pre-departure government approval for a visa on arrival.
The total score for each passport is equal to the number of destinations for which no visa is required (value = 1).
The ranking of the 2023 Henley Passport Index is now out, with Japan claiming the top spot for the fifth year in a row. India is ranked 85th on the passport index, which indicates that holders of an Indian passport are not need to obtain a visa in order to enter 59 other countries. Afghanistan's passport came in at number 109 with a visa-free score of 27, while Iraq's passport came in at number 108 with a visa-free score of 29. Syria has a visa-free ranking of 107 and a score of 30. With a visa-free score of 32, Pakistan ranks as the fifth worst passport in the world, at number 106. Yemen is ranked 105th with a score of 34 for visa-free travel.
Asia's Strongest Passports- Here's the list
Visa Free Score
193 destinations
97 destinations
China's allows access to 80, the same as Bolivia's. Russia's is better, providing hassle-free entry to 118 destinations, while Afghanistan's remained the weakest, with access to just 27. "At the bottom of the ranking, the Afghanistan passport gives visa-free entry to only 12% of the world and less than 1% of global economic output." noted Henley Passport Index website.
Bigg Boss 16 Shanivaar Ka Vaar updates: Kartik Aaryan enters house, Tina Datta gets evicted
NEW DELHI: High-voltage entertainment drops in tonight's 'Weekend Ka Vaar' hosted by Farah Khan on COLORS' 'Bigg Boss 16' as...
Alka Yagnik Becomes 2022's Most-Streamed Artist on YouTube, Beats Taylor Swift, BTS
NEW DELHI: Bollywood playback singer Alka Yagnik has become the most streamed artist on YouTube globally last year with 15.3...
Survey Shows Lack of Holocaust Awareness in the Netherlands
What another Bank of Canada rate hike could mean
Global shares edge higher, tracking Wall Street rally


The reason why is because of the characters.
Great characters are what make us fall in love with a book.
Boring one dimensional characters inspire no one.
And if you think back to the books you loved the most, you'll realize I'm right.
Luckily, the secret to writing great characters is simple.
Your characters have to express emotion, they have to feel things and interact emotionally with the other characters. When you do this the right way, the emotion gets transferred over to the reader.
They feel what the characters are feeling, connect to them and get caught up in your story.
All about your favorite Books. Novels , Fiction and all other. Get Tips and reviews from other users.


text:
Home>MassCEC Announces Expansion of Program to Boost Adoption of Solar Hot Water Systems
MassCEC Announces Expansion of Program to Boost Adoption of Solar Hot Water Systems
Feb 20, 2014 –
CEO and Executive Director Alicia Barton
Matt Kakley
mkakley@masscec.com
Commonwealth Solar Hot Water program provides rebates for the installation of solar hot water systems
BOSTON – February 20, 2014 –Massachusetts Clean Energy Center (MassCEC) CEO Alicia Barton today announced an increase in the rebate amounts available for individual projects completed under the Commonwealth Solar Hot Water program.
"Solar hot water systems present an opportunity for families and business owners to save money on their water heating bills," said Secretary of Energy and Environmental Affairs Rick Sullivan, who chairs the MassCEC Board of Directors. "Expanding rebates will make these projects more affordable, and hopefully allow more people across Massachusetts to participate."
"By increasing the adoption of clean energy technologies like solar hot water, we can create local jobs and lessen our dependence on costly, dirty fossil fuels," said Barton.
Launched first as a pilot program in 2011, the Commonwealth Solar Hot Water Program offers rebates for qualifying solar hot water projects at residential, multi-family, commercial-scale, municipal and non-profit buildings.
Under new guidelines, home and business owners will be eligible for rebates of up to 40 percent of total system costs, up to $4,500 for residential systems or up to $50,000 for commercial-scale systems.
Non-profit organizations and municipalities, who are not eligible for state and federal tax incentives, will be eligible for larger rebates, and additional funding will be available for projects that are installed alongside solar electricity systems.
Solar hot water systems use the sun's natural energy to heat water for use in homes and businesses, often through roof-mounted panels that look similar to those used to generate solar electricity.
A solar hot water system typically provides between 50 and 75 percent of a household's hot water needs, and can, in some cases, be used to provide space heating. Roughly 20 percent of the energy consumed by a typical Massachusetts home is used to heat water.
Since its launch, the Commonwealth Solar Hot Water program has helped facilitate the installation of nearly 500 systems across Massachusetts.
To find out more about solar hot water, visit www.masscec.com/solarhotwater.
Created by the Green Jobs Act of 2008, the Massachusetts Clean Energy Center (MassCEC) is dedicated to accelerating the success of clean energy technologies, companies and projects in the Commonwealth—while creating high-quality jobs and long-term economic growth for the people of Massachusetts. Since its inception in 2009, MassCEC has helped clean energy companies grow, supported municipal clean energy projects and invested in residential and commercial renewable energy installations creating a robust marketplace for innovative clean technology companies and service providers.
Visit our website:.......................................................http://www.MassCEC.com
Follow MassCEC on Twitter:...........................www.twitter.com/MassCEC
View our videos on You Tube……………………www.youtube.com/masscec
Check out our photos on Flickr………………….www.flickr.com/photos/masscec
63 Franklin Street, 3rd Floor, Boston, MA 02110 — Office: (617) 315-9355 office / Fax: (617) 315-9356 or Fax@masscec.com


