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Day 22 | Advent Calendar
Christmas Dreams by Willow Willers
It is dark and very cold,
I snuggle deep into my blanket fold.
There is no noise, nor light to see
My beloved teddy next to me.
A silver light shows through a curtain chink,
Reminding me that the stars still wink.
The Moon still lights the way
That leads us into the brilliance of the day.
Quietly slipping out of bed,
I find my slippers and dressing gown red.
Heading blindly to the door,
Luckily not tripping on a dropped toy upon the floor
Creeping, creeping, fingers crossed, that no one wakes.
Listening at each step I take
Slipping though the door, along the landing
Where the floor boards creak .
To reach the window big and round,
With cushioned seat. Don't make a sound!
Deep breath now my goal is near,
Don't rush don't slip don't make a sound,
My biggest fear is I'll be found.
So near so far please don't let anyone wake.
For back to bed they will me take.
I need to reach that cushioned seat,
Then in silence the view I can greet.
I pray for in my childhood mind …..
Those gentle wishes left behind.
Finally alone in the silver light of the window,
Curtains drawn back as if a stage.
Yes my wishes have come true
The snow has visited and lies out there clean and new.
It adds a hush to the night
The moon above it looks so bright.
The street looks clean and new, the gardens
All roll into one with white topped trees alive with magic blossom
Time passes as I watch the scene
The cat next door is really vexed
She thinks she has been hexed.
She cannot walk on this deep white stuff.
Jumping and twitching her fur all a fluff
She shoots through her cat flap.
She has had enough.
Then I hear a tinkling sound,
Does it come from sky or ground.
A silver light begins to play
Where our front garden used to lay.
Am I asleep or am I awake?
I'm not sure I can't say
But what I see next is with me still to this day.
A brightly coloured sledge
With sacks of presents glides over the hedge.
The driver all dressed in red with white trim.
I shake my head and press my nose against the window
It is so cold it makes me shiver.
A tiny sigh I deliver.
It must be, can it be, yes it must be him.
He raises a hand in greeting,
His fingers on his lips to silence me.
I wave back my face a grin
As I look a shower of stardust and coloured lights
Remove the beautiful apparition from my sight.
Gently, gently falls the silent snow,
No tracks, no stardust left to show
What I had seen on this night.
I knew at once that if I told,
No one would listen,
And if I repeated I would be chided as bold.
Then as I watched I saw on the white lawn,
A lovely smiley face had been drawnI awoke in my mothers arms,
I started to tell her but she whispered "be calm."
Gently she tucked me up in bed,
She slid teddy onto the pillow next to my head.
Then bending she whispered in my ear.
"Sweet dreams my love and wake anew.
For tonight a special child was born for you".
Author Bio:
I am a married mum and grandmother. I have three handsome sons all grown and flown.The youngest married with a beautiful wife and son of his own. Seven years ago I was working, running a home, driving and socialising then bang in a split second all that was gone. I had an accident at home. I broke my back, not for the first time. Unfortunately this time I had broken it really badly and it was truly messed up so I had to have two operations. I was told before each operation that the outcome could mean I spend the rest of my life in a wheelchair.
Still as some guy once wrote "I am still standing " yes "better than I ever was " not quite but with a lot of determination ( bloody mindedness) physio therapy, work at the gym and Pilates I am now doing most of what I was before and walking stick free.
My hobbies are walking , because I can, blogging because it keeps me sane and music of all sorts.
I started blogging to write out the physical and mental suffering I went through after my accident and I found it was a great help and now I am hooked!
I have made lots of new friends, real diamonds. I am also very grateful for all the support and help I have encountered here on WordPress.
Willow was so kind and to jump in when I was desperately looking for contributors, thus please give her other little poem "Christmas Lights" a read!


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Hello everyone!! I'm on the Top Dog Dies Blog today with another card that I created using one of my new dies.
Did you see that awesome release yesterday? Top Dog Dies released 10 new dies and they are really to "die" for!! Just in case you missed it you can find it here.
They are giving away all of the dies to one lucky winner!! That is $122.00 worth of great dies!! You don't want to miss that.
Today I'm here to show you how to maximize your dies. I used the new Top Dog Dies Typewriter Uppercase Die!
How many time do we use a die for it's intended purpose but throw the negative piece away? Well not today. I'm going to show you how to use that negative piece on your project.
(I saw a card with this technique and I knew I need to give it a try. I wish I knew whose card it was but if anyone knows please let me know.)
Now take a look at my card:
To see how I created this card, head on over to the Top Dog Dies Blog for the full photo tutorial!!
Supplies used:
Thanks for stopping by!

subset: commoncrawl


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What do many Fortune 500 chief executive officers have in common with Rochdale Securities analyst Richard X. Bove? A maniacal pursuit of short-term profits instead of long-term strategies.
To be sure, CEOs have an excuse: Wall Street investors and their boards of directors are laser-focused on quarter-by-quarter performance. And, the average CEO's tenure rivals that of a Mayfly.
But, Bove has no such out. His job is to follow the financial services sector and report on best and worst practices. And, Bove thinks customer service is the wrong way to attract customers!
Based on a recent first-hand experience with Wells Fargo, Bove believes all banks should push products and service rather than catering to customers' whims. Reflecting on Wells Fargo in particular, he said, "I'm struck by the fact that the service is so bad, and yet the company is so good."
Ouch. As one might expect, a Wells Fargo spokesperson immediately responded and, naturally, emphasized the giant bank's focus on delighting customers. And, yet, I fear CEOs and institutional investors will be whipped into a frenzy by Bove's myopic viewpoint and double down on product development and risk management. That's worrisome because it will only produce a short-term spike in sales while damaging the long-term image and reputation of those banks that pursue a parochial path to profits.
Bove seems to have literally lost sight of the modern reality. The customer is king (or queen). Period. The best product in the world can't overcome a horrible experience. And, it can absolutely kill a mediocre or inferior product. Worse still, a single-minded focus on product and profits will undermine the authenticity and credibility of any marketing message from a bank.
In our partnership work with author and customer service expert, Emily Yellin, we've analyzed every brand from Starbucks and Comcast to Sony and T.J. Maxx. And, in almost every instance we've uncovered a disconnect between what the brand promises and what we, placing ourselves in the customers' shoes, actually experienced. And, therein lies the rub (and the opportunity).
Smart CEOs should be taking the exact opposite tack than the one suggested by Bove. They should elevate the role of the chief customer contact executive and empower the customer service representatives to participate in the brand messaging. The latter, and the latter alone, have first-person knowledge of what does, and doesn't, delight the target audience.
Alas, the average chief executive is far more concerned about his personal compensation and golden parachute than in focusing on a long-term strategy that includes superb customer service. For every enlightened Tony Hsieh at Zappos there are far too many Richard X. Bove clones occupying the corner office. And, Bove's clarion call is a real red flag to this blogger. It's a sure fire prescription for short-term profits (and long-term loss).


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Meteor shower -- or two-- Thursday night
- As many as 100 shooting stars an hour could light up the sky
Eat your hearts out, Christmas lights. Thursday night will see a real celestial show as the Geminid meteor shower, one of the two biggest of the year, sprinkles the night sky with falling stars.
And a Russian astronomer is predicting a whole new meteor shower might happen at the same time, giving sky-watchers a double dose of thrills.
"The Geminids are one of the best performers among the meteor showers of the year," says Mark Hammergren, an astronomer at the Adler Planetarium in Chicago.
As many as 100 shooting stars an hour are possible.
The show should start just after sunset local time across North America and continue until dawn. "Meteors will appear in every part of the sky," says Alan MacRobert, a senior editor with Sky & Telescope magazine.
The shower is named for the constellation Gemini because it looks as if the meteors radiate out from it, although they don't.
The Geminids are "right at the top or near the top of most people's lists of meteor showers," Hammergren says.
The second shower comes from a comet named Wirtanen, discovered in 1948, which may cause a new meteor shower.
Meteors are the debris trail of comets, which leave behind bits of ice and rock dust as they swing near the sun on their long, elliptical orbits. The shooting stars appear when that dust and ice burn up in Earth's atmosphere.
Wirtanen takes 5.4 years to orbit the sun. It has come close to Earth's orbit many times, but the Earth has never before run through its debris stream. However, computer models run by Russian forecaster Mikhail Maslov predict it could happen Wednesday or Thursday.
Astronomers haven't yet named the new shower because they don't know if it will produce meteors.
"Dust from this comet hitting Earth's atmosphere could produce as many as 30 meteors per hour," says Bill Cooke of NASA's Meteoroid Environment Office.
"Meteors from the new shower, if any, will be visible in the early evening, with the Geminids making their appearance later on and lasting until dawn," he says. Maslov's model predicts that they will move slower than the Geminids.
For the Geminids, those who brave the cold and find a dark area to watch from should be rewarded with "one or two meteors a minute," MacRobert says. Even in a suburb or brightly lit city, "you might see one every couple of minutes."
The Geminids peak Thursday night into Friday morning, but they'll be visible in lesser numbers as late as Friday night.
Weatherwise, much of the country will have clear skies and seasonably cool temperatures Thursday night. The best areas for viewing the meteor shower will be the Northeast, the Mid-Atlantic, the Midwest, the Plains and the interior Southeast, according to AccuWeather meteorologist Mark Paquette.
The West might be the worst for seeing the shooting stars, Paquette says, because much of the West Coast from the Pacific Northwest down to California will be mostly cloudy with some rain possible. Other likely cloudy spots: southern Texas and the Southeast coast.
If skies are clear, there will be a bonus with this meteor shower: a new moon, so the darker sky will make the meteors easier to see. Paquette says the best time for viewing will be shortly after twilight. Look to the east or northeast to see the most meteors.
The key to seeing the Geminids is to suit up in warm clothes and prepare to spend some serious time outside in the dark.
"It's not going to do any good to go out to your front porch and just look up for a few minutes," Hammergren says.
The eye needs up to 20 minutes to adjust to night vision, he says. Find a dark area away from lights, if possible, and avoid looking at any lights. If you can't get away from city lights, Hammergren says, "at least find a shadowed place that has a wide open view of the sky and doesn't have any light actually glaring into your eye."
The origins of the Geminids is not well understood. Most meteor showers come from icy comets, but these appear to spring from an odd, rocky object named Phaeton after the son of the Greek sun god Helios.
"It's a new type of object that astronomers are talking about," says Rick Kline of Cornell University's Astronomy Department. "It's still something of a mystery."
Contributing: Doyle Rice


