text:
Unlock iPhone 6S – How to Unlock iPhone 6S
Factory Unlock iPhone 6S to work on other GSM Networks
The iPhone 6S is now out can be easily unlocked to be used on different service providers. This would be great for traveling and purchasing a local sim card or even locally switching service providers without having to purchase a new phone. We can unlock all major carriers including AT&T, T-Mobile, Rogers, Telus, Bell, Fido, Virgin, Koodo, Vodafone, Three, Orange and many more. We use the same safe and easy process networks will use to unlock their devices, but we do it as a fraction of the cost. Its 100% Guaranteed to permanently unlock your device or your money back.
Requirements for iPhone 6S PLEASE READ:
* Please make sure that your iPhone 6S has been activated with its original carrier at least once before.
* IMEI Number must not be barred, reported stolen or blacklisted.
* Network must be listed in the drop down box below.
* If your iPhone 6S is running on iOS 7, Please read HERE first
Watch Exactly How we will Unlock your iPhone 6S Network
Simply plug your iPhone 6S into iTunes when we send you the completed email
Safe, Fast & Easy!
Customers Who recently Unlocked their iPhone 6S using Cellunlocker.net
Why Unlock your iPhone 6S with Cellunlocker.net?
* Easily switch Sim cards between GSM Carriers using the same iPhone 6S Phone
* There is absolutely no risk of damaging your iPhone 6 phone by unlocking it.
* If you are travelling, buy a local SIM card and save on roaming fees
* Cellunlocker.net Guarantees Lowest price and Fastest Turnaround time
* No complicated jailbreaking,software, or cables required
* Unlock your Apple iPhone device from the comfort of your own home
* Our Automated system will E-Mail you when your iPhone is unlocked
Frequently asked Questions about Unlocking iPhone 6S
Q: Is this permanent? What if I update my firmware?
A: This is a permanent unlocking solution, once unlocked, it will never lock up again.
Q: How much will it cost to Unlock my iPhone 6S?
A: The pricing will vary depending on the Network your iPhone 6 is locked to. Do a code look up below and you will see the pricing for your device.
Q: How will I receive notification my iPhone 6S is unlocked?
A: Once your payment has cleared you will be emailed a message saying "Unlocked" and detailed instruction. The average turnaround time for processing depends on the network it is currently locked to
Q: Will this work for sure?
A: Yes we guarantee 100% this is will factory unlock your iPhone 6. However please keep in mind not all networks support unlocked phones, it is up to you to make sure the network you wish to use will support your unlocked iPhone 6S before placing your order
Q: Does it matter what software version my iPhone is?
A: No any software version will be fine.
100% Guaranteed to Unlock your Apple iPhone 6S Network
CHECK PRICING and do a free iPhone 6S code look up now!
START HERE by selecting your make below
Check your iPhone 6S code availability
We quickly scan our IMEI databases to see if a code is available for your device.
This search is completely free and anonymous!
Press *#06# on your device to get the IMEI number.
We need your contact information
Your information will be strictly used to deliver the code and instructions to the email address you specify once your order is complete.
Review your order and payment
Once you have finalized and checked that all the information is correct you will be transferred to Paypal's secure payment gateway.
Receive your iPhone 6S unlock code
Upon receiving your order and payment we will immediately begin processing your code request.
You will receive an e-mail with detailed instructions on how to unlock your device!
That's it!
Follow or Subscribe to Us for a chance for a FREE iPhone 6S Unlock Code


text:
|23 Sep 2011
This is a good example where with backup imaging you could have swapped in the most recent Win7 with IE8 in 20 minutes, saving a reinstall as that may well be your only option if you are that game for having an older browser version.
Backup Complete Computer - Create an Image Backup
|My System Specs
|Thread Tools
|Similar help and support threads
Is it possible to rollback to SP0 using others' backup files?
Hi all, Long story short, I would like to uninstall Service Pack 1 but unfortunately this can't be done because the backups have been removed. http://cdn.ghacks.net/wp-content/uploads/2011/02/removing-backup-files-550x295.jpg Is it possible for me to roll back to SP0 by borrowing this...
|General Discussion
Strange rollback after boot.
Today when booting Windows 7 I noticed Aero was disabled, I also noticed my wireless was disabled. Turns out WLAN AutoConfig was disabled. Now, I had both Aero and WLAN AutoConfig disabled (by choice) a time ago. So I'm thinking it must have rolled back to a point before I turned thoes two...
|General Discussion
Computer rollback issue
My computer graphics card seams to be rolling back its driver updates automatically. i have a radeon 5770, and the only update tht sticks is 8.851.0.0, the newest update driver for my graphics card is 8.902.0.0, why does it always roll back whn i turn my computer on?
|Windows Updates & Activation
Windows Setup Rollback?
Hi everyone, I have a Windows 7 Professional computer with 1 hard drive installed. I recently partitioned the hard drive to have two sections, 1 for my Windows 7 installation and one (20) GB Vista partition. While trying to install Vista, something went wrong so I had to force shut it down because...
|Installation & Setup
help me to rollback my computer
when I run the application newsid.exe. after the application process is complete I rebooted my computer. but. one irregularities. ie I can not open files that are on my documents and I can not open files on the desktop. when viewed in the documents and settings. the list grew and the user should...
|General Discussion
|Our Sites
|Site Links
|About Us
|Find Us
Windows 7 Forums is an independent web site and has not been authorized, sponsored, or otherwise approved by Microsoft Corporation. "Windows 7" and related materials are trademarks of Microsoft Corp.
© Designer Media Ltd
All times are GMT -5. The time now is 18:25.

subset: commoncrawl


text:
Robert M. Califf, M.D.
Vice Chancellor for Clinical Research
Duke Translational Medicine Institute
Professor of Medicine
Duke University Medical Center
Thursday, March 8, 2012
Building 45 (Natcher), Rooms E1/E2
NIH Campus | Bethesda, Maryland
Office of Disease Prevention
National Heart, Lung, and Blood Institute
National Institute on Aging
National Institute on Alcohol Abuse and Alcoholism
National Institute on Drug Abuse
NCI Division of Cancer Prevention
With the science of clinical trials evolving quickly, Dr. Califf discusses the role and value of clinical trials in medical research. The number of therapeutic interventions is growing, and the need for clear scientific evidence that these interventions work is mounting. Recent emphasis on evidence-based medicine, patient-centered outcomes research, learning, and accountable healthcare systems underscores the fact that most clinical trials fail to provide the evidence needed to inform medical decision-making. The need for a balance between commercial interests and public health is warranted.
Dr. Califf is the vice chancellor for clinical research and director of the Duke Translational Medicine Institute, and professor of medicine in the Division of Cardiology at the Duke University Medical Center in Durham, North Carolina. He is also the editor in chief of American Heart Journal and is the author or coauthor of more than 1,000 peer-reviewed articles. Dr. Califf also serves as a contributing editor for www.theheart.org , an online information resource for healthcare professionals involved in the diagnosis and management of cardiovascular disease.
He has served on the Cardiorenal Advisory Panel of the U.S. Food and Drug Administration and the Pharmaceutical Roundtable of the Institute of Medicine. He currently serves as co-chair of the Clinical Trials Transformation Initiative, a public-private partnership focused on improving the clinical trials system, and as chair of the Clinical Research Forum, an organization of academic health and science system leaders focused on the improvement of the clinical research enterprise. A member of the National Advisory Council on Aging, he also serves on the Secretary's Advisory Council on Human Research for the U.S. Department of Health and Human Services. Dr. Califf received his undergraduate degree from Duke University and his M.D. from Duke University Medical School.