What are the main causes when QuickBooks File Doctor Does not work?
What New QuickBooks 2019 Features are most appreciative in terms of Accounting?
How To Contact QuickBooks Support Phone Number ?
QuickBooks Customer Service Phone Number-Why QuickBooks Premier is Great?
QuickBooks Desktop 2019-What New Features & Improvements Are Now Considerable Here!


text:
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text:
Performance studies of the measurement test for detection of gross errors in process data
C. Iordache, R. S.H. Mah*, A. C. Tamhane
Industrial Engineering and Management Sciences
The measurement test proposed by Mah and Tamhane (1982) allows the gross error associated with a measurement to be directly identified without a separate procedure. In this paper a comprehensive evaluation of this test was carried out based on two different definitions of its power. The influence of constraints, network configuration, position of measurement, magnitudes of gross error and standard deviations, number of measurements, and other factors were summarized as rules and guidelines for the application of this test. The simulation procedure developed in this investigation may be used to design a gross error detection scheme for any specific application.
https://doi.org/10.1002/aic.690310717
10.1002/aic.690310717
Dive into the research topics of 'Performance studies of the measurement test for detection of gross errors in process data'. Together they form a unique fingerprint.
Error Chemical Compounds 100%
detection Earth & Environmental Sciences 78%
Guidelines Medicine & Life Sciences 43%
Error detection Engineering & Materials Science 36%
Iordache, C., Mah, R. S. H., & Tamhane, A. C. (1985). Performance studies of the measurement test for detection of gross errors in process data. AIChE Journal, 31(7), 1187-1201. https://doi.org/10.1002/aic.690310717
Iordache, C. ; Mah, R. S.H. ; Tamhane, A. C. / Performance studies of the measurement test for detection of gross errors in process data. In: AIChE Journal. 1985 ; Vol. 31, No. 7. pp. 1187-1201.
@article{0ebb05d8aaac4ec1b70cf15639853360,
title = "Performance studies of the measurement test for detection of gross errors in process data",
abstract = "The measurement test proposed by Mah and Tamhane (1982) allows the gross error associated with a measurement to be directly identified without a separate procedure. In this paper a comprehensive evaluation of this test was carried out based on two different definitions of its power. The influence of constraints, network configuration, position of measurement, magnitudes of gross error and standard deviations, number of measurements, and other factors were summarized as rules and guidelines for the application of this test. The simulation procedure developed in this investigation may be used to design a gross error detection scheme for any specific application.",
author = "C. Iordache and Mah, {R. S.H.} and Tamhane, {A. C.}",
doi = "10.1002/aic.690310717",
journal = "AICHE Journal",
publisher = "American Institute of Chemical Engineers",
Iordache, C, Mah, RSH & Tamhane, AC 1985, 'Performance studies of the measurement test for detection of gross errors in process data', AIChE Journal, vol. 31, no. 7, pp. 1187-1201. https://doi.org/10.1002/aic.690310717
Performance studies of the measurement test for detection of gross errors in process data. / Iordache, C.; Mah, R. S.H.; Tamhane, A. C.
In: AIChE Journal, Vol. 31, No. 7, 07.1985, p. 1187-1201.
T1 - Performance studies of the measurement test for detection of gross errors in process data
AU - Iordache, C.
AU - Mah, R. S.H.
AU - Tamhane, A. C.
N2 - The measurement test proposed by Mah and Tamhane (1982) allows the gross error associated with a measurement to be directly identified without a separate procedure. In this paper a comprehensive evaluation of this test was carried out based on two different definitions of its power. The influence of constraints, network configuration, position of measurement, magnitudes of gross error and standard deviations, number of measurements, and other factors were summarized as rules and guidelines for the application of this test. The simulation procedure developed in this investigation may be used to design a gross error detection scheme for any specific application.
AB - The measurement test proposed by Mah and Tamhane (1982) allows the gross error associated with a measurement to be directly identified without a separate procedure. In this paper a comprehensive evaluation of this test was carried out based on two different definitions of its power. The influence of constraints, network configuration, position of measurement, magnitudes of gross error and standard deviations, number of measurements, and other factors were summarized as rules and guidelines for the application of this test. The simulation procedure developed in this investigation may be used to design a gross error detection scheme for any specific application.
U2 - 10.1002/aic.690310717
DO - 10.1002/aic.690310717
JO - AICHE Journal
JF - AICHE Journal
Iordache C, Mah RSH, Tamhane AC. Performance studies of the measurement test for detection of gross errors in process data. AIChE Journal. 1985 Jul;31(7):1187-1201. https://doi.org/10.1002/aic.690310717