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The first time I showed up at Hak Heang Chinese-Cambodian Restaurant, I couldn't get in.
Reading online comments about Hak Heang, this does not seem unusual. It's the top-of-the-line restaurant in Long Beach's Cambodia Town, with Saturday nights apparently often booked for massive weddings, anniversaries or, in this particular case, a Sweet 16 party.
And not a Sweet 16 party like any I've seen before. It took over the whole restaurant, with seating for maybe 300, maybe more.
The parking lot was filled with Mercedes-Benzes. People were dressed to the nines. Photographers were everywhere. There was a small army of security people.
I tried to look into the dining room, and was asked — firmly — to leave. And I don't think the teenager at the center of this extravaganza and her family had arrived yet. I wouldn't have been surprised to find them pulling up in a horse-drawn carriage.
The good news about not being able to get into Hak Heang is that there are a fair number of other options in Cambodia Town — like Siem Reap Khmer and Monorom Cambodian, both of which are a short walk away. The downside is that, like Thai Town in East Hollywood, there's not a lot of charm to the neighborhood. You go where you go, and then you leave; this is not a colorful variation on Little Italy or Chinatown. But what you do eat at Hak Heang, as I found some weeks later, is pretty great stuff, served in a room where the party never ends.
Several nights a week, there are live bands at Hak Heang — and it seems as if there are disc jockeys as well. There are local singers. There's karaoke. There's the community, come out to play. And to throw major events; there are probably more Cambodian events here than anywhere else in the city, which boasts the largest Cambodian population outside Southeast Asia.
When I finally got in on a weekday, I found a restaurant that's a lot less packed than it is at parties. It's such a big room that even with a hundred diners or so, it feels a bit empty. And the long distance that servers have to traverse, from the kitchen to the tables, can make service go a bit wonky.
At first glance, aside from the wonderfully curvy Cambodian letters on the menu, the place may seem more Chinese than Cambodian, and more Thai and Vietnamese as well. The menu is written in Chinese, Cambodian (which looks like transliterated Vietnamese) and English. There's kung pao chicken on the menu, and beef with broccoli. But thanks to the community — and troupes of girls who love to work the microphone — it's hard to get away from the feeling that you're definitely someplace else.
Show up for breakfast, served from 7 a.m. till 2 p.m., and you'll find a selection of dishes I think of as Southeast Asian street market food — a variety of soups, some with rice noodles, some with egg noodles, flavored with seafood, duck, beef stew, beef balls, chicken and pork parts.
Come later in the day, and there's a different world of soups, including an assortment of hot and sours, with shrimp, catfish, banana blossoms, beef and deer.
Many of the dishes are spicy, indicated by a little hot pepper next to their name on the menu. All of the dishes are listed with a photograph, which gives you a fair sense of what you're about to get — though the fried frog on steamed rice could be mistaken for chicken. Isn't that ever the case?
I liked the bo nuong, which is a crispy beef stick, a cousin of satay, served with a pickled salad. Get the barbecue beef (or deer) Cambodian style, and a do-it-yourself meal comes to your table, with meat and condiments on one plate, and rice and raw veggies on another.
The one dish that really stands out as Cambodian is the sadao with fish. In India, sadao is known as "neem." It's a bitter leaf that comes from a tree, and it's used to cure skin diseases. I don't know what it does when eaten, but a little goes a long way. I followed it with some Hainam chicken on steamed rice, a famously bland dish. Like the restaurant itself, contrast is everywhere.
Merrill Shindler is a Los Angeles-based freelance dining critic. Send him email at email@example.com.


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Cullerton dismisses union tax proposals to support pensions
Illinois Senate President John Cullerton Monday largely dismissed a proposal floated by public employee unions to close business tax breaks and raise other taxes in order to meet the state's pension obligations.
Speaking to the editorial board of The State Journal-Register, Cullerton said a change in pension benefits is also necessary to solve the state's pension funding problems.
Cullerton is the sponsor of Senate Bill 1, which incorporates two separate pension reform plans into one bill.
Both of those plans include reductions in cost of living adjustments to pension benefits.
We Are One Illinois, a coalition of public employee unions, is resisting any change to pension benefits.
Instead, it has proposed to have workers contribute more toward their pension plans and that lawmakers enact tax changes the unions say could produce $2 billion for pensions.
"This notion of having to have no sacrifice from the pensioneers and have us just raise taxes and then spend it on them ...," Cullerton said. "What if we had $2 billion in new revenue? Why not do a capital bill? Why not spend more money on human services or pay old bills?"
Nonetheless, Cullerton said he would have a representative at a union-sponsored summit on pension reform to be held later this month. House Speaker Michael Madigan, D-Chicago, issued a blistering letter to We Are One Illinois last week, saying the summit should have been held years ago and accusing the unions of offering "no cooperation" on the issue of pension reform.
Like Madigan, Cullerton said unions have been included in pension reform talks, particularly last spring.
"It's frustrating when they pretend like we weren't meeting," Cullerton said. "We were meeting at the (Executive) Mansion."
He also singled out Henry Bayer, executive director of the American Federation of State, County and Municipal Employees, for blaming lawmakers for underfunding pensions.
"He forgets about the fact he was negotiating what some would say were generous contracts eating up the money instead of putting it in the pension fund," Cullerton said.
The relationship between legislative leaders and public employee unions is strained, Cullerton said, "because the unions are opposed to any changes in the law that's going to go anywhere toward solving the problem."
The offer by unions to have employees pay 2 percentage points more of their salaries toward pensions would generate only a fraction of the $66 billion to $88 billion that would be saved by his plan, Cullerton said.
His plan would force employees and retirees to choose between their current pension COLAs or state-subsidized health insurance.
AFSCME stood by the union plan.
"The plan would free up $2.35 billion a year, more than the value of any of the pension cuts lawmakers have proposed," AFSCME spokesman Anders Lindall said in a statement.
"No other group has volunteered anything to help solve the problem. The union coalition is simply saying that retirees should not be harmed, workers can't do it alone, and walking away from the debt they are owed is irresponsible and wrong."
Cullerton said he is not yet ready to push for passage of Senate Bill 1, but will do so soon.
"We have to start educating our own members," said Cullerton of the 16 new senators. "They aren't familiar yet with the crowding out of the budget."
Some people say the state constitution should be changed to allow Illinois to impose a graduated income tax rather than the flat version it has now.
A graduated tax would be fairer and raise additional revenue, they argue.
Cullerton, though, said it is possible to achieve the effects of a graduated tax without changing the Constitution. That could be achieved by increasing breaks available to lower income taxpayers while raising tax rates, he said.


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The other afternoon I was reading The Northern Miner newspaper from Charters Towers, an old mining town in North Queensland where one branch of my family had lived for some decades. I had ordered the microfilm in on an inter-library loan from the National Library of Australia to follow up some information on a friend's family history.
I was focused on a particular month in 1947 and what struck me afresh was just how full of human misery a newspaper can be. This sometimes seems to be more obvious decades ago when it was reported more graphically.
It also struck me that this is perhaps the one down side to Trove, though I absolutely love it in all other respects. By not sitting in a library and turning page after page on a microfilm, we lose the broader sense of what was happening in that place and at that time. We also lose a sense of perspective on how that particular editor and newspaper handled their news stories, what they focused on, and their general credibility. You also lose the sense of how they structured their paper, and where particular news features are placed. Sure, we could browse any edition on Trove, but do we really do that?
So here's my abbreviated misery list from one mere month in a country newspaper:
- A Rockhampton woman jumped off a bridge into a river clutching her 14 month old baby to her chest. The baby's body was recovered, the mother's had not been. What tragedies lay behind this story?
- A child's arm was caught in a milking machine
- A railway shunter was severely injured in an shunting accident (one of the most dangerous occupations, believe it or not)
- A Javanese child stowed away on a plane and was found alive and wrapped around the landing gear when it landed in Darwin –he lived
- A literally feral 7 year old child was found by the Salvation Army (place unidentified). He had been rejected by his parents because he was believed to have been swapped at birth. He had lived in their shed in the back yard with no clothes, toys or training and minimal human contact. He was responding well to the Salvos treatment. One family history you would not want to find.
- A "Negro" woman had been enslaved by her employer, a "society woman" for 30 years: "reparation" for having a child to the employer's husband. The court ordered payment of 30 years wages and a jail sentence which was revoked because the employer had otherwise been a very Christian woman
- Inter-racial, inter-religious massacres in India
And one for the Darwinites: Darwin had no dentist and a man had to fly to Adelaide for treatment. And yes, we do have dentists now but the need/desire to fly interstate for some significant medical treatment still exists.
And a "good news" item: the wonder drug Streptomycin was to be mass produced.
Most of these stories were found easily on Trove and are reported in newspapers around Australia, demonstrating that you may find the stories you want well beyond the confines of the local newspaper.
So there we have it, what sad and tragic family stories lie behind each and every one of these news items.