text:
While messing around on Facebook, Ian got this horrifying combination of security words that seems like something straight out of a Final Destination flick. He writes:
Part of
Founded in 2005, Consumerist® is an independent source of consumer news and information published by Consumer Media LLC, a not-for-profit subsidiary of Consumer Reports.
Want Consumerist in your inbox? We will not sell or rent your email


text:
Youth Basketball: Grades 1-3
Oct 27 - Dec 22
Poudre Schools
Starting at
Meeting Dates
From Oct 27, 2016 to Dec 22, 2016
About This Activity
We're sorry, but this activity is over. The last meeting was Thursday, December 22, 2016.
4v4 Youth Basketball for students in first through third grade. Games to be played Thursday nights at local school gyms (game night subject to change). Games begin November 10. Practices to be held weekday evenings, exact dates and times are up to coaches and gym availability. Roster Assignment Drills will take place on October 27, 6:00pm at Eyestone Elementary. Walk in registration closes October 21 at 7:00PM. Space is limited to 48 registrants. Coaching needs must be met by 4:00pm, October 26 or league will be cancelled.
Practice dates and times TBD by coaches. Jerseys purchased online may be picked up, with receipt, at Recreation Office during registration hours. If coaching needs are not met by 4:00pm, October 26 this activity will be cancelled.
first - third
Games to be played at local schools.
Organizer Info
Wellington Recreation


text:
Models For Hob Surr Frm Whte
Hob Surr Frm Whte by Indesit
£55.08 Out of Stock
Email me when back in stock - we'll try to re-stock quickly!
The product Hob Surr Frm Whte is suitable for the models listed below.
View full product details for Hob Surr Frm Whte.
Search our range of models by entering your model number to perform a search.


text:
Home » Office Equipment & Supplies » Supplies » Printing Media » WAU22401
Wausau Paper Astrobrights Card Stock - For Inkjet, Laser Print - Letter -...
Over 50 in stock (as of 11/23/2017 06:49 AM)
Zoom panel loading...
Additional Images: Medium | Large | Original | Life-Style | Collections | 900 | 1100 | Out-of-Package | Hero-Shot | Zoom-Closeup | Alternate-Image1 | Alternate-Image2 | 1500 | 2000
Model: WAU-22401
View other products from Wausau Papers
Estimated Shipping: $8.00
Bold colors get all the attention! Heavyweight stock is ideal for applications and projects that need the durability to withstand repeated use. Perfect for direct mail business cards table tents presentations and more. Smooth finish. Laser inkjet and copier performance guaranteed. Acid- and lignin-free. This product was made from wood that came from a certified managed forest. Size: 8 1/2 x 11; Paper Color(s): Stardust White; Paper Weight: 65 lb; Sheets Per Unit: 250.
Brightly-colored card stock gets noticed every time. Ideal for color-coding, menus, posters and more. Guaranteed performance in laser and inkjet printers. Durable and heavyweight. Acid- and lignin-free. This product was made from wood that came from a certified managed forest. Global Product Type:Paper-Card Stock Size:8 1/2 x 11 Paper Color(s):Stardust White Paper Weight:65 lb Sheets Per Unit:250 Machine Compatibility:Inkjet Printers Machine Compatibility:Laser Printers Machine Compatibility:Copiers Compliance Standards:FSC Certfied Pre-Consumer Recycled Content Percent:0% Post-Consumer Recycled Content Percent:0% Total Recycled Content Percent:0%
Laser & Inkjet Printers
Recycled: No
Recycled Content: 30%
Post-consumer-waste%: 30%
Assembly Required: No
Environmentally Friendly: Yes
Environmental Certification: FSC
Environmental Certification: Green Seal
Country of Origin: United States
|General Information
|Neenah Paper, Inc
|Manufacturer Part Number
|Manufacturer Website Address
|Brand Name
|Product Name
|Colored Cardstock
|Marketing Information
Heavyweight cardstock provides great durability. Perfect for color-coding, menus, posters and more. Acid-free, lignin-free paper provides consistent, trouble-free press performance. Use in laser printers, inkjet printers, copiers and offset presses. 65 lb. weight.
|Packaged Quantity
|250 / Pack
|Product Type
|Printable Multipurpose Card
|Product Information
|Sheet Standard
|Sheet Size
|8 1/2" x 11"
|Basis Weight
|65 lb
|Print Technology
|Surface Finish
|Physical Characteristics
|Stardust White
|Card Stock
|Weight (Approximate)
|65 lb
|Astrobrights Inkjet, Laser Print Printable Multipurpose Card - Letter - 8 1/2" x 11" - 65 lb Basis Weight - 30% Recycled Content - Smooth - 250 / Pack - Stardust White
Warranty Information
|Beach Audio Warranty
This product was added to our catalog on Thursday, November 23, 2017.