text:
Q: VBA Code to update a field in access My goal is to update the specialty code field based on the entry in the specialty field. As an example, if they select Nurse Practitioner, I want the specialty code field to automatically update to 000.
I've used the following code but to no avail:
Private Sub SpecialtyCode_BeforeUpdate(Cancel As Integer)
Me.SpecialtyCode.Value = DLookup("[HSD_Code]", "Crosswalk_ProviderHSD",
"[Specialty] = Me.Specialty.Value")
End Sub

HSD Code is the specialty code I want to pull and the crosswalk is the table I want to reference.
I'd like to do the same for county and region data given a ZIP Code. I know my code is wrong. What's the proper syntax? Is there a more efficient way of accomplishing this?

A: You can't update the field in its own BeforeUpdate event. And your DLookup syntax is wrong.
Try this:
Private Sub Form_BeforeUpdate(Cancel As Integer)
    Me.SpecialtyCode.Value = _
    DLookup("[HSD_Code]", "Crosswalk_ProviderHSD", "[Specialty] = '" & Me.Specialty.Value & "'")
End Sub

That said, listen to the comments regarding queries.

redpajama_set_name: RedPajamaStackExchange


text:
Parts Of The Amazon Rainforest Are Now Releasing More Carbon Than They Absorb
By Sharon Pruitt-Young
Carl de Souza
Aerial view of a burning area of Amazon rainforest reserve, south of Novo Progresso in Para state, on Aug. 16, 2020.
Portions of the Amazon rainforest are now releasing more carbon dioxide than they absorb, disrupting an important balancing act that signals a worsening of the climate crisis, according to a new study.
Findings from the nearly decade-long research project, published Wednesday in the journal Nature, suggest that deforestation and fire, among other factors, have dramatically undercut the Amazon's ability to absorb heat-trapping carbon emissions from the atmosphere.
Researchers who routinely tested the atmosphere at four areas in Amazonia twice a month over a nine-year period found that not only are carbon emissions higher in the eastern areas of the rainforest than in the western areas, but that the southeastern area is putting more carbon dioxide into the atmosphere than it absorbs. The eastern Amazon is a hotspot of deforestation to facilitate logging and agriculture, including cattle ranches.
In addition to deforestation and fires, the study says the rise in emissions from the Amazon has been accelerated by warming temperatures and "moisture stress" during the dry season. The eastern areas have less moisture than the west during already-difficult dry periods, which now have become drier and have lasted longer due to climate change.
The Amazon may no longer be a reliable carbon sink
For generations, Amazonia, which spans more than two million square miles, was a reliable carbon sink, meaning that it naturally absorbed high levels of carbon dioxide from the air, and it played an important role in keeping the global environment stable.
However, in recent decades, humans have increasingly contributed to the degradation of the Amazon, upsetting a crucial natural balance. Of the 17% of forest reduction that occurred over the last 50 years, about 14% of that loss to the agricultural industry, which has burned the land and used it for crops and livestock, the report states.
Burning the rainforest to make room for crops or livestock can pose dangers for the climate, even decades after those fires occur. Research shows that areas that were burned as long ago as 30 years back — and the accompanying decomposing trees — were still considerable sources of carbon dioxide. Past fires and other factors like logging can also degrade nearby areas that were previously untouched and make those areas more susceptible to burning, according to the study.
The report confirms scientists' worse fears
What's happening now is a domino effect of destruction, one that scientists say needs to be curbed — sooner rather than later.
"The Amazon is a carbon source. No doubt," Luciana Gatti, a researcher at Brazil's National Institute for Space Research who led the study, said in an interview with environmental news site Mongabay. "By now we can say that the budget for the Amazon is 0.3 billion tons of carbon per year [released] into the atmosphere. It's a horrible message."
Gatti said that were it not for the emissions from man-made fires, the southeastern part of the Amazon could have continued to be a "carbon sink," meaning it absorbs more CO2 than it lets out. The region is now at a "tipping point," Gatti said. But when faced with the question of whether these disastrous effects could be reversed if we started now, she answered, "I don't know."
Brazil's president has faced criticism for deforestation
Brazil's president, Jair Bolsonaro, has been criticized for years for his environmental policies and aggressive deforestation of the Amazon. But in 2019 he described troubling deforestation data as "lies."
"You have to understand that the Amazon is Brazil's, not yours," Bolsonaro said, according to The Guardian. "If all this devastation you accuse us of doing was done in the past the Amazon would have stopped existing, it would be a big desert."
The following year, deforestation numbers in the region were the highest they'd been in 12 years.
Sharon Pruitt-Young
See stories by Sharon Pruitt-Young