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Skipping 'Controversial Stings' of the Left
The Washington Post reported something surprising on April 29 – a hidden-camera expose by pro-life advocates. On the front page of the Metro section, they reported how a veteran D.C. abortion doctor named Cesare Santangelo told a 24-week pregnant woman that in the unlikely event that an abortion resulted in a live birth, "we would not help it."
"[T]echnically, you know, legally, we would be obligated to help it, you know, to survive, but it probably wouldn't," he said in a way to reassure the woman who was working for the undercover group Live Action.
The legal technicality is the Born-Alive Infants Protection Act of 2002, to insure that that any baby "mistakenly" born during an abortion has all the rights of any other living, breathing human. When it passed and was signed by President Bush, the networks also completely censored that.
It tells you something about the precarious nature of America's soul that such a law even needs to exist.
Live Action also released an expose of another abortion clinic, Dr. Emily's Women's Health Center in the Bronx. The Live Action mother in that video asked what happens if a child is accidentally born during an attempt at a late-term abortion. An unnamed staffer advised on the video to "flush" the baby down the toilet if he or she was delivered at home before the final stage of the two- or three-day abortion procedure. "If it comes out, then it comes out. Flush it...if anything, you know, put it in a bag or something or somewhere and bring it to us."
When Live Action's undercover investigator asked what the clinic would do if, after the abortion, the baby was moving, the counselor responded: "If it did come out in one piece, it's very small. So they would still have to put it in a container -- like, a jar -- with solution and send it to the lab." But if the baby is breathing or twitching? "The solution will make it stop. It's not going to be moving around in the jar. That's the whole purpose of the solution."
All on tape. This callous murder plot sounds all too familiar to those following the just-concluded trial of Dr. Kermit Gosnell in Philadelphia. It is the culture of death on display, pure evil.
The networks adore hidden-camera stories when the targets are conservative. Last September they gave 88 minutes to Mother Jones reporting Mitt Romney was secretly recorded dismissing the "47 percent" that would never vote for him, which probably cost him the election.
When Mother Jones recently leaked video of Senate Majority Leader Mitch McConnell's team talking about the vulnerabilities of actress Ashley Judd as a Democratic opponent, ABC and NBC reported it in the evening and then again the next morning, with CBS just catching up in the morning. ABC's Jim Avila said the Republican leader's "private and politically embarrassing strategy session" showed a "cutthroat attack on a Hollywood opponent."
Undercover videos by conservatives – those don't deserve the light of day. When Live Action exposed Planned Parenthood clinics in New Jersey and Virginia in 2011, with its clinic staff advising a "pimp" on how to evade the law with underage prostitutes, these three networks simply pretended the tapes didn't exist. When James O'Keefe and his activists exposed the leftist pro-Obama group ACORN with hidden cameras in 2009, the networks waited for days to touch it and then aired just one solitary story (ABC, CBS) or three (NBC) once Congress moved to defund them. But Mother Jones is somehow a non-ideological outfit of journalistic integrity.
The Washington Post explained "Live Action was founded by Rose, a former associate of conservative activist James O'Keefe, whose controversial stings contributed to the demise of the liberal group ACORN." But on April 11, the Post wrote a story celebrating how David Corn at Mother Jones, the "liberal-leaning magazine" was striking "audio gold." They didn't talk about "controversial stings." The Post rounded up other liberal journalists to laud Corn as "passionate, innovative and always at the edge."
The Post also felt it necessary to reflect on the controversial nature of these (conservative) videos. Dr. Santangelo was very upset about how he was "tripped up" by a "hypothetical at a moment when he was trying to reassure a client." He said he has not watched the video because "I don't like to feed into these people. I really consider them terrorists."
The Gosnell murder trial is now in the hands of the jurors. While they ponder, let us ponder:
CNN: Some coverage, not much.
Fox News: Some coverage, not much.
CBS: Two segments, and a couple of tiny updates.
NBC. One question to Obama.
ABC: Nothing.
The Live Action videos? Crickets on ABC, CBS, and NBC.


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SEATTLE >> Seahawks fans rocked the stadium so hard during Monday night's matchup with New Orleans that seismic instruments registered small tremors at various points in the game.
A magnitude 1 or 2 quake was recorded during Michael Bennett's 22-yard fumble return for a touchdown in the first quarter. The game, a 34-7 victory that clinched a playoff berth for the Seahawks, registered on nearby seismic instruments several other times.
John Vidale, director of the Pacific Northwest Seismic Network, said fans get the oval stadium moving back and forth by stomping their feet and jumping up and down. "It's sort of what you see when a car rocks back and forth," said Vidale, also a University of Washington earth and space sciences professor.
Vidale said a small quake wasn't all that surprising in the stadium, which is built on pilings dug through soft ground in earthquake country.
Structural engineers who plan buildings in Seattle often do so with room for movement, so when a natural earthquake happens the buildings aren't so stiff that they crack and crumble.
Vidale watched the game from his office to compare seismic reports with game action because he wondered if there would be a repeat of the 2011 "Beast Quake," when Marshawn Lynch ran for a 67-yard, fourth quarter touchdown as Seattle upset the Saints to advance to the second round of the playoffs.
After the 2011 quake, Vidale looked at the whole season and found that that one Lynch run shook the stadium more than any other moment during that season.
He said it's possible quakes occur in stadiums in other cities, but he suspects Seattle's stadium is more flexible than most and may flow with the fans more.
"People unconsciously get the stadium moving, sort of like the wave," he said.
Seattle structural engineer John Hooper said similar quakes can happen anywhere a large number of people are moving in unison, but the difference in Seattle is that there were instruments nearby to record the quake and people were paying attention.
The same thing could happen next weekend in San Francisco, when the Seahawks play the NFC West-rival 49ers, said Hooper, director of earthquake engineering at Magnusson Klemencic Associates.
But he also acknowledged Seahawks fans are unique.
"They're very enthusiastic and it shows," Hooper said.
Seattle fans also made record noise Monday, setting the Guinness World Record for loudest outdoor sports stadium noise at 137.6 decibels.
Seismic reading from Monday's game: http://pnsn.org/seismogram/current/kdk


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To be Set Free from Addiction, You Must Have a Humble Heart!
Therefore He says: "God resists the proud, but gives grace to the humble."James 4:6b
In order to receive the grace of God in your life, you must first prepare the soil of your heart. Those who are proud are self-seeking, arrogant and have a hardened heart. Jesus often illustrated moral principles for us to apply in our daily living, as well as gave us spiritual insights into His Kingdom, through parables. The Lord Jesus told a parable concerning the conditions of the heart which will prevent or bear fruit in a person's life. An understanding of the natural elements used in His teachings and what they symbolize will give us greater insight, so that we not only hear the voice of God, but understand what He is saying to us.
Again Jesus began to teach by the lake. The crowd that gathered around him was so large that he got into a boat and sat in it out on the lake, while all the people were along the shore at the water's edge. He taught them many things by parables, and in his teaching said: "Listen! A farmer went out to sow his seed. As he was scattering the seed, some fell along the path, and the birds came and ate it up. Some fell on rocky places, where it did not have much soil. It sprang up quickly, because the soil was shallow. But when the sun came up, the plants were scorched, and they withered because they had no root. Other seed fell among thorns, which grew up and choked the plants, so that they did not bear grain. Still other seed fell on good soil. It came up, grew and produced a crop, multiplying thirty, sixty, or even a hundred times."
Then Jesus said, "He who has ears to hear, let him hear." Mark 4:1-9
Everyone in the crowd had ears, but unless they had spiritual insight into what Jesus said, they were unable to comprehend His parables. Many heard the voice of God the Son that day, but they were unable to receive the truth He spoke. Unless a person understands the symbolic meaning of the natural elements used in the parable, it remains a mystery.
When he was alone, the Twelve and the others around him asked him about the parables. He told them, "The secret of the kingdom of God has been given to you. But to those on the outside everything is said in parables so that, "'they may be ever seeing but never perceiving, and ever hearing but never understanding; otherwise they might turn and be forgiven!'" Mark 4:10-11
Except for the followers of Jesus, the Jews had committed blasphemy of the Spirit. They attributed the glorious working of Jesus' miracles by the Holy Spirit – to the power of Beelzebub. Therefore, Jesus began to speak in parables in public so that the secrets of the Kingdom were hidden to the masses.
Once in private and away from the crowd, it says in verse 13:
… Jesus said to them, "Don't you understand this parable? How then will you understand any parable?"
The reason that understanding the parable of the sower is primary is that it emphasizes the key to unlock the understanding of the other parables. The key is that elements related to the natural world such as soil, seed, thorns and fruitful crops are symbolic with spiritual applications. There is a natural as well as a spiritual application in God's Word.
The farmer sows the word. Some people are like seed along the path, where the word is sown. As soon as they hear it, Satan comes and takes away the word that was sown in them. Others, like seed sown on rocky places, hear the word and at once receive it with joy. But since they have no root, they last only a short time. When trouble or persecution comes because of the word, they quickly fall away. Still others, like seed sown among thorns, hear the word; but the worries of this life, the deceitfulness of wealth and the desires for other things come in and choke the word, making it unfruitful. Others, like seed sown on good soil, hear the word, accept it, and produce a crop—thirty, sixty or even a hundred times what was sown." Mark 4:14-20
Seed must be planted in good soil means that the Word of God can only take root, grow and bear fruit in a softened heart and compliant heart. The hardness of the soil of the heart must be broken by humbling oneself, repenting of sins and forgiving others. The stones of bitterness and selfishness need to be removed. The heart must be watered by the Word of God and softened by the oil of the Spirit. When properly prepared and received, the word of God will bear much fruit.
There are two types of fruit. The first is the fruit of the Spirit found in Galatians 5:22-23:
But the fruit of the Spirit is love, joy, peace, patience, kindness, goodness, faithfulness, gentleness and self-control. Against such things there is no law.
The fruit of the Spirit is the character of Christ being developed in the believer so that the person is conformed to His image. The second type of fruit – is bearing fruit after its own kind by leading others to Christ. Fruit contains seed. When a single seed falls to the ground which is prepared to receive the seed and it is watered, it grows into a plant. When the plant matures, it bears fruit that contains many more seeds. Therefore developing a godly character that producers a good witness will bless both the messenger and bring conviction to many of those hearing the message of the gospel.
If you are abusing alcohol or other drugs and want to lead a victorious life and be set free from addiction you need to have a relationship with the LORD God, Creator of the heavens and the earth. To find forgiveness and freedom, pray the following prayer or a similar prayer in your own words –
"Lord Jesus Christ,
I know that I am a sinner and there is nothing that I can do to earn my way to heaven. Although I deserve God's wrath, by God's mercy, I accept your free gift of eternal life by faith. I believe that You were born of a virgin and died on the cross to pay the price of my sins. I believe you were buried, rose again on the third day, have ascended into heaven, and will soon come again.
Lord, please forgive me of my sins, come into my heart and take control of my life." AMEN
If you sincerely prayed this prayer, then you have just made a decision by faith, to accept the free gift (God's grace) of the substitutionary sacrifice of the Messiah (the Christ), whose suffering and death paid the price of your sins. You have been born again. As a new born, you need to be nourished.
Peter replied, "Repent and be baptized, every one of you, in the name of Jesus Christ for the forgiveness of your sins. And you will receive the gift of the Holy Spirit. Acts 2:38
In order to grow and mature spiritually you need to:
•Be baptized into Messiah Yeshua (Jesus Christ)
•Speak to God each day through prayer. (Pray each day in the name of Yeshua/Jesus).
•Read your Bible every day. When you read the Bible, God speaks to you through His Word. (If you don't own a Bible, then we will help you get one.)
•Find a Bible believing church and attend regularly – both worship services and a Bible study.
•Share with someone what God has done for you.
We have a variety of resources for you on our website such as:
Biblical Insights into Combating Addiction, Teachings on Prayer and Fasting, links to Christian resources for the addicted: Find Help, Healing Scriptures and information on our Annual Weekend of Prayer event.
Posted on August 31, 2012, in Biblical Insights into Combating Addiction and tagged addiction, christ, Fruit of the Holy Spirit, Fruit of the Spirit, God, Holy spirit, JESUS, Parable. Bookmark the permalink. 4 Comments.
Making yourself strong mentally is the first step to get rid from the addiction and this is one of the hard levels in the direction to stop use of drugs more than necessary.