text:
As part of their long-term plan to increase boost sales and increase its presence on the market, Huawei is strategizing how to become among the top five cell phone companies in the US. The company has its headquarters in China and has for a number of years produced good quality smartphones. The top 5 best Huawei smartphones are as follows:
1. Huawei Activa 4G
If you are looking for a heavy phone that says to people 'I am a smartphone' when you take it out of your pocket, then this would an excellent choice for you. It is 0.4 inches thick and weighs an incredible 4.9 ounces. It has a width of 2.4 inches and a length of 4.8 inches. This gives you an advantage in that you can watch movies and videos on the phone without straining your eyes. As per all Huawei smartphones, it runs on the Android operating system. The phone is equipped with Bluetooth, Wi-Fi, VPN and GPS support. You can browse the internet; download videos, music, and wallpapers with its superfast 4G network. This phone is great for taking pictures with a decent camera and 3.5 inch LCD screen.
You can use it to take photos of your family and friends or of memorable places. The phone gives you some simple buttons for navigation and five home screens, which you can customize to your liking. You do not have to worry so much about damaging the phone at the slightest fall since its heavy design can withstand such incidents. In case you are wondering about the price, do not worry; it is easy on your pocket.
2. Huawei Mercury M886
Do you want an all-rounded smartphone that is very light, superfast and appealing to the eye? Look no further, the Huawei Mercury offers all these features and so much more. The phone runs on the Android operating system and uses 3G network. This means that your internet connection is incredibly high thus; you can download anything you want fast. Do you get tired or bored carrying your current phone around all day as you go about your business? Well, this does not have to be a problem anymore since this phone is very light and slim.
You can move with it all day without putting it down. If you are into music, you will love the fact that Mercury comes with a 2GB internal storage space with an option to expand using a micro SD memory card. You can store your music, videos and photos comfortably without worrying so much about space. On top of that, it has excellent sound and video quality. If you are a lover of pictures, you have not been forgotten. The smartphone has two cameras one on the front and the other on the back with 8 megapixels. The battery is pretty durable and lasts for a full day.
3. Huawei Ascend G300
Sometimes you want to own a masterclass phone to make a statement or to boost your status. Going for approximately £100, the Huawei Ascend G300 gives you everything you would expect from a mid-range smartphone. You have probably heard of the saying "cheap is expensive". While this is true in many cases, this phone is among the few exceptions. Despite its very reasonable price, the phone has a great looking design that attracts others immediately you take it out of your pocket. It has a huge, bright and sharp screen that is simply eye-candy.
The physical appearance of this gadget indeed proves that cheap does not always have to mean ugly. One of the greatest advantages of the Huawei Ascend G300 is that it can handle desktop web browsing, movies, music and games without any intention of slowing down. The phone is equipped with a 5-megapixel camera that works perfectly for everyday photos and a long lasting that lasts a whole day. The phone is great for traveling since it is light and easy to carry and the battery lasts. Of course, all of us know the feeling when you are far from home and your cell phone battery dies. That will probably not happen with this phone. In short, it is a great phone at a great price.
4. Huawei Honor
Honor is an important part of anyone's personality and you would do anything to get it. Well, one of the things you can do to be honorable is having the Huawei Honor smartphone. One of the most notable features of this gadget is its big battery that can last for days without going off as long as you do the normal functions and do not use it excessively. This gives you an advantage in that you can watch full-length movies and videos on the phone back to back without worrying about the battery. As with the other Huawei smartphones, it runs on Android and has a processor of 1.4GHZ.
This means the phone is incredibly fast when swiping around the phone's menu. This phone is great for taking pictures with a decent camera and excellent display. The design of this phone is honorable and the weight is bearable. It has good audio and video quality in addition to big screen. If you love taking random photos with your phone then you have a new toy to play with. To get this kind of honor though, you have to go deep in your pockets since it goes for £250.
5. Huawei Pinnacle M365
Are you a text addict? Here is a new gadget that will take your addiction into a completely new level. The Huawei Pinnacle has a QWERTY portrait that is family and is to you. The company understands that not everyone is into touch screens, hence this phone. The user interface is very simple and easy on the eyes. It has a great design with a smooth back and a gray face. The phone runs on a 2.5G network, has a considerably good processor and a 2.4-inch screen.
Do you love listening to music while you text with your pals? Well this gadget also comes with a good quality audio player and a slot for a micro SD card, where you can put all your music. The phone is very light, weighing only 3.5 ounces. Therefore, you can carry it with you all day long as you text and listen to music. Initially, the phone was going for about $50 dollars but now it is less than half that figure. Thus, it is extremely affordable and anyone can pretty much afford it!


text:
A NEW business chief has been appointed to lead a regional food group.
Commercial specialist Jane Hogan has taken on the role of Business Development Manager at Taste North East, which champions the local food and drink industry.
Ms Hogan has vast experience in the innovation, engineering, manufacturing and corporate finance sectors and has founded two businesses of her own.
Her new role will be to help find new markets to support any food or drink-based business in the region, from growers and makers to those who sell, prepare or serve.
She said: "Our role at Taste North East is to inspire everyone, from families to football clubs and big and small organisations, to discover, source and share local food and drink.
"We are so lucky to have outstanding local food from Tweed to Tees. Our region has one of the best larders in the country, thanks to its strong fishing and farming heritage, and our producers are some of the most inspiring in the UK.
"Connecting people, especially buyers and suppliers, and creating a buzzing network of people and businesses who buy, supply, produce and consume food and drink in the region and beyond is pretty fundamental to what we do.
"My aim is for the North East to punch well above its weight food and drink wise. By working together we can shape a place where local food is actively sought out, enjoyed and shared."
Members of the group receive advice on developing their products and services, discounted training, ingredients and packaging, and updates on the latest industry news and legislation, as well as funding opportunities.
The organisation campaigns for regional produce to be sold in every food outlet in the region and aims to inspire the hospitality sector, restaurants, hoteliers and pubs to serve local produce.


text:
Find a business
Hotels in St. Martin/St. Maarten
See also: Bed & Breakfast Inns, Log Cabins / Treehouses, Resorts, Vacation Rentals, Motels, All categories
Showing 1 - 1 of 1 result(s)
Sunset La Terrasse CondosMaho Village, St. Martin/St. Maarten
Sunset La Tarrasse Condos is a vacation rental that sleeps up to 4 people conveniently located in the heart of the Maho village.
More information & rates Check availability
Show Lodging - Hotels in:
Show Lodging - Hotels in:
United States, Australia, Mexico, Indonesia, India, Malaysia, Philippines, Argentina, Colombia, Austria, Honduras, Dominican Republic, Canada, Nigeria, Morocco, South Africa, Kenya, Cameroon, Vietnam, Ecuador, Thailand, Haiti, Bahamas, Costa Rica, Chile, Bulgaria, Algeria, Sir Lanka, Oman, Dominica, Singapore, New Zealand, Trinidad/Tobago, Puerto Rico, Japan, Nicaragua, Guatemala, Taiwan, United Arab Emirates, Saudi Arabia, Anguilla, Gambia, France, Ukraine, Russian Federation, Venezuela, Brazil, Panama, Mauritius, Aruba, Turks and Caicos
Get your business listed here!
Click here for more information.


text:
Last year I got talking to this man, our kids were friends, he's quite a bit older than me, but he was canny enough. After a while he invited me round for a cuppa, so I went and he was telling me how he liked me ect, next thing you know we go to kiss. Well all I could see were these teeth coming at me and then his lips round my chin and on my nose. He said he has only ever been with one person before, but that and the kiss didn't put me off, he took me to his bed. A single bed!! We get undressed, he gets on top and no word of a lie, after going in and out 2 times, he stops and kisses me, then in another 2 times, kisses. And this carries on for a while. Obviously he was doing it to stop him cumming so quick. So I thought, right, I will play with myself while he is in me, as it usually feels really good that way and I need some pleasure. So I put my hand down there, he looks and gets embarrassed and starts giggling. After half an hour of this, he finally finishes. Safe to say i never went back again, and try avoid him when we collect our kids from school. And I did get a message telling me it was the best he ever had. Pity I couldn't say the same ..
Embarrassing S.E.x Stories! all funny and Embarrassing stories can be found here :D
Friday, February 22, 2013
Playground Fun
Subscribe to: Post Comments (Atom)
Blog Archive
- Field Trouble?
- Dont have a Baby Monitor!!
- Keep the Dog away!
- Everyone's First time!
- Dont spank each other!
- Find a Room!!!
- Keep track of your stuff! :D
- Pillows can be dangerous!
- Dont forget the handbreak
- Dont scare People!
- Having a Train Quicky
- Find a Better place!!
- BirthControl!
- Strep Cock
- Wasted Fun!!
- Double Embarrassment!
- Banned from Church!
- Shocking Towel
- Shocking Towel
- Parking Lot Embarrassment
- Face Creampie with own Cum!!
- Playground Fun
- Church Badluck
- Tampon Fun!
- Suprise!
- Keep a condom!
- Blowing some Cummm...
- Shaving Fun!
- First time fail!
- Just like the movie!
- Expiration Date
- Dad veiws the Fun!
- Sleepy Head!
- Grandma got a suprise!
- Embarrasing Mom!!
- Having fun with the Daughter
- Embarrasing Night out!
- Pre-cum
- bondage Fun!
- Queefs!!
- Roommates Suck!
- Anal Fun!
- Shopping Fun
- Boner Boy!!
- Sex in the open
- Park Fun
- Neighborly Love
- Neighbor fun!!
- Check your tent!
- Be quick!
- I like to Pee!!
- This isnt Narnia!
- Tampon Fun
- Never too old for Sex
- Pregnancy is not a good time!
- College Fun
- Gay Guys have a Prank
- Too Drunk :D
- Allgeric Reaction
- ▼ February (61)