ONE OF THE WORLD'S MOST POPULAR MOBILE WORD GAMES is better and smarter than ever with all new game modes built for the word player in all of us. Beautifully and intelligently redesigned, Words With Friends 2 is teeming with more ways to challenge your friends and your brain than ever before.
Want to boost your word game? Play against fictional characters in Solo Challenge events, updated with new themes and opponents twice a month. Got a competitive streak? Jump in for a fast-paced team match to test your rapid word building skills in the Lightning Round.
The classic one-on-one gameplay you love is here too and now you can earn unique themed badges for completing weekly challenges and scoring big against your friends. Words With Friends 2 backs up your gameplay by pulling in all your past games, friends and progress from previous versions. There's nothing to lose, and more fun to gain!
Be a part of the BIGGEST LIVE FEATURE ever in your favorite word game!
? Experience Words With Friends LIVE, the hottest, new word trivia game show with real hosts and cash prizes daily!
? Answer 12 word-focused trivia questions correctly for your chance to win real cash and other rewards.
? Even if you answer incorrectly, you can still keep playing to earn in-game rewards and improve your word knowledge.
? Words With Friends LIVE is a new way to test your linguistic smarts and train your brain every day!
? It all starts here. Challenge your Facebook friends and family members to a game or use Smart Match to find your perfect word puzzle opponent.
? Test and improve your word skills against themed WordMaster characters in Solo Challenge events. Stay sharp, because as you move up the ladder, the WordMasters will get tougher to beat.
? Collaborative meets competitive gameplay in this new, fast team mode. Play on a team of up to 5 players, and face off in a match to score the most points first and win.
? Play the weekly challenge and earn fun, themed badges that are different every week. Build the ultimate collection and display them proudly in your badge case.
? Our biggest update to the Dictionary ever includes 50,000 new words, inspired by our players and pop culture.
Play Words With Friends 2 without third party ads between moves if you previously purchased either Words With Friends Pro or no third-party ads in the original Words With Friends on any mobile device. Be sure to login with Facebook or the email account you used to make the previous purchase to continue to play without third party ads between moves.
Already an accomplished Wordie? Like us on Facebook or follow us on Twitter to stay up-to-date on game news, contests, polls and other fun stuff.
Thank you for playing Words With Friends 2!
Download Words With Friends 2 – Word Game Word for PC – Windows XP /7 /8 /10 and MAC PC for Free for PC is now available for free download. You can directly download Download Words With Friends 2 – Word Game Word for PC – Windows XP /7 /8 /10 and MAC PC for Free for PC app. After that you have to also download the Bluestack install files. The last step to run the software are to follow the instructions step by step that will help you run without any issues or errors n Download Words With Friends 2 – Word Game Word for PC – Windows XP /7 /8 /10 and MAC PC for Free for PC in your Windows XP/7/8/10 and MAC PC.
In order to run Download Words With Friends 2 – Word Game Word for PC – Windows XP /7 /8 /10 and MAC PC for Free on your Windows 7/8/10/XP or MAC PC, you will need an Android emulator. There are many emulators for both Android or iOS but we are gonna use Bluestack for it's simplicity and because so far we have not encountered any problem. So the first step is to install Bluestack for PC on your Windows 7/8/10/XP or MAC PC and then would need to install theDownload Words With Friends 2 – Word Game Word for PC – Windows XP /7 /8 /10 and MAC PC for Free for PC apk or setup file.
Bluestack for PC is the best emulator until now and it is capable to run smoothly Android/iOS mobile applications (including Download Words With Friends 2 – Word Game Word for PC – Windows XP /7 /8 /10 and MAC PC for Free for PC) and mobile games on the host PC.
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For that we need the internal search function that is inside the Bluestacks. Simply search in the Bluestack Apps Search Console for . You will be redirected to Play store and from where you could download the Words With Friends 2 – Word Game for PC which now runs smoothly on your Bluestack Emulator.