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Immigrant children continue to surge into South Texas
MISSION, Texas – A group of around 250 immigrants, mostly children, trotted across the U.S. border near the Anzalduas International Bridge here earlier this month and climbed atop a river levee.
Then, instead of sneaking around Border Patrol checkpoints or cramming into vans for safe houses farther north, the group did something peculiar for those crossing illegally into the USA: They squatted on the levee and awaited their arrest.
The group was part of the recent surge of unaccompanied minors who are streaming into this hot, flat stretch of South Texas, overwhelming Border Patrol facilities and sparking heated debate in Washington over what's causing the crisis and how to handle it.
One key difference the recent arrivals are displaying from their predecessors: They're not bothering to sneak deeper into Texas, opting instead to turn themselves in and allow U.S. policy toward immigrant youth decide their fate, said Chris Cabrera, a McAllen-based Border Patrol agent and vice president of the local chapter of the National Border Patrol Council.
"We're seeing record numbers of children coming across," he said. "We're dealing with so many of them turning themselves in that it makes it hard for our agents to focus on anything else."
The number of immigrant children served by the Office of Refugee Resettlement, which is responsible for the youth, has soared from around 7,000 to 8,000 a year earlier this decade to 13,625 in fiscal year 2012 and 24,668 last fiscal year, according to the office. So far this year, the agency has counted more than 42,000.
The children are crossing over from Mexico but are predominantly from Central American countries, such as Honduras, El Salvador and Guatemala. On Friday, Vice President Joe Biden is expected to meet with Guatemalan President Otto Perez Molina, along with Salvadoran and Honduran officials, in Guatemala to discuss the crisis.
Administration officials have said violence and economic hardship in those countries are prompting the children to seek a better life in the USA. Some lawmakers, however, argue the youths – and the smuggling rings bringing them in – are exploiting U.S. policy, which allows youngsters from Central American countries other than Mexico to be released to an adult living in the USA while awaiting their court hearing. Mexican youth are returned to an agency in that country.
Meanwhile, they continue to arrive, filling up facilities faster than officials can open them. In South Texas, where the bulk of the surge is coming through, more than 1,600 youths have filled up 13 shelters, said Kimi Jackson, of the South Texas Pro Bono Asylum Representation Project, one of the few agencies that has met with the detained children. Federal officials have also opened temporary facilities at Lackland Air Force Base in San Antonio, in Ventura, Calif., and in Fort Sill, Okla., to deal with the overflow.
The children at the South Texas facilities, overseen by ORR, live in dormitory-style bunkers, receive school instruction and legal reviews, and get to play outside, Jackson said. More worrisome are those still stuck in Border Patrol holding facilities, which are not set up to house children, she said. "The shelters are all full right now," Jackson said. "There's definitely crowding happening."
Overwhelmingly, the children cite growing gang violence in their home countries as a main motivator for making the treacherous trek to the USA, she said. The children are being reunited with their U.S. caregivers after an average stay of around 33 days at the shelters – less than half the time it was three years ago, she said.
Still, some aren't released fast enough. Linda Brandmiller, a San Antonio immigration attorney who represents unaccompanied minors, said she routinely has to battle with the shelters and ORR to release undocumented children who have proven they're fleeing hardship and have a parent in the USA waiting to take them home.
In March, Brandmiller learned of an 11-year-old Honduran girl who came to the USA through Mexico to try to reunite with her father, who was living in Alabama. It took her 2½ months to have the girl released to her father, she said.
"This is insanely expensive," she said. "Everything is costing we, the taxpayer, an unnecessary amount of money when these children have places to go."
But that policy of allowing the children to reunite with adults in the USA could be fueling the influx, said Cabrera, the border agent. The unaccompanied children often arrive with a slip of paper in their pocket with the information from their home country and the name and number of their contact in the USA. Once across the border, they're instructed to turn themselves in and play the system, he said.
"It's a loophole they've found in the system," Cabrera said. "And, frankly, they're exploiting it well."


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Today's News: Our Take - Marvin Gaye's Family Turned Down Six-Figure Settlement Offer From Robin Thicke
Singer Robin Thicke reportedly offered Marvin Gaye's family a six-figure settlement sum to avoid taking their copyright dispute to court, but Gaye's family rejected the money, Billboard reports.
Gaye's family is accusing Thicke of plagiarizing Gaye's "Got to Give it Up" for his hit "Blurred Lines," and Bridgeport Music, Inc. is similarly accusing the singer of copying George Clinton's "Sexy Ways." Earlier this month, Thicke and his co-writers,Pharrell Williams and Clifford Harris, Jr., filed suit in Los Angeles asking a judge to rule that "Blurred Lines" doesn't lift from either Gaye's or Clinton's songs. (Clinton has said that he supports Thicke in the dispute.)
Fall TV Preview: Where we left off with returning shows
Thicke has said that "Blurred Lines" was inspired by Gaye's song, according to Billboard, but the Gaye family feels differently.
"We're not happy with the way that he went about doing business, let alone suing us for something where he clearly got his inspiration from at the least," Gaye's son, Marvin Gaye III, told TMZ.
Gaye died in 1984.
View original Marvin Gaye's Family Turned Down Six-Figure Settlement Offer From Robin Thicke at TVGuide.com
Other Links From TVGuide.com


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Were it not for his innate understanding of suburban agony, which totally eclipses such obvious fare as American Beauty, Solondz would be swiftly dismissed, but the Newark, New Jersey, native knows how to claim his swatch of territory and render it engrossing, often with the emphasis on gross. His knack for concocting disturbing characters smacks of Stephen King back when the horror meister was worth reading, yet Solondz doesn't require the supernatural to drench us with nastiness. Like Neil LaBute (Your Friends & Neighbors) and Larry Clark (Kids), the writer-director is desperate to point out that something is very wrong here in the real world. Fortunately, he also appraises his suburban condition with jaw-dropping edginess and an uncanny ability to wrench stunning performances from his casts.
Storytelling is sort of Solondz's third feature (if one mercifully omits his 1989 debut, Fear, Anxiety & Depression), and in many ways it is his strongest effort to date. As with 1996's Welcome to the Dollhouse (actual working title: Faggots and Retards), he proves himself an expert in the mode of John Hughes gone to hell, and after the projection of adolescent angst that dumbed down the adults of the otherwise impressive Happiness, he seems comfortable here focusing mostly from the point of view of freaked-out kids. (He's also amplified the hipster factor with the music of Belle and Sebastian, plus the presence of Franka Potente, Conan O'Brien and Mike Schank of American Movie.) There's nothing terribly new or surprising on tap -- Ghost World already covered this miasma of moping, and the documentary Chain Camera provides a strong taste of the real thing -- but Solondz is a master of backing you into a queasy corner and tickling you until you puke, a dubious but noteworthy talent.
To achieve his goal this time, Solondz breaks Storytelling into two chapters: "Fiction" and "Non-Fiction." (A third was reportedly excised -- "Autobiography," perhaps? -- lending the film its zippy 83-minute length.) The first segment is a period piece set in a third-rate community college in 1985, where a Pulitzer Prize-winning African-American novelist named Mr. Scott (Robert Wisdom) holds court over a class of wildly opinionated creative-writing students. The crux is that the punky blond Vi (Selma Blair) has grown weary of the drab sex and painfully mawkish prose of her cerebral-palsied boyfriend, Marcus (Leo Fitzpatrick), and so approaches her brooding professor for an "exotic" tryst. Naturally for Solondz, incredible unpleasantness ensues (some of it ridiculously censored), and we're invited to flinch or guffaw as we please.
"Non-Fiction," if less successful overall, is much more ambitious, echoing the domestic madness of Dollhouse but channeling its confusion through the present-day torpor of a teenage dullard named Scooby (Mark Webber). After a rest-room encounter with a pathetic documentarian and shoe salesman named Toby (Paul Giamatti), Scooby -- whose only ambition is to become a famous talk-show host -- volunteers himself and his extremely unhappy family (John Goodman, Julie Hagerty, Noah Fleiss, Jonathan Osser) to be the subjects of Toby's meandering exposé on . . . something or other. Again, unpleasantness ensues, but not before we catch countless darkly satiric details, such as the Machiavellian youngest son, Mikey (Osser), grilling the Latina housekeeper, Consuelo (Lupe Ontiveros), with "innocent" questions such as, "Even though you're poor, don't you have any hobbies or interests?" Things get even uglier when Scooby informs his parents that, if it weren't for Hitler, they'd never have met each other in America and their children would never have been born. My Three Sons this is not.
Solondz clearly wants to up the ante of his previous films, with the kidnapping of Dollhouse leading to the pederasty, rape and murder of Happiness to more rape and murder in Storytelling (plus there's a creepy scene of sexual submission best described as the worst commercial for iMacs ever conceived). What's finally clear, however, is that his characters -- the clichéd blonde, the moronic slacker, the pompous patriarch -- are all asking for it. Despite the slight irony of the "Fiction" and "Non-Fiction" titles, Solondz isn't working with irony at all. His singular game plan is to dangle profoundly obnoxious caricatures before us, then punish them mercilessly for their stupidity, which is amusing enough if you're in the mood for that sort of thing.


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I was at a Financing workshop this morning at the Bronzeville Visitors Bureau for what is affectionately called simply "The Rosenwald." Organized by National Trust Advisor Paula Robinson and Harold Lucas, who have been involved in South Side community preservation for a generation, the effort was the latest in an ongoing series of attempts to save a truly important building. As Harold pointed out at the outset, the building – which covers most of the block between 46th and 47th Streets, Michigan to Wabash, was significant in both the history of Bronzeville as the home of famous individuals like Quincy Jones and Joe Louis, and in the history of Chicago's greatest philanthropist, Sears, Roebuck Chairman Julius Rosenwald. Rosenwald is known nationwide for his early 20th century empowerment efforts, building schools for African-Americans across the south. The Rosenwald was one of two predecessors to public housing in Chicago, the other being the Marshall Field Garden Apartments on the north side. Officially called Michigan Terrace Garden Apartments, Rosenwald had his nephew Ernest Grunsfeld, Jr. design the 5-story Art Deco complex for Bronzeville in 1929. It was listed on the National Register in 1981.
The building has drawn the attention of preservationists for a while. The National Trust put it on their 11 Most Endangered List three years after it closed in 2000. Landmarks Illinois and Preservation Chicago have put it on their most endangered lists as well. Architect Phil Kupritz presented the redevelopment plan, which will add corridors and elevators, create 300 units instead of 440, and bring the building into the modern market.
The market is on its way already. If you haven't been to the Near South Side lately – say 26th to 47th Street – it's too late – that train left the station. The new housing at 35th and State where the Robert Taylor homes used to be has shot up in the last few months, and new greystones line every street from the lakefront to Michigan. Bronzeville has been one of the hottest markets for new single-family homes for the last decade. As one developer at the meeting said: it is only a matter of time before the Rosenwald is redeveloped. This thing is solid – concrete, not the knotty sticks they are using to build the new houses.
The scale of the building – almost a full block, well over 400,000 square feet, combined with the lack of elevators and fire exits to scare off developers a few years ago, but they are running out of excuses. A TIF district and a raft of tax credits – historic, low-income, New Market, make the deal better, and a preservation easement could add more. If it goes condo, the Illinois Property Tax Freeze could offer an extremely enticing incentive for new homeowners.
It's not out of the woods yet, but I suspect the real challenge will be keeping the community – ably represented by Paula and Harold and Rosenwald preservationist Bobbie Johnson – in the deal. Harold has a nice sense of history – he talked about the proposed National Heritage Area for the section of the South Side where blacks were forced to live by racial covenants before 1948. This heritage area is a worthwhile goal, and like most historic projects, it will recall a time and place that is, in ways both good and bad, long gone.
Save The Rosenwald!


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This article discusses major changes and developments that directly affect S corporations and their tax advisers during the period of this update (July 10, 2012–July 9, 2013). It also presents tax planning ideas for S corporations and their shareholders concerning several provisions, including the 3.8% net investment income tax.
Sec. 1374(d)(7) BIG Tax Holiday
The Sec. 1374 built-in gain (BIG) rules were significantly and favorably liberalized by the American Taxpayer Relief Act of 2012 (ATRA). 1 ATRA also added certainty to several lingering issues. For tax years beginning in 2012 or 2013, if the prior year was the fifth calendar year or later in the recognition period, then any recognized gain is not subject to the BIG tax (the BIG tax holiday). Note that this rule requires five 12-month periods and not necessarily five tax years; the latter often are a shorter period. The built-in gains period will be 10 years for years after 2013. The new law clarified two important issues concerning the BIG tax holiday: First, it allows gain from an installment sale of qualified property to be exempt from Sec. 1374 tax, even if it is recognized in a year after 2013 in which the BIG tax applies. Second, a technical amendment to Sec. 1374(d)(2) provides that the rule requiring the excess of net recognized built-in gain over taxable income for a tax year to be carried over and treated as recognized built-in gain in the succeeding tax year applies only to gain recognized within the recognition period. For example, built-in gain recognized in a tax year beginning in 2013, from a disposition in that year that occurs beyond the end of the temporary five-year recognition period, will not be carried forward under the income limitation rule and treated as recognized built-in gain in the tax year beginning in 2014 (after the recognition period is again 10 years).
Example 1 : In January 2007, a calendar-year C corporation switches to S status. In 2013, it is qualified for the BIG tax holiday, since six calendar years have elapsed in the recognition period. It sells a BIG asset on the installment basis in 2013, with gain recognized in 2015, a nonexempt year. The recognized gain in 2015 will not be subject to Sec. 1374.
Example 2: In January 2007, a calendar-year C corporation switches to S status. In 2013, it is qualified for the BIG tax holiday. In 2013 it has recognized BIG of $200,000 and taxable income of $140,000. Normally, the $60,000 difference would be subject to BIG tax in 2014, but the technical amendment to Sec. 1374(d)(2) exempts the $60,000 carryover from Sec. 1374 tax in 2014.
Chief Counsel Advice (CCA) 201324013 2 opines against an attempt to use the partnership and S corporation rules to circumvent Sec. 1374 BIG tax. Essentially, one party contributed money (and received property), and the other party contributed property and received the cash funds. It is widely speculated that the ruling involved the Tribune Co., which publishes the Chicago Tribune newspaper, divesting itself of the Long Island Newsday newspaper similarly to how it divested itself of the Chicago Cubs a few years earlier. The IRS ruled that Sec. 707(a)(2)(B) and Regs. Sec. 1.752-2(j) should be applied to treat the transaction as a disguised sale, and hence the Sec. 1374 rules would apply to the taxpayer.
S Corporation Data
The 2012 Data Book 3 reports that the number of S corporation tax returns filed increased 0.8% in 2012 over 2011; partnerships and LLCs increased by 1.5%; and C corporations decreased by 2.2%. S corporations and partnerships were audited 0.5% of the time, while small business C corporations were audited at a rate of between 0.9% and 2.6%, depending on their asset size. Interestingly, individual returns with nonfarm business income (and without an earned income tax credit) were audited between 1.2% and 3.6% of the time, depending on gross receipts reported.
Qualifying as an S Corporation
To qualify as an S corporation, a corporation must meet requirements concerning its type, number and type of shareholders, type of stock, and type of income. In addition, the corporation must elect to be treated as an S corporation. If applicable, it may also elect to treat a subsidiary as a qualified subchapter S subsidiary (QSub), and certain trusts may elect to be treated as eligible shareholders. If any of the requirements are not met at any time, the corporation's S election is terminated. However, the taxpayer can request an inadvertent termination relief ruling under Sec. 1362(f) and, subject to IRS approval, retain its S status continuously. Congress asked the IRS to be lenient in granting inadvertent election and termination relief, and it is clear from numerous letter rulings that the IRS has abided by congressional intent.
In all of the recent letter rulings on failures to make a timely election by, or related to, an S corporation, if the taxpayer could establish reasonable cause and show that granting the relief would not prejudice government interests, the taxpayer was granted inadvertent termination relief, as long as a proper election was filed within 120 days of the ruling. These rulings applied to the failure to file Form 2553, Election by a Small Business Corporation ; Form 8832, Entity Classification Election ; and Form 8869, Qualified Subchapter S Subsidiary Election ; 4 as well as the elections required by the beneficiary of a qualified subchapter S trust (QSST) and the trustee of an electing small business trust (ESBT) to be an eligible S corporation shareholder. Nontimely filing was deemed inadvertent in a number of rulings. 5 The IRS also granted inadvertent termination relief involving trusts that were intended to be ESBT trusts but whose trustees failed to make the election. 6
Likewise, in at least two letter rulings, 7 a shareholder transferred S stock to a grantor trust. When the shareholder died, the irrevocable trust was a qualified shareholder for two years. After that, the stock was transferred to a QSST, but the beneficiary failed to sign the election. The IRS allowed the S status to continue under Sec. 1362(f) without a termination. The IRS also forgave the termination of a corporation's S status due to a trust's failure to satisfy the QSST requirements. 8 Unlike baseball, in an example of three strikes and you are not out, two letter rulings 9 involved an S corporation that filed Form 2553 with the wrong date and a wrong signature on behalf of one of its two shareholders and failed to properly file an ESBT election, and yet it was permitted to be an S corporation from inception.
Eligible Shareholders
Sec. 1361(b) restricts ownership in an S corporation to U.S. citizens and resident individuals, estates, certain trusts, certain pension plans (but not individual retirement accounts (IRAs)), and certain tax-exempt charitable organizations.
Historically, S corporations have been more successful if they are proactive and request inadvertent termination relief from the IRS before they are audited and the issue is decided in court. The IRS issued inadvertent termination relief to S corporations that had various ineligible shareholders. Letter Rulings 201245001 and 201245002 10 involved shareholders that were partnerships. In other rulings, 11 the IRS did not make it clear why the shareholder was ineligible, but it allowed continued S status. In Letter Ruling 201325003, 12 an LLC elected to be treated as an S corporation. At one point, an ineligible shareholder had ownership, but the error was corrected when recognized. The IRS allowed continuous S status, but the eligible shareholders had to include the ineligible person's income on their tax returns.
One Class of Stock
Sec. 1361(b)(1)(D) prohibits an S corporation from having more than one class of stock, defined as equal rights to distributions and liquidations (but not necessarily equal voting rights). Regs. Sec. 1.1361-1(l) provides that a corporation generally is treated as having only one class of stock if all outstanding shares of stock of the corporation confer identical rights to distribution and liquidation proceeds. Whether all outstanding shares of stock confer identical rights to distribution and liquidation proceeds is determined based on the corporate charter, articles of incorporation, bylaws, applicable state law, and binding agreements relating to distribution and liquidation proceeds (collectively, the governing provisions). However, any distributions (including actual, constructive, or deemed distributions) that differ in timing or amount are given appropriate tax effect in accordance with the facts and circumstances.
In Santa Clara Valley Housing Group , 13 a family used a marketed tax shelter called the S Corporation Charitable Contribution Strategy to transfer millions of dollars in income from an S corporation the family owned to a Los Angeles public employees' pension plan for tax purposes but to keep control of the S corporation and receive virtually all the distributions of the income. The family used stock warrants to maintain control. The key issue was whether the warrants were a second class of stock and, therefore, invalidated the corporation's S status and caused the distributions to be subject to tax under Sec. 301. A district court in California originally decided that the stock warrants were a second class of stock but agreed to reconsider their terms under the safe-harbor rules of Regs. Sec. 1.1361-1(l)(4). In August 2012, the court denied the corporation's motion to bifurcate the tax and penalty phases of the trial.
In Letter Ruling 201309003, 14 the taxpayer originally had a typical buy-sell agreement based on fair market or book value purchase price that would not cause a violation of the one-class-of-stock requirement. However, the taxpayer had amended the agreement in relation to a third-party claim and created a bonus plan related to any future recovery the taxpayer might receive from the claim. In Letter Ruling 201308008, 15 the taxpayer asked the IRS to rule on the effect of its redemption agreement. In both cases, the IRS ruled that the agreements did not create a second class of stock.
In Letter Ruling 201306004, 16 the shareholders of the taxpayer entered into an agreement that allowed varying income distributions to be made to the shareholders. A governing provision does not alter the rights to liquidation and distribution proceeds merely because it provides that, as a result of a change in stock ownership, an S corporation makes distributions in a tax year on the basis of the shareholders' varying interests in the S corporation's income in the current or immediately preceding tax year. In this case, the IRS ruled that the agreement to make varying interest distributions did not create a second class of stock.
Letter Ruling 201326012 17 involved a corporation that issued convertible debenture notes to employees at zero interest and to the employees' IRAs at a market interest rate. Under Regs. Sec. 1.1361-1(l)(4), debt can be treated as equity for purposes of the second-class-of-stock rule. In this case, the IRS ruled that the issuance of debentures did not create a second class of stock.
Letter Ruling 201246008 18 presents a plethora of issues related to potentially creating a second class of stock, including computational errors and improperly characterizing a loan as a distribution. The IRS held that two of the taxpayer's actions might have created a second class of stock that caused an S status termination, but if they did, the termination was inadvertent.
A common way that a second class of stock is created is through disproportionate distributions to shareholders. In Letter Ruling 201234001, 19 an S corporation made disproportionate distributions. The IRS ruled that the disproportionate distributions would not be treated as a second class of stock if the taxpayer made corrective distributions within 120 days. Letter Ruling 201322036 20 involved an S corporation that made disproportionate distributions to various shareholders related to paying state and local taxes and corrective distributions at different times. The IRS concluded that because the taxpayer's stock had identical distribution and liquidation rights under its governing provisions, the difference in timing between the disproportionate distributions and the corrective distributions did not cause the taxpayer to have more than one class of stock.
Earnings and Profits
An S corporation that has subchapter C accumulated earnings and profits (E&P) may be subject to a tax under Sec. 1375 on its excess net passive investment income if its total passive investment income exceeds 25% of its gross receipts. In addition, if these conditions persist for three consecutive years, its S election automatically terminates the first day of the fourth year. In IRS Letter Rulings 201248001 21 and 201320008, 22 the S corporations met these criteria, and therefore their S elections were technically terminated. The IRS allowed the shareholders to make an election under Regs. Sec. 1.1368-1(f)(3) to make a deemed distribution of accumulated E&P so that the corporations no longer violated the rules of Sec. 1362(d)(3) and thus could continue their S status uninterrupted. The government did require the payment of Sec. 1375 tax and amended returns by the shareholders to reflect the dividend. In Letter Ruling 201232023, 23 the IRS found that rental income that involved significant services was active income, and therefore the S corporation election was not terminated under Sec. 1362(d)(3). This was despite a former accountant's filing a statement with the corporation's tax return revoking the S election, because it was not properly prepared or signed by shareholders.
Final Regulations on Controlled Corporations
Final regulations 24 were issued effective for tax years beginning on or after April 11, 2011, that distinguish a controlled group under Sec. 1563 from affiliated group rules of Sec. 1561. In general, for purposes of Sec. 179, all component members of a controlled group are treated as a single taxpayer. Many practitioners believed that because S corporations were defined as "excluded corporations," and thus were not component members of a controlled group, two S corporations that were members of a controlled group could each take a maximum Sec. 179 deduction and pass it through to their shareholders. There was concern that these new regulations would have an impact on this position. An IRS Information Letter released June 28, 2013, 25 confirmed that the regulations were not meant to limit the Sec. 179 deduction and that each S corporation would in fact be entitled to its own $500,000/$2 million limitation .
Wages and Self-Employment Taxes
Tax advisers should be aware of a National Research Program (NRP) for 2010–2012 (2,000 returns per year) on employment status (employee vs. independent contractor), reasonable compensation, S corporation distributions vs. salary, and matching tax identification numbers. Fifteen hundred of the 2,000 returns per year are from the Small Business/Self-Employed Division.
The Watson case 26 represents exactly what the government is trying to ferret out with the NRP. A seasoned accountant worked 35 to 45 hours per week, 46 weeks a year, but took a salary of only $24,000. In addition, he distributed more than $200,000 in cash to himself. The taxpayer's behavior echoes a long line of cases going back to Radtke, 27 Spicer Accounting, 28 and Joseph M. Grey Public Accountant, 29 which all failed in their attempt to avoid taxes by undercompensating themselves and instead taking money out of the entity through distributions. The court reclassified $67,000 of Watson's distributions as salary. It should not be a surprise for the reader to learn that the wage limit subject to Social Security tax for the relevant year was approximately $91,000. The Eighth Circuit 30 affirmed the district court decision, and, recently, the Supreme Court denied the writ of certiorari, 31 so the Eighth Circuit decision stands.
On the good-news side, CCA 201228037 32 allows 2% shareholder-employees to take a Sec. 162(l) above-the-line deduction of all Medicare premiums paid or reimbursed by the S corporation if the premiums are reported as wages on the shareholder/employee's W-2 and are reported as gross income on his or her tax return.
In one of the stranger cases in recent history, Stephens, 33 a taxpayer incorporated his trucking business as an S corporation. Each year, the business earned around $120,000 in taxable income, and in 2008 the taxpayer paid himself $136 in wages. The government did not argue undercompensation, and the court did not allow any penalties to be assessed. The court upheld the IRS's assessments based on unreported S corporation income and unreported wages but did not uphold the penalty assessment because the IRS did not produce evidence to prove that the penalties were appropriate.
Basis, Losses, and Limitations
A major motivation for a corporation choosing S status is the ability to flow entity-level losses to its shareholders. To be able to use this benefit, shareholders must keep careful track of their stock and debt basis. As a matter of fact, in discussions with IRS personnel, the hottest area for IRS review is adjusted basis. A shareholder must overcome several hurdles before losses are deductible, including Sec. 183 (hobby loss), Sec. 1366 (adjusted basis), Sec. 465 (at-risk), and Sec. 469 (passive activity loss). Several court cases, proposed regulations, and rulings were issued relative to these loss limitation rules.
Prop. Regs. Secs. 1.1366-2 and -5 34 were promulgated on June 12, 2012, and, when finalized, may be helpful to many taxpayers that use related entities to fund loss S corporation activities. Essentially, the regulations move away from the "economic outlay"/poorer in a material sense criterion of many court cases and instead use a "bona fide debt" criterion. This may make it easier to use funds from related parties, back-to-back loans, and even in some cases the "incorporated pocketbook" concept. It may also allow "round tripper" lending where each leg of the transaction is bona fide. For example, if an individual owns both a partnership interest and an S corporation interest, and the S corporation leases property from the partnership, the shareholder/partner may be able to borrow from the partnership (or receive a distribution), lend to the S corporation on bona fide terms, and have the S corporation pay the rent. The crucial concept is: What is bona fide debt under general tax principles? The authors would argue that if the terms of the loan/note are similar to what an unrelated third party would lend at, then the loan/note is a bona fide debt.
The proposed regulations also explicitly point out that guarantees and recourse debt arrangements will not give rise to Sec. 1366 basis for loss until they are actually paid. In Montgomery , 35 an S shareholder guaranteed an entity loan and the entity failed to pay. The debt was recognized by the shareholder but not paid, so it was not available to increase basis for Sec. 1366(d) loss purposes until paid. The regulations' preamble also states that Rev. Rul. 81-187 36 still applies to limit the ability to increase basis by contributing a self-written note.
Barnes 37 involved a trap for the unwary, in which the S corporation had suspended losses due to insufficient basis. In a prior year, there had been sufficient income to absorb the suspended losses, but the shareholder did not take the losses. The statute of limitation had lapsed on those years, and currently the taxpayer wanted to take the losses. The taxpayer argued no deduction, no reduction in basis. The Tax Court and D.C. Circuit came up with their own assertion: Use your losses when they are available or lose them.
Ball 38 involved an S corporation that made a QSub election that included a Sec. 332 tax-deferred liquidation. The taxpayers argued that this event created tax-exempt income that would increase the shareholders' basis under Sec. 1366(a)(1)(A). The court ruled that this was not tax-exempt income, and therefore no upward basis adjustment was allowed.
In Powers , 39 a CPA did not have sufficient basis for a loss, as notes between a commonly controlled partnership and S corporation did not give basis, and the check deposits contributed of more than $145,000 did not reflect the more than $503,000 withdrawn during the same year. Therefore, the Tax Court held, there was no adjusted basis to absorb the entities' losses.
Cancellation-of-Debt Income
Final regulations 40 under Sec. 108(i) deal with reacquisition of debt in 2009 or 2010 and an available election to defer the gain over five years. One of the dangers of this election is that several fairly common events may accelerate the deferral into a year when the taxpayer may have profits but no cash to pay the tax on the accelerated income.
For example, switching from C to S status triggers an acceleration of deferred cancellation-of-debt income in the last C year. Also, a sale of substantially all assets or the sale or exchange or redemption of S stock accelerates this noncash income. A shareholder's death also triggers the acceleration provision. The final regulations noted that earnings and profits are increased in the year the income is realized.
Sec. 83 Compensation
Davis 41 involved an S corporation in which there was a dispute among the shareholders, and one of them, the father of the corporation's founders, exercised his restricted stock rights. The corporation deducted the $36.9 million under Sec. 83(h), but the father did not include the proceeds in gross income. The Eleventh Circuit, affirming the Tax Court decision, required the shareholder to include the amount in ordinary income because, it held, he was granted the option in connection with the performance of services, and allowed the corporation a corresponding deduction.
Trust Expenses
CCA 201327009 42 dealt with a QSST that acquired S corporation stock from a third party with a note. The issue was whether the interest on the note was deductible by the beneficiary under the grantor trust rules or should be allocated to the nongrantor portion of the trust. The government ruled that it was deductible, as it was directly traceable to the acquisition of the S stock.
Tax-Deferred Reorganizations
The flexibility engendered by the QSub disregarded-entity rules generated some merger-and-acquisition activity involving S corporations. In IRS Letter Ruling 201308017, 43 for business reasons of management stability and resolving disputes of differing business philosophies, the IRS approved an S corporation's dropping assets into a controlled corporation and doing a split-off to one shareholder and his grantor trust under the divisive D reorganization rules. Similarly, due to shareholder disagreements about the running of the business , Letter Ruling 201234009 44 allowed a divisive D reorganization, but as a condition precedent, the shareholders had to distribute accumulated E&P. Note that a recent government announcement 45 states that the ruling division of Treasury will no longer issue a letter ruling after Aug. 23, 2013, on the qualification of a transaction under Sec. 332, 351, 355, or 1036 or whether a transaction constitutes a reorganization within the meaning of Sec. 368, but will rule on significant issues.
CCA 201326014 46 involved a complex set of facts in which an S corporation owned a number of QSubs that were treated as disregarded entities for federal tax purposes. In all but two cases the subsidiaries had liabilities in excess of the basis of the assets. The S corporation formed an LLC and contributed the stock of the subsidiaries. In addition, C , an unrelated party, contributed a note to the LLC. The result of this transaction was to convert the LLC from a disregarded entity to a partnership, a regarded entity. Because the LLC was now a separate entity for tax purposes, the subsidiaries' QSub status would be terminated. However, the IRS ruled that there would be a taxable formation of new C corporations under Sec. 1001 before the termination of the QSub status, because the S corporation was not in control (as defined in Sec. 368(c)) of the C corporation "immediately after the exchange."
In a situation 47 where an S corporation did a tax-deferred spinoff, two issues arose. One was whether transitory ownership by a C corporation would end the S status, and the second was whether there was more than one class of stock. The government held that neither terminated the S election.
Letter Ruling 201232003 48 involved an S corporation that sold the stock that was to be treated under Sec. 338(h)(10) as a deemed asset purchase. One of the shareholders was a QSST, and the issue was which would include the gain on the sale in income—the trust or the beneficiary. The ruling held that the trust would, under Regs. Sec. 1.1361-1(j)(8).
Bankruptcy and Fraudulent Tax Returns
Three bankruptcy or fraud-related developments occurred in this article's time frame. CCA 201238026 49 dealt with a two-shareholder S corporation in the real estate repair and remodeling business. One shareholder billed the S corporation for subcontractor work done for him individually, thus lowering corporate taxable income. This fraudulent behavior triggered an unlimited statute of limitation under Sec. 6501(c)(1) for the S corporation and that shareholder. The CCA stated that the innocent shareholder would not have his statute of limitation extended.
In Kenrob Information Tech Solutions, 50 an S corporation had a long-standing agreement that it would pay the federal taxes of the shareholders on undistributed profits so that the corporation could retain funds for operations and expansion. The Chapter 7 bankruptcy trustee tried to claw back the funds as fraudulent conveyances, but the judge held for the S corporation and its shareholders.
In The Majestic Star Casino v. Barden Development , 51 a parent S corporation revoked its S status, thus ending a subsidiary corporation's QSub status. The subsidiary, which was in bankruptcy, went to court seeking to have the revocation of the parent's S corporation status voided. The subsidiary argued that its QSub status was property that belonged to the subsidiary, and the revocation of the parent's S corporation status resulted in an invalid post-petition transfer of property of the subsidiary's bankruptcy estate. The Third Circuit, vacating and remanding a bankruptcy court decision, held that the subsidiary's QSub status was not property, and even if it were, it would be the parent's property.
Tax Planning
American Taxpayer Relief Act of 2012
The American Taxpayer Relief Act of 2012 maintained the capital gain and dividend zero and 15% tax rates for 2012 and 2013, but, effective 2013, also created another capital gain/dividend bracket at 20% for certain levels of adjusted gross income (AGI). It also enacted a permanently inflation-adjusted alternative minimum tax exemption for 2013 on. The two-percentage-point Social Security tax reduction for employees and self-employed taxpayers for 2011 and 2012 was not continued in 2013. The law reimposed the Pease phaseout of itemized deductions and personal exemptions. For assets acquired and placed in service on or after Sept. 9, 2010, and before Jan. 1, 2012, Sec. 168(k) allowed 100% expensing for new tangible personal property. For 2012 and 2013, a 50% deduction is allowed.
This law also extended to 2012 and 2013 the $500,000 limit of new or used tangible personal property that may be expensed in the year placed in service under Sec. 179. The phaseout of this tax benefit starts at $2 million and is fully phased out for property acquired in the tax year that exceeds $2.5 million. Tax professionals should note that the taxable business income limitation still applies. If the deduction is limited due to the taxable income limitation, then a carryforward is allowed. In an expansion of the Sec. 179 provision, $250,000 of the $500,000 property acquired can apply to qualified leasehold, retail, and restaurant improvement property. This category of assets has a 15-year class life. If the income limitation applied for 2012, this category of asset carryover may be used in 2013 but, unless extended, not beyond 2013. This is a trap for the unwary.
Zero Capital Gain Rate in 2012 and 2013
Because of the extension of the zero capital gain rate for individual taxpayers in the lower two tax brackets in 2012 and 2013, taxpayers should consider gifting appreciated S corporation stock to their children, grandchildren, or parents. In 2007, the Small Business and Work Opportunity Tax Act 52 extended the "kiddie tax" to income (including capital gains and dividends) of 18-year-olds (or 19- to 23-year-olds who are full-time students 53 ) whose earned income does not exceed half of their support. Thus, the zero tax rate generally is not available to students through age 23 unless they have significant earned income. This leads to a balancing act. Parents may legitimately hire their children to work for them and pay them enough to meet the 50% self-support test but not so much that they exceed the first two bracket limits. Also, the parent will lose the dependency exemption.
Example 3: Child C, age 22, is in graduate school and has $5,000 dividend income and $2,000 ordinary income from an S corporation, plus $10,000 earned income from summer work and from helping his parents with computer work in their business. His total support is $18,000. In May 2013, C's parents give him stock worth $26,000, with a basis of $6,000 and that has met a holding period of at least one year. C has a standard deduction and personal exemption that put his 2013 taxable income in the first two tax brackets. (The taxable income bracket limit for the first two brackets in 2013 for single filing status is $36,250.) The income of C's parents places them in the highest income tax bracket.
Assuming that C sells the gifted stock in 2013, he will pay no tax (zero tax rate) on the $20,000 capital gain and the $5,000 dividend income, for a tax savings over his parents' hypothetical tax on the dividend and capital gains of $5,000 ($25,000 × 20%) as well as avoiding the 3.8% net investment income tax on the $25,000 for a further savings of $950.
Example 4: Retired couple A and B take a required minimum pension distribution of $10,000 and invest primarily in tax-exempt bonds whose interest they are living off. Their S corporation Schedule K-1, Shareholder's Share of Income, Deductions, Credits, etc., shows ordinary income of $30,000, and they receive distributions of $40,000 during the year. They have total itemized deductions of $30,000. Their net ordinary income is $10,000 (40,000 – 30,000).
The taxable income limit for the first two brackets in 2013 for a married couple filing jointly is $72,500. Therefore, if they recognized $200,000 in capital gains or dividend income through the S corporation or otherwise, $62,500 of the gain ($72,500 – $10,000 ordinary income) would be subject to a zero tax rate. The other $137,500 would be subject to the normal 15% tax rate. This results in a federal tax savings of $9,375.
IC-DISC Tax Rate Arbitrage (Qualified Dividend Rate 15%, Tax Deduction 35%)
Most practitioners are aware of the tax planning opportunity in the right situation (investment interest expense being less than net investment income) of increasing investment interest expense and investing in dividend-paying stocks to play the tax rate differential. Less well-known is using an interest charge domestic international sales corporation (IC-DISC) to achieve the same results for companies that produce products in the United States but sell them overseas. IRS statistics show a 119% increase in the number of IC-DISCs from 2005 (876 returns) to 2008 (1,917 returns), during which gross export receipts more than tripled from nearly $12 billion to nearly $37 billion. 54 Considering that there are more than 4 million S corporations, there is obviously a very small percentage taking advantage of these provisions. Essentially, the IC-DISC receives commissions based on the greater of 50% of net export income or 4% of gross revenue. Dividends to shareholders qualify for the Sec. 1(h) 15% tax rate, and the producing entity corporation gets a deduction of 35% of commissions. To sweeten the deal, the producing entity can use Sec. 199 as well.
Net Investment Income Tax
The Health Care and Education Reconciliation Act of 2010 55 imposes a net investment income tax of 3.8% of the lower of net investment income or modified AGI over a base amount for tax years beginning in 2013. The key term is net investment income and how is it defined relative to S corporations. If the S corporation has income such as interest, dividends, certain royalties and rents, and capital gains (other than those derived in the ordinary course of, or from property held in, a trade or business that is not a passive activity with respect to the shareholder or a trade or business of trading in financial instruments or commodities), it is part of net investment income. Net investment income also includes other gross income from a trade or business that is a passive activity with respect to the shareholder or a trade or business of trading in financial instruments or commodities. If the shareholder is considered not materially participating in the S corporation's trade or business activities under the rules of Sec. 469, then the income reported on line 1 of Schedule K-1 will be considered net investment income. The S shareholder should note that estimated taxes are required for this Sec. 1411 tax. If the shareholder is an ESBT, the 3.8% tax will more likely apply because the modified AGI threshold for trusts is $11,950, while for individuals it is $250,000 (married filing jointly) or $200,000 (single).
Example 5: An ESBT has no non-S portion of net investment income. Its share of net investment income consists of $10,000 of dividends, $5,000 of interest, $25,000 of rental income, and $12,000 of capital gains. Its modified AGI is $52,000, as is its net investment income. The lower of $52,000 or $40,050 ($52,000 – $11,950) is $40,050, which multiplied by 3.8% equals a Sec. 1411 tax of $1,522 on the ESBT. If it were an individual, a threshold of $200,000 or more would have been available.
In addition, a hospital insurance tax 56 beginning in 2013 imposes a 0.9% tax on wages and self-employment income above the same thresholds as those for the net investment income tax.
Employee Stock Ownership Plans
To facilitate the generation of cash in a tax-free manner, a C corporation might form an employee stock ownership plan (ESOP) and sell at least 30% of the stock to the trust, utilizing Sec. 1042. As long as the sellers reinvested the proceeds in publicly traded stocks and bonds, the realized gain on the sale to the ESOP would not be recognized. The buyers then might convert the C to an S corporation, where the income allocated to the ESOP would not be taxable. However, there are some fairly complicated provisions to prevent abuses of these very favorable rules. In particular, the tax professional should be aware of the normal fiduciary rules that apply to trusts, as well as the Sec. 409(p) disqualified person rules, when dealing with S corporations . It is important to note that the corporation should set up the ESOP before it elects to be an S corporation.
1 American Taxpayer Relief Act of 2012, P.L. 112-240.
3 IRS Data Book, 2012, Tables 2 (p. 4) and 9a (p. 22); see also IRS News Release IR-2013-32.
4 See, e.g., IRS Letter Rulings 201306020 (2/8/12), 201314006 (4/5/13), 201314012 (4/5/13), and 201320011 (5/17/13).
5 See, e.g., IRS Letter Rulings 201302013 (1/11/13), 201314036 (4/5/13), and 201311005 (3/15/13).
6 IRS Letter Ruling 201308022 (2/22/13).
7 IRS Letter Rulings 201306015 (2/8/13) and 201302004 (1/11/13).
8 See IRS Letter Ruling 201245014 (11/9/12), among many such rulings.
9 IRS Letter Rulings 201323012 (6/7/13) and 201323013 (6/7/13).
10 IRS Letter Rulings 201245001 (11/9/12) and 201245002 (11/9/12).
11 See, e.g., IRS Letter Ruling 201303009 (1/18/13).
12 IRS Letter Ruling 201325003 (6/21/13).
13 Santa Clara Valley Housing Group, Inc., No. 08-05097 (N.D. Cal. 8/6/12, 1/18/12, and 9/21/11).
14 IRS Letter Ruling 201309003 (3/1/13).
15 IRS Letter Ruling 201308008 (2/22/13).
16 IRS Letter Ruling 201306004 (2/8/13).
17 IRS Letter Ruling 201326012 (6/28/13).
18 IRS Letter Ruling 201246008 (11/16/12).
19 IRS Letter Ruling 201234001 (8/24/12).
20 IRS Letter Ruling 201322036 (5/31/13).
21 IRS Letter Ruling 201248001 (11/30/12).
22 IRS Letter Ruling 201320008 (5/17/13).
23 IRS Letter Ruling 201232023 (8/10/12).
25 IRS Information Letter 2013-0016 (6/28/13).
26 Watson, P.C., 714 F. Supp. 2d 877 (S.D. Iowa 2010).
27 Joseph Radtke, S.C., 712 F. Supp. 143 (E.D. Wis. 1989), aff'd, 895 F.2d 1196 (7th Cir. 1990).
28 Spicer Accounting, Inc., 918 F.2d 90 (9th Cir. 1990).
29 Joseph M. Grey Public Accountant, P.C., 119 T.C. 121 (2002), aff'd, 93 Fed. Appx. 473 (3d Cir. 2004).
30 Watson, 668 F.3d 1008 (8th Cir. 2012).
31 Watson, Sup. Ct. Dkt. 12-174 (U.S. 10/1/12).
33 Stephens, T.C. Memo. 2013-47.
35 Montgomery, T.C. Memo. 2013-151.
36 Rev. Rul. 81-187, 1981-2 C.B. 167.
37 Barnes, 712 F.3d 581 (D.C. Cir. 4/5/13), aff'g T.C. Memo. 2012-80.
38 Ball, T.C. Memo. 2013-39.
39 Powers, T.C. Memo. 2013-134.
41 Davis, No. 12-10916 (11th Cir. 5/16/13), aff'g T.C. Memo. 2011-286.
43 IRS Letter Ruling 201308017 (2/22/13).
44 IRS Letter Ruling 201234009 (8/24/12).
45 Rev. Proc. 2013-32, 2013-28 I.R.B. 55.
47 IRS Letter Ruling 201314031 (4/5/13).
48 IRS Letter Ruling 201232003 (8/10/12).
50 In re Kenrob Information Tech. Solutions, Inc., 474 B.R. 799 (Bankr. E.D. Va. 7/10/12).
51 The Majestic Star Casino, LLC v. Barden Dev., Inc., 716 F.3d 736 (3d Cir. 5/21/13).
52 Small Business and Work Opportunity Tax Act of 2007, P.L. 110-28.
53 This assumes that the children age 19–23 are not married. If they are, then the expanded kiddie tax does not apply.
54 Holik, "Interest-Charge Domestic International Sales Corporations," Tax Year 2008, Statistics of Income Bulletin 116 (Summer 2011).
55 Health Care and Education Reconciliation Act of 2010, P.L. 111-152; Sec. 1411.
56 Secs. 1401(b)(2) and 3101(b)(2).
Stewart Karlinsky is professor emeritus at San José State University in San José, Calif., and is an associate member of the AICPA Tax Division's S Corporation Taxation Technical Resource Panel. Hughlene Burton is an associate professor and chair of the Department of Accounting at the University of North Carolina–Charlotte in Charlotte, N.C., and is a member of the AICPA Tax Executive Committee. For more information about this article, contact Dr. Karlinsky at firstname.lastname@example.com or Dr. Burton at firstname.lastname@example.com .


text: While in San Francisco last week I stumbled upon the best cappuccino I've had in ages at Blue Bottle Coffee—purveyors of beans and beverages made from fair trade, organically grown coffee. Blue Bottle has sort of a make-shift store front on the street side of Earl Gonzalez and Tad Longmaid's Linden, a custom furniture workshop at 315 Linden Street. The beans are roasted, exhaled and blended in small batches at their Oakland headquarters across the bay. Each batch is only 21 lbs. (5 to 6 times smaller than average commercial roasters) which allows them to carefully inspect and control their product. Blue Bottle currently offers 13 different blends and is available online. Though given how small the batches are, I'm not yet sure how easy it is to get some.


text:
Morocco was never on my travel wish list. New Zealand, Iceland, and Brazil were all possibilities. But a visit to a predominately Muslim, developing country in northern Africa? I hadn't even considered it. All of that changed, however, when my 26-year-old son Karsten joined the Peace Corps.
The fact that he was assigned to work there not only put Morocco squarely on my radar, it allowed me to transcend the typical tourist experience and literally break bread with ordinary Moroccans—people whose language, dress, and culture are very different from my own.
I've been home just a couple of weeks, and I'm still sifting through the many sights, sounds, and tastes of my trip, yet there's one aspect that stands out—the connection I made with the women I met there.
My first introduction to a Moroccan woman was, oddly enough, during a video chat. My husband and I were conversing with our son shortly after he had arrived in Sefrou for training, when he invited his host mother, Fatima, to join us. At this point, Fatima had already nursed our son through one illness and had given him his Moroccan name, Karim.
In what remained of my high school French, I tried to thank her for taking such good care of "mon fils." While my French vocabulary failed me, my facial expression and our immediate connection did not. "Avec plaisir," Fatima replied with a smile that blew through the miles and burst through the screen like a warm breeze.
A year later, Karsten now lives in Tinghir, a city located south of the High Atlas Mountains, where he teaches life skills, like typing and AIDS awareness, to a co-ed group of local teens. During the week my husband and I visited him this past April, he and a Moroccan counterpart organized games and exercises to help his students develop confidence and communication skills.
"There is definitely a feeling of sisterhood among the women here," he told me one morning as we walked through town.
I felt the truth of that observation almost immediately. On the first full day after we arrived in Tinghir, I found myself sitting upstairs from Karsten's place in his landlord's apartment, surrounded by a group of women wearing the traditional hijab (head scarf) and ankle-length skirts or dresses.
Laila, who speaks a little French, was decorating my hands with henna. Rachida, who had her young daughter in tow, spoke to me in English. The rest, friends and relatives of my son's landlady, chattered away in the local Berber dialect.
Without my son present to translate, I did a lot of nodding and smiling. But Rachida clearly wanted more than just small talk.
"What do you think about the head scarf?" she asked me. (Most of the mature women I encountered in Morocco wore the traditional head scarf and a long dress or skirt — at least out in public —but not everyone does.) I told her that I thought it was fine if a woman chooses to wear it. She nodded her head and said that the "choice" was sometimes dictated by a strict father or husband. I had the feeling that Rachida was talking about herself. She clearly regretted not continuing her education. Once they are married, she told me, "Moroccan women are responsible for everything." It was a lament I was to hear from other women as well.
I felt the full force of Rachida's assertion a few days later when my husband, Karsten, three of his male friends, and I drove through a nearby town, passing cafes overflowing with male customers, while the few visible women were on the road, laden with babies, groceries, or bundles of alfalfa they carried home on their backs to feed the family donkey.
On that day, my femaleness, even more than my Western appearance made me self-conscious. I felt truly alien, oppressed by the difference between this place I was visiting and the place I call home.
Yet those differences seemed to dissipate whenever I was with a Moroccan woman; even if my daily outfit of jeans and a long-sleeved T shirt clashed with her long dress and hijab, even if we couldn't communicate through talk, her friendliness, interest, and generosity fostered a feeling of camaraderie that coursed through our time together.
Where did this feeling of sisterhood come from? Part of it, I'm sure, had to do with the high esteem these women have for my son and the respect he shows them. In fact, one conversation I overheard between Peace Corps volunteers during an earlier leg of our trip was focused on ways they could teach their young male charges to treat girls with more respect.
Moroccans are naturally hospitable, and making strangers feel welcome is an ingrained part of their culture. Family is very important there as well, so having "Karim's mama and baba" in their home was considered something of an honor. Beyond that—and I don't know this for sure—I believe that our mutual femaleness in a male-dominated society triggered the sense of sisterhood that Karsten observed, and that I experienced.
For example, one morning, Aisha, Karsten's landlady, showed me how to make the flat, round loaves of bread that are served with almost every meal. As she demonstrated her muscular kneading technique, rotated loaves of bread in and out of the oven, and cut up vegetables for a tagine—all accomplished with her 2-month old daughter strapped to her back—we also managed to commiserate, in our mutually limited French, about the challenges of nursing a newborn throughout the night.
Surprisingly, this feeling of oneness wasn't just limited to encounters with adult women. The hugs and kisses I received from the 12-year-old daughter of Karsten's Tinghir host family made me feel like a revered and much-loved aunt. And then there was our 10-mile trek to Todra Gorge with Karsten's Leadership Club.
The walk, which wound through the local oasis and up a dusty road to the gorge, took about four hours. While some of the boys reached out to me, I spent most of the hike surrounded by teenage girls who were determined to teach me a few words of Berber. By the time we reached the gorge, I had a vocabulary list. By the end of the day, I had been given cookies and candy, offered the use of a coat and some lip gloss, and had acquired several new Facebook friends.
I was lucky enough to see these girls on two more occasions, when we accompanied Karsten to his classes at the cultural center. I will never forget Hayat, who was both patient and persistent when teaching me how to introduce myself and ask others their name in her native language. And I will cherish my conversations with Kaoutââr, who will soon be leaving for the university to study medicine and whose nose is constantly in her schoolbooks. Nor will I forget the feisty Soukaina or the other Hayat, a tall, lanky athlete in a headscarf who can out-throw, out-catch, and out-run all the boys when participating in my son's American football club.
Several times during our visit, Karsten mentioned the Peace Corps mission to help "promote better understanding of other people on the part of Americans." I'd say they are achieving that mission.
The next time I look at a photograph of a Moroccan woman, I won't see a stranger, I'll see a friend.
This post was also published today on Women's Voices for Change.