text:
Under Armour taps 170M fitness users for new shopping app
Under Armour is bulking up on mobile by adding a shopping application to the brand's array of fitness titles, providing more than 170 million users with a personalized experience based on their workout history.
The new UA Shop app leverages data from Under Armour's digital fitness platform, which includes apps such as UA Record, MapMyFitness, Endomondo and MyFitnessPal, to provide users with a personalized shopping experience. UA Shop was developed to leverage data to provide in-app recommendations that connect consumers to the right gear.
"UA Shop is incorporating what we call personalization to contextualization," said Sid Jatia, vice president of direct-to-consumer digital at Under Armour. "We are creating experiences that are not just about who you are but where you are.
"We've integrated layers of custom content, your physical environment, and behaviors in other channels – including in -store experiences, purchase history and activity data – to create a single view perspective on how you are engaging with UA as a brand," he said.
Bridging fitness, shopping
The UA Shop app leverages data from the brand's connected fitness platform, such as athlete inspiration, workout history and previous purchase history, to create a personalized shopping experience for its core product categories – performance apparel, footwear and equipment.
Using in-app recommendations, the app will direct users to the right products. For example, a consumer living in a warmer climate who has logged several runs through MapMyRun might be exposed to UA CoolSwitch apparel and running footwear.
Members of the UA Record and MapMyFitness app-based communities can sync their existing account information to UA Shop. MyFitnessPal and Endomondo integration will be added soon.
A single profile
UA Shop is the first app to launch with the new Under Armour Account – a single profile for all Under Armour apps.
The UA Shop app also includes one-touch purchasing with Apple Pay, expanded product content and customer reviews and apparel tag scanners for in-store use.
"We have created a beautiful on-boarding experience that includes video content from the brand's athlete family upon opening the app," Mr. Jatia said. "From there, consumers can choose who they are shopping for, specific sports and activities they are interested in and select athlete inspiration.
"From these three simple steps, recommended products are provided from the complete Under Armour collection," he said.
The app is currently available in the Apple App Store and will be available soon in the Google Play store. It was designed to maximize the brand's digital platform while complementing its existing in-store experience by enabling consumers to find the products they want when they want them.
"As an industry standard and for Under Armour specifically, traffic is trending dramatically towards mobile," Mr. Jatia said. "Consumers are shifting from shopping on their desktops to their mobile phones today more than ever.
"Our Connected Fitness communities have millions of consumers who are already on mobile and UA Shop is the next step in bridging these communities with our core products," he said.


text:
Contact the MLAA
The Mountain Lakes Alumni Association is dedicated to serving all Mountain Lakes alumni by fostering a sense of togetherness, and promoting networking and communication among our community. Please contact us with any questions, comments or concerns you may have or if you'd like to get involved in any way. We are happy to accept any support offered to us.
Contact Us
The Mountain Lakes Alma Mater
When all Mountain Lakers gather
It is never very long
'Til we praise our Alma Mater
With a song
As we join our hearts together
Raise our voices clear and true
In allegiance to the Orange
And the Blue!
Where the echoes from the hillsides
Ring around the Wildwood shore
Dwell a host of friends we'll
Cherish evermore
Though our paths may someday sever
We'll recall the happy throng
That was bound as one together
In a song.
Sing! Sing! The Mountain Lakers' song
To thee our loyal hearts belong
For no matter where we wander
Or wherever we may roam
We will always think of Mountain Lakes
As home.
Follow Us


text:
Paytm is offering Asus X200MA-KX233D Laptop for Rs.12853 (after 18% cashback).
Now you can save more on buying Asus X200MA-KX233D Laptop at extra savings in your pocket. Asus is known brand in market for quality with best prices. Even now you can get various other gadgets also like mobile phone, tablets, smart watches and many more.
Asus Laptop Specifications: 1.83GHz Intel Celeron Quad Core Processor, 2GB DDR3 RAM, 500GB Hard drive, 11.6-inch Screen, Intel HD Graphics, DOS.
18% Cashback Promo Code: LAP18 (cashback can be used to recharge & buy products)
Buy: Asus X200MA-KX233D Laptop | More Laptops


text:
I started Purposeful because I was tired of seeing creative people like you struggle at companies that don't share their values.
I'll teach you exactly how to uncover your purpose, live your life purposefully, and land your dream job. You'll learn how to find companies that will value your skills the most, how to impress those companies with an optimized resume and portfolio, and how to negotiate with them from a point of power to secure the best-paying, most rewarding job possible.
If you're struggling with taking the next step in your career, I hope you find our free resources helpful. If you've got questions or need advice, please don't hesitate to get in touch.
Tim Noetzel
Founder | Purposeful


text:
GraphicRiver Skull Vector Illustration 4637181
Category: Stock Vector | Comment: ( 0 )
GraphicRiver Skull Vector Illustration 4637181
Stock Vector \ Tattoos
Roger \ Rock \ Isolated \ Illustration \ Skeleton \ Skull \ Vector \ Design \ Tshirt
Stock Vector - Skull Vector Illustration 4637181 by aos1212 @ GraphicRiver
Stock Vector \ Tattoos
Graphics Files Included: Vector EPS; Layered: Yes; Minimum Adobe CS Version: CS.
Very detailed skull vector illustration isolated on white. The contour and details are separated on different layers.
Butterfly Tattoo; Skull Tattoo; Pirate Skull and Crossbones; Ribbons.
Keywords: anatomy, black, bone, dark, dead, death, detailed, evil, fear, gothic, grunge, head, horror, illustration, isolated, rock, roger, skeleton, skull, tattoo, tshirt design, vector.


text:
Au Pair Blogs
Hi. I'm Treasa and I'm a Cultural Care Au Pair from Ireland. I'm 22 years old and I've been with my Host Family since November 1st 2013. I was very fortunate to have matched with a great family in St.Louis, Missouri. Here's my blog of how I'm getting on.


text: Power of Prayer We so often share with others but forget our creator. He is so powerful and with Him you can do greater things. At CFS, we need more Prayer warriors, those who know they can go to another level with God's help. Let's fill this earth with warriors!! Without your prayer support, we won't be able to do much. Our work will go fruitless. With your prayer support, there is absolutely nothing impossible. Join our prayer team: http://www.christianforumsite.com/groups/prayer-warriors.html or get in touch with Godbe4me via pm or send email to email@example.com


text: No recent wiki edits to this page. OriginLisa Castle was the daughter of Frank Castle. She was Frank's ticket to a normal life after his life as a soldier during the Vietnam war. Things finally seemed to calm down for them as Frank once more learned to live life in peace-time. However, disaster struck when Lisa, her brother Francis and her parents went for a pick-nick in Central Park. There they where witnesses to a mob execution. During this time, the mob fired on the family as well, fatally hitting Lisa and the other family. Frank was also gunned down but survived. These events and the death of Lisa, Maria and Francis where the trigger for Frank Castle to become the Punisher. Creation Lisa Castle was created by Gerry Conway and Tony DeZuniga and first appeared in the black and white magazine known as Marvel Preview Issue #2 (1975), that depicts the origin of the Punisher for the first time.Major Story ArcsDark ReignIn Dark Reign, Frank Castle - The Punisher - was gunning after Norman Osborn. He decided to take down The Hood. This decision did not turn out well for Frank. Frank soon found that The Hood was working with Frank's old partner, Microchip, and that Microchip had allied himself with The Hood for two reasons; one, he owed The Hood for bringing him back, and two, The Hood promised to resurrect his dead son.Eventually Frank's crusade came down to a final standoff. Microchip, Frank, The Hood, and the corpses of Frank's family and Microchip's son gathered. All Micro had to do to resurrect his son and Frank's family - according to The Hood's rules - was kill a SHIELD agent. Micro dutifully obliged, and Frank was horrified to watch as the caskets of his dead family opened once more.Frank then grabbed a flamethrower from a recently resurrected d-list villain The Hood had sent after him, and burnt his family and Micro's son alive, knowing that they were meant to be dead.


text:
« April 2009 |
| June 2009 »
This is just to let readers know that A Taxing Matter will be on break from May 29 through June 1, 2009. Regular postings will return June 2, 2009.
May 29, 2009 | Permalink
Comments (0)
TrackBack (0)
David Sirota, on Salon.com, sometimes has the perfect word painting for today's over-the-top age of Reagan-inspired government corporatism, where our government has been captured by Wall Street and the big corporations. Here's his description of the "destructive greed" behind the Yankee Stadium fiasco, whereby "a billionaire politician using the municipal office he bought [defends] charging $2,500 a ticket to a new Yankee Stadium he forced the public to finance." As Sirota notes, the Yankees are "the wealthiest corporation in sports". Sirota concludes--"In the new Gilded Age, socializing risk and privatizing profit has become the standard--as American as General Motors, Bank of America and, yes, the New York Yankees." See Sirota, the House that Taxpayers Built, salon.com, May 23, 2009.
May 28, 2009 in Current Affairs, Debunking the Reagan "Free Marketarian" Myth, Democratic Egalitarianism, Distributive Justice, Economic Conditions, State Taxes | Permalink
Comments (7)
TrackBack (0)
Last week, GM reached a deal with its union and now is trying to get its bondholders to come to terms before the June 1 deadline. It seems likely that a bankruptcy will follow, since bondholders want more than the $2 billion they would get under current transactional structure. See Vlasic, GM in Deal with Union as Deadline Approaches, NY Times, May 22, 2009.
Are the bondholders doing right to hold out? They seem to think it is unfair for the union to end up with a significant equity stake in the new company. Or are the bondholders really just another example of Wall Street greed run amok?
I tend to think the latter. As others have noted, bondholders' squawks about the union deal is a red herring. That's a deal that applies to the new Chrysler company, not money that would ever have been available to pay off the bondholders. Stephen Lubben (Seton Hall prof) told Salon.com it's erroneous to "think that value is being diverted to the unions, because the value that is going to the unions was never in the debtor to begin with." See Who is screwing with bankruptcy law?, Salon.com, May 23, 2009. The $2 billion offered bondholders is likely a reasonable sale price for the company--and that's all the bondholders are entitled to. The hedge funds in particular seem to object to the government's paying attention to the union. But that's a role that government should play, using its resources strategically for the long-term good of the economy and the American people. the government may invest $45 billion in GM by the time it is done, see Lois Romano, Treasury Secretary: Economic CPR, Wash. Post, May 26, 2009. so it is reasonable to pay attention to the people being served with that money. The bondholders aren't entitled to a similar bailout, however much they may have thought they might get one. If the government weren't involved, would somebody else come up to the table to put that money out? Don't think so.
Thus, the Washington Post editorializing strikes me as just another bit of the corporatist agenda that the paper has adopted over the last decade or so. See Government Motors, Wash. Post.com, May 26, 2009. The Post editorial board complains about the government caring about the workers more than the greedy bondholders some of whom bought bonds hoping that government funding would help them make a killing on the cheap as dirt bonds. Nuts. Why doesn't the board see that as appropriate ? Why are the unions--who have made concession after concession--being treated by the Post like bad guys, when the company (and its managers, owners, and bondholders) have always put the obligations to fully fund pensions for its legions of retired workers on the back burner while borrowing for even bigger shareholder/manager/bondholder gains? The Post has it wrong: working a good deal for the workers in the post-restructuring new company is a worthy goal for government's return on its investment in the business. And the fact that government is the big investor is a reality that the bondholders will just have to deal with.
Hedge funds are big lenders, it's true, and they may hold off on lending if they end up not getting as much out of the deal as they wanted. But the answer to that isn't to feed them more government dollars or to coddle them so that they even more successfully privatize gains/ socialize losses. They've gotten a cushy ride out of this economy for quite a while now. The answer is to regulate hedge funds and the exotic derivatives they use to speculate on the economy--if they are going to act like banks, they should be regulated like banks. No more overleveraging. No more opacity. No more unregulated derivatives. Less speculation and more solid investment. If they find they can't operate under those terms, then fine--leave the banking to banking institutions that are and should be heavily regulated, and let investors invest through more traditional means.
I think hedge funds are sort of like the sophisticated customized tax planning advice that big corporations use to constantly cut their effective tax rates lower and lower--they serve no genuine public good, and actually do a lot of harm. We should require taxpayers to file their returns based on the position that they think is more likely than not correct, rather than letting them speculate on a risky bet with a claim of "substantial authority." Congress goofed when it backed down on the tax preparer standard--it just needed to extend that same MLTN standard to taxpayers and tax preparers and we'd see a major shift in the tax advising and tax filing as a result. Similarly, let banks return to being the lenders of choice by regulating hedge and private equity funds like the banks they are and by applying anti-trust rules much more vigorously. Downsize most financial institutions by reinstating the old Glass-Steagall walls, and then don't ever let them grow to behemoth size that is "too big to fail" again. Regulate derivatives, so that these hedge funds and investment banks are not just speculating with wild bets that make it even harder for solid companies to keep working.
So Congress needs to do a lot to get this economy working in a way that provides a sustainable economic base for healthy living for ordinary Americans: regulate derivatives (and not just the plain vanilla ones), regulate hedge and private equity funds like banks, re-instate Glass-Steagall, reinvigorate the union laws (including passing the card system for approving a union, rather than letting anti-union employers hold all the cards), pass a "more likely than not" confidence level applicable to both taxpayers and tax advisers, and otherwise get busy eliminating the corporatist framework put in place over the four decades since Reagan first tooko office, so that it becomes harder for corporate America to take advantage of the American system without paying their fair share to workers and to the federal fisc.
May 27, 2009 | Permalink
Comments (4)
TrackBack (0)
edited 0526 to add Hyman article reference.
The Senate action on Health Care seemed to be targeted not at solving the health care crisis in the most economical way, but at finding a way to continue allowing the insurance/financial institution industry to siphon off huge profits while providing inadequate care. At the hearings of the Senate Finance Committee in May, protesters appropriately gathered to demonstrate against the Baucus committee's decision against having voices in favor of single payer/single provided government health care system represented in the committee's "roundtables". See, e.g., Washington Times, Health Care Protestors Disrupt Senate Panel for Second Week in a Row, May 12, 2009.
Of course, the problem is that the Republican Party today stands for privatization of everything, along with weakening of government's role even in areas in which government is more able to provide services than private companies. Senate Republicans have taken aim at universal health care, and intend to make it very hard for the Senate to pass a decent bill with a public option. Republicans argue that government-provided health care usurps medical doctors' role and rationing. See e.g., AP, Senate republicans plan attack on Obama health care bill, May 17, 2009. That disregards the facts: 1) the current system rations health care based on sick people's ability to pay rather than on decisions about how to best provide for the majority of the people, with profit-making health groups deciding whether or not a person's doctor will be paid if he or she performs a particular medical care regimen; and 2) government acts in the public interest, whereas care providers and insurers may be acting in their own profit-making interests.
Baucus has already made up his mind that a government provided health care system is neither practical nor politically feasible in this country, which demonstrates the incredible power of the financial/insurance industry today. Nonetheless, there needs to be a public option in the reforms, so that the role of government in providing such a basic service can be demonstrated and show ordinary Americans that it works, in spite of the misleading propaganda from the financial industry PR machine. We already know that Medicare and VA medicine meet patient needs at a cost staggeringly below that of private insurers, and one suspects that the reason the financial/insurance establishment is so against a public option as part of the current reforms is that they know that Americans will find out what Europeans have experienced for some time--health care as a service provided by government works better than privatized care where making a profit, not providing care, drives decisions.
The Senate approach has bogged down, though Baucus still claims that the Senate will begin consideration of reform legislation in mid-June. See Geisel, Health Care Reform Could Clear Senate This Summer, Assurant, May 21, 2009. Instead of enacting a single payer system, Baucus is still thinking about adding regressive taxes (the beer and soda tax proposal) and curbing the existing tax break for health insurance premiums to expand coverage (possibly capping the exclusion for healthcare expenses based on income). Baucus is even considering reducing Medicare spending on successful projects like home healthcare, medical imaging and durable medical equipment. See, e.g., Senate serves up Beer Tax For Health Care, CBS News.com, May 21, 2009; Young, Sens: Time has come for decisions on healthcare, Leading the News, May 20, 2009. It is hard to see how taking a good program like home healthcare--which permits families to take care of their chronically ill relatives at home for a pittance of the cost of hospital care--aids the goal of moving to a more equitable and more reasonably priced health care system.
David Hyman has a new article considering the factors that influence the costliness of health care in the US. David Hyman, Health Care Fragmentation: We Get What We Pay For (available on SSRN). One such factor is the highly fragmented system, on both the delivery and the financing sides of the market. Multiple providers and multiple payers without integration across the systems create incentives that favor inefficiency and duplication--and this is true of Medicare as well as private systems (not surprising, Hyman notes, since Medicare was modeled on 1965 private sector arrangements). The lack of a single payer system means that "in health care, most compensation arrangements pay health care providers for what they do, not for what they accomplish." Id. at 5. To avoid abuses in the private sector, various anti-trust and unfair competition laws tend to encourage further fragmentation. Hyman outlines some of the problems, but notes that it isn't clear how to achieve coordination and integration under our current payment system. While he proposes a few options (the typical economic incentives), he doesn't address the "elephant on the table"--the possibility of moving to a single payer, or even a single payer-single provider, system to address these problems of fragmentation.
Citizens for Tax Justice notes that discussion about "difficult choices" and "sacrifices" for funding health care reform seem to always disregard progressive choices in favor of regressive ones, like a value-added tax or regressive national sales tax. CTJ has a simple proposal--reduce the subsidies and preferences in the tax code "for the wealthiest and most powerful, especially in light of our having provided Wall Street (and thus the richest people in America) the biggest taxpayer-funded bailout in history." Given the recent history of the Wall Street collapse and savings by ordinary taxpayers, CTJ suggests a deal: "Main Street is paying to make wall Street healthy. Wall Street, when it is healthy, will return the favor." CTJ, Progressive Revenue Options to Fund Health Care Reform, May 21, 2009. Here's what CTJ proposes for raising a trillion dollars over a decade, beginning in 2012, to fund health care reform, simplify the tax code and move to fairer taxation of individuals:
CTJ notes that most of the new revenue would come from taxpayers with adjusted gross income above $200,000 (singles). As CTJ notes, we provide an ongoing subsidy to Wall Street through the preferential treatment of capital gains and most dividends. The Bush Congress claimed that reducing the rate for capital gains and dividends would encourage investment, create jobs, and improve quality of life. That claim was a mirage that did not materialize, and it is time to recognize it. We have in the meantime provided a huge bailout to Wall Street that makes it even harder to justify the capital gains preference (if there was ever a decent reason for it in the first place).
The Senate needs to get serious, and it needs to quit giving primary consideration to the insurers and financial interests that manage privatized health care in this country today. A public option needs to be on the table, in a way that lets Americans see how well it works. Let the health insurers compete.
P.S. Jim McDermott of Washington has introduced (again) legislation that makes considerable sense, whatever else we decide about health care reform. See McDermott website press release, May 22, 2009 (with a link to the proposed legislation). H.R. 2625, the "Tax Equity for health Plan Beneficiaries Act", would end the taxation of health care benefits provided to domestic partners. As McDermott notes, "there is no justification for the grossly unfair treatment some Americans receive today simply because Congress has not updated the tax code to reflect the modern labor market." Businesses have to pay taxes on employer-provided domestic partner benefits, and the employee receiving the benefit also faces an income tax liability. McDermott appropriately wants Congress to treat domestic partners the same way that dependent children or spouses of a qualifying employee ar etreated. Good thinking, McDermott!
May 26, 2009 in Health Care Reform | Permalink
Comments (4)
TrackBack (0)
Mike Crapo and Tim Johnson have introduced a bill in the Senate (S. 1082) to defer taxation of capital gains dividends from mutual funds that are reinvested in the same fund. The idea, according to their news release, is to "keep retirement savings earning more money for a longer period of time" and to treat those invested in mutual funds the same as those investing in the stock market. See Crapo website on GROWTH Act.
That's problematic for several reasons. First, the changes should go the other way. Instead of extending more preferential treatment to capital gains, Congress should eliminate the preference. Second, the fact that these funds may be used for retirement doesn't justify the tax reduction. Third, equating the trigger for taxation as the time that mutual fund shares themselves are sold is inappropriate and gives an inappropriate tax deferral. Holding stock through mutual funds means that when the mutual fund sells shares, it is as though the holder of the mutual fund had sold shares. The proposal gives a tax break to mutual fund ownership that parallels in part the tax treatment of individual retirement accounts, but those funds are established expresslyto encourage retirement savings, whereas mutual funds may be merely a way of diversifying.
Congress still seems to think that cutting taxes is the answer to every economic issue. Retirement savings not as good as they should be? cut taxes on income flows from vehicles that are used for retirement. Nobody buying as many cars? Give a tax break on the purchase of any number of new vehicles. Nobody investing as much as they should be in R&D? give a tax credit instead of a deduction. All these tax breaks are indirect ways of accomplishing policy that likely reward many a taxpayer for doing what the taxpayer would be doing without the tax break. They cost the federal fisc, and they add complications to an already complex tax code. They aren't very well targeted, and likely do as much public harm as public good in most cases. Congress should stop these special tax breaks, and start thinking about how to collect more in taxes in ways that are fair and help create a sustainable democractic foundation. The GROWTH Act proposed by Crapo-Johnson is not a good idea.
May 25, 2009 in Democratic Egalitarianism | Permalink
Comments (1)
TrackBack (0)
The Northern Illinois District Court has stayed the pending case brought by investors Leslie and ronnie Leff against Deutsche Bank pending arbitration. See Leslie Leff and Ronnie Leff v. Deutsche Bank, Case No. 08-CV-733 (May 14, 2009)(available on BNA).
In 1999, the Leffs entered into a "COBRA" strategy involving currency options, for whichJenkens & Gilchrist (the now-defunct Texas firm) provided a tax opinion and Deutsche Bank served as accommodation party. In 2000, the Leffs entered into a "PICO" shelter, again with Deutsche Bank as an accommodation party. The Leffs were audited and assessed back taxes as well as interest and penalties. Then in February 2008, they filed a lawsuit against Deutsche Bank for marketing the COBRA and PICO shelters, claiming that they were induced by Deutsche Bank to undertake the shelter transactions. In the course of executing the transactions, the Leffs entered into various agreements with counterparties (Counterpoint and Delta), in which Deutsche Bank was named as manager of various aspects of the accounts. The Counterpoint and Delta agreements included an arbitration provision covering "any controversy arising out of or relating to this Agreement or the breach thereof." Deutsche Bank therefore filed a motion to compel arbitration in the Leff's case against it, even though it was not a signatory to the agreements. The court concluded that the Leffs' "complaint alleges substantially interdependent and concerted misconduct between Deutrsche Bank and singatories to the contracts containing the arbitration provisions" and therefore the Leffs were equitably estopped from avoiding arbitration.
May 20, 2009 in Court Cases of Interest | Permalink
Comments (0)
TrackBack (0)
I. FASB rules for accounting for special purpose vehicles:
The Financial Standards Accounting Board yesterday voted on a measure to rein in the "qualifying special purpose entities" that banks (and other companies) used to do securitizations, --i.e., vehicles that permitted the banks to get "offbook" treatment that made them look better than they actually were to investors, since they often retained control and considerable risk of loss. The FASB will approve new principles-based standards for determining whether a company "controls" a variable interest entity and thus whether it can be deconsolidated. As noted in the "Briefing Document" (linked below), the FASB noted a problem with the current practice of permitting determinations of proper deconsolidation only when special triggering events occurred,
Under existing guidance, as expected credit losses increased significantly due to unpredicted market events, some companies did not reconsider whether they should consolidate a variable interest entity. The new standard requires a company to update its consolidation analysis on an ongoing basis. Briefing Document: FASB Statement 140 and FIN 46(R), fasb.org, May 18, 2009.
Under existing guidance, as expected credit losses increased significantly due to unpredicted market events, some companies did not reconsider whether they should consolidate a variable interest entity. The new standard requires a company to update its consolidation analysis on an ongoing basis. Briefing Document: FASB Statement 140 and FIN 46(R), fasb.org, May 18, 2009.
Additional disclosures will also be required, to increase transparency of these vehicles.
The new standards will also eliminate the automatic deconsolidation of certain "qualifying special purpose entities".
The second standard now headed for finalization—Statement 140—enhances information reported to users of financial statements by providing greater transparency about transfers of financial assets and a company's continuing involvement in transferred financial assets. It removes the concept of a qualifying "special-purpose entity" from U.S. GAAP, changes the requirements for derecognizing financial assets, and requires additional disclosures about a transferor's continuing involvement in transferred financial assets. Briefing Document: FASB Statement 140 and FIN 46(R), fasb.org, May 18, 2009.
The second standard now headed for finalization—Statement 140—enhances information reported to users of financial statements by providing greater transparency about transfers of financial assets and a company's continuing involvement in transferred financial assets. It removes the concept of a qualifying "special-purpose entity" from U.S. GAAP, changes the requirements for derecognizing financial assets, and requires additional disclosures about a transferor's continuing involvement in transferred financial assets. Briefing Document: FASB Statement 140 and FIN 46(R), fasb.org, May 18, 2009.
This is clearly a step in the right direction, including the fact that the rules, expected to be effective in 2010, will apply to existing entities as well as to newly created ones. There has long been a disjunct between the tax analysis of these deals (whether a transaction is a financing or a sale) and the accounting analysis as financing or sale. The tax analysis looks at all the facts and circumstances to determine the substance of the transaction, whereas accounting has too often been satisfied with satisfying a few objective criteria (that can often be manipulated through swaps and other derivative instruments that undo the appraent lack of involvement). That is one of the many reasons that I have objected to the Bush Treasury's determination to permit mark-to-market valuations for tax purposes based on a financial statement.
See also Appelbaum, Board to Ban Accounting Practice that Helped Lending Proliferate, Washington Post.com, May 18, 2009.
II. Klamath Strategic Investment Fund (BLIPS "economic substance" case in Fifth Circuit):
In another development in the ongoing saga about corporate tax shelter analysis in the federal courts, the Fifth Circuit joined a majority of other federal courts of appeal in holding that a tax plan can be derailed as failing the economic substance judicial doctrine when it lacks economic substance, without having to establish that tax avoidance was the sole reason the deal was undertaken.
The Klamath case involves the Bond Linked Issue Premium Structure (BLIPS). The BLIPS transaction used a foreign bank as an accommodation party (in this case, NatWest), and structured financings from the bank with a contingent liability (for $25 million) and a fixed liability that had an above-market interest rate. The liabilities were assumed by a partnership, and the partners claimed no reduction in basis for the contingent liabilities. Eventually, Euros were distributed in liquidation of the partnership and sold, and the partners claimed losses attributable to the artifically high basis. In the summary judgment case, the district court rejected the government's argument that the contingent liability would be treated as a liability under section 752, and invalidated the retroactive effect of new regulations under section 752 which define liability to include contingent liability, asserting that the law was "settled" under Helmer, 34 TCM 727 (1975), Long, 72 TC 1 (1978), and La Rue, 90 TC 465 (1988), in which the government successfully argued that partners got no basis increase for certain contingent liabilities. Eastern District of Texas summary judgment decision on issues other than economic substance in Klamath case, July 2006.
In the second opinion on the contested economic substance issue, the district court recognized the short-term planning evidenced in internal promoter documents (NatWest and Presidio) that made clear that the investors/partners would end their investment in the "nominal" seven-year strategy after 60 days and that the funds "invested" through the partnerships would be held by NatWest in short-term time deposits and not put at risk. A further giveaway--NatWest and Presidio treated the transaction as involving zero credit risk, and Presidio's management fee was based on the tax loss to be generated for the investors/partners on the 60-day exit. The court ruled that the "loans" lacked economic substance and were not loans at all, and any economic substance in the swaps was "illusory" because of the planned exit to generate losses. Accordingly, the partners were not entitled to the approximately $25 million in losses they had each claimed. (Note that the loss amount was approximately equal to the "loan premium" claimed not to be liability for partnership accounting purposes.)
Despite the literal terms of the documents, the court finds that Presidio, as the agent of and on behalf of Klamath and Kinabalu, entered into additional understandings and agreements with NatWest concerning the expected duration of NatWest's lending relationship with individual investors, including Nix and Patterson. In addition, Presidio and NatWest understood that the Funding Amounts would not be used to provide leverage for foreign currency transactions. Finally, Presidio's fee structure strongly suggests that Presidio's goal was not to earn a profit, but rather to secure large tax losses for its investors.
Despite the literal terms of the documents, the court finds that Presidio, as the agent of and on behalf of Klamath and Kinabalu, entered into additional understandings and agreements with NatWest concerning the expected duration of NatWest's lending relationship with individual investors, including Nix and Patterson. In addition, Presidio and NatWest understood that the Funding Amounts would not be used to provide leverage for foreign currency transactions. Finally, Presidio's fee structure strongly suggests that Presidio's goal was not to earn a profit, but rather to secure large tax losses for its investors.
Despite the literal terms of the documents, the court finds that Presidio, as the agent of and on behalf of Klamath and Kinabalu, entered into additional understandings and agreements with NatWest concerning the expected duration of NatWest's lending relationship with individual investors, including Nix and Patterson. In addition, Presidio and NatWest understood that the Funding Amounts would not be used to provide leverage for foreign currency transactions. Finally, Presidio's fee structure strongly suggests that Presidio's goal was not to earn a profit, but rather to secure large tax losses for its investors.
However, the district court basically treated the investors/partners as ignorant of the tax advantages of exiting this "investment" as they did until after the fact, and held that they were not liable for various penalties (gross valuation mistatement, substantial valuation mistatement, or substantial understatement of income taxliability or negligence/disregard of rules). The court also ruled that it had jurisdiction over a reasonable cause defense on behalf of the partnership in the suit for readjustment of partnership items under section 6226 (even though it would be the partners who ordinarily would claim reasonable cause as a defense in their own refund proceedings), and ruled that the partners satisfied its requirements, so that no accuracy-related penalties could be imposed. It also allowed the taxpayers to deduct operational expenses and ordered a refund of taxes based on a $250,000 management fee paid to their accountants.
On May 15, 2009, the Fifth Circuit, on appeal of the economic substance decision, affirmed in part, vacated in part and remanded. The court ruled that the Government lacked standing to appeal the section 752 issue (and the ruling that the regulation cannot apply retroactively), since it won anyway on economic substance grounds. It rejected the Fourth Circuit's Rice's Toyota World test for economic substance, concluding that lack of substance was sufficient even if the taxpayer professes to have a genuine business purpose, and considered only the question whether the purported loans would be invested, disregarding the actual, "collateral" investments made with the additional $1.5 million contributed by the partners. Otherwise, the court notes, it would "reward a 'head in the sand' defense where taxpayers can profess a profit motive but agree to a scheme structured and controlled by parties with the sole purpose of achieving tax benefits for them."
The court decided that the district court did not err in allowing the partner'ss reasonable cause and good faith defenses to be asserted in the partnership proceeding on behalf of the partnerships. Because the government had not asserted that the district court's decision was wrong on the merits of the defense, the Firth Circuit affirmed that no penalties would apply.
The District Court's decision was vacated on the question of deductions for interest and operating expenses, and remanded for reconsideration. No deduction for interest expenses is permissible, because the purported loans were not indebtedness, and the payments of purported interest are not deductible interest payments under section 163. similarly, if the other expenses are not made in connection with an investment undertaken with a profit motive, those expenses would not be deductible under section 212. The court held that the determination must be made in regard of Presidio, rather than in terms of the 90% partners who were able to generate tax losses, as done by the district court. It also held that a district court may not order a refund in a section 6226 readjustment action and vacated that determination.
May 19, 2009 in Accounting, Corporate Taxes, Court Cases of Interest, Tax Shelters | Permalink
Comments (1)
TrackBack (0)
Naked Capitalism's guest poster, Tyler Durden, has an interesting short blurb on AIG's unwind of its credit default swaps (CDS), at "AIG CDS Unwind Goes From Waterfall to a Trickle," May 13, 2009.
Why is this interesting? AIG unwound a trillion or so of its swaps portfolio in an extraordinarily short time, resulting in huge cash drains from AIG that were paid for by good ole American taxpayer money. That money drained straight from AIG over to the big investment banks that were mostly AIG's counterparties on those swaps. So when we bailed out AIG, we were really bailing out big investment banks. Many of the same banks were getting TARP funds directly, and likely some of those same financial institution counterparties (like UBS) were helping wealthy American taxpayers hide their assets offshore to avoid paying US taxes. Great deal for the investment banks, but not such a good deal for US taxpayers (socializing losses, privatizing gains).
I'm glad Andrew Cuomo is proving a dogged investigator. That is something on the ordinary taxpayer's side. And I am glad that Washington is finally switching gears, with the Obama administration's request to Congress on Wednesday for legislation that would permit federal oversight of exotic derivatives like CDS, legislation that would undo the catastrophic December surprise of 2000, when Phil Gramm pushed through the "no regulation legislation" for CDS. The proposal is for standard swaps and other derivatives to be exchange traded and reserved for, making the "shadow banking system" come out of some of the shadows. Customized swaps would not be traded on exchanges, but they will need to be open and transparent nonetheless. See Labaton and Calmes, Obama Pushes Broad