The 4935 California King Sleigh Bed with Tall Legs by Lifestyle at Beck's Furniture in the Sacramento, Rancho Cordova, Roseville, California area. Product availability may vary. Contact us for the most current availability on this product.
C4935A-CSO-XXXX Cal King Rails 1 0" 0" 0"


text:
[![Gem Version](https://badge.fury.io/rb/cheatset.png)](http://badge.fury.io/rb/cheatset)

Generate your own cheat sheets as docsets for [Dash](http://kapeli.com/dash)!
Use this simple command line tool and write your cheat sheets in an easy
language (Ruby DSL).

## Installation

    $ sudo gem install cheatset

Note: this requires the Xcode Command Line Tools to be installed. Install them using this:

    $ xcode-select --install

## Contributions

If you make a useful cheat sheet, please [contribute it](https://github.com/Kapeli/cheatsheets#readme) to Dash.

## Usage

Write a file (here `sample.rb`) containing your cheat sheet data, e.g.:

```ruby
cheatsheet do
  title 'Sample'               # Will be displayed by Dash in the docset list
  docset_file_name 'Sample'    # Used for the filename of the docset
  keyword 'sample'             # Used as the initial search keyword (listed in Preferences > Docsets)
  # resources 'resources_dir'  # An optional resources folder which can contain images or anything else

  introduction 'My *awesome* cheat sheet'  # Optional, can contain Markdown or HTML

  # A cheat sheet must consist of categories
  category do
    id 'Windows'  # Must be unique and is used as title of the category

    entry do
      command 'CMD+N'         # Optional
      command 'CMD+SHIFT+N'   # Multiple commands are supported
      name 'Create window'    # A short name, can contain Markdown or HTML
      notes 'Some notes'      # Optional longer explanation, can contain Markdown or HTML
    end
    entry do
      command 'CMD+W'
      name 'Close window'
    end
  end

  category do
    id 'Code'
    entry do
      name 'Code sample'
      notes <<-'END'
        ```ruby
        sample = "You can include code snippets as well"
        ```
        Or anything else **Markdown** or HTML.
      END
    end
  end

  notes 'Some notes at the end of the cheat sheet'
end
```

To convert this file to a docset, call

    $ cheatset generate sample.rb

The following values may contain Markdown or HTML:

* The `introduction` and the `notes` of the cheat sheet
* The `name` and the `notes` of the entries

Syntax highlighting is supported (see Ruby code in the sample). For a list of supported languages, see the [rouge](http://rouge.jneen.net/) [lexer repository](https://github.com/jneen/rouge/tree/master/spec/lexers)

For more complete examples look at some of
[the actual cheat sheets](https://github.com/Kapeli/cheatsheets/tree/master/cheatsheets).

If you do not use Ruby or lack a working Ruby toolchain and still want to generate cheatsheets.

You can use the `cheatset` Docker image.

    $ docker pull jonasbn/cheatset:latest
    $ docker run --rm  -it --volume $PWD:/tmp --name cheatset jonasbn/cheatset:latest generate sample.rb

For more details on the Docker image please visit the repositories on [DockerHub](https://hub.docker.com/repository/docker/jonasbn/cheatset) or [GitHub](https://github.com/jonasbn/docker-cheatset)

## Advanced Usage

Apart from the attributes listed in the sample cheat sheet above, you can also use these:

* `style` (under `cheatsheet`) - define any CSS style you want. See example [here](https://github.com/Kapeli/cheatsheets/blob/f9e40e30b6fde9063b7a0fb5de8fb203851b17df/cheatsheets/CSS_Named_Colors.rb#L7-L12)
* `html_class` (under `category`) - define a HTML class to be added to a category. This can be used to define custom styling for each category
* `td_command` (under `entry`) - just like `command`, but multiple ones are added in a separate column (as opposed to a separate row)
* `td_notes` (under `entry`) - just like `notes` but can be repeated multiple times, each becoming a separate column
* `html_notes` (under `entry`) - just like `notes`, but doesn't support Markdown
* `index_name` (under `entry`) - this is not displayed in the cheat sheet at all. You can use it to define a separate index name (i.e what gets added to Dash's search index and is searchable in Dash). In other words, if this entry is not present, the value in `name` is used.

## Thanks

[Nix-wie-weg](https://github.com/Nix-wie-weg/dasheets) for the initial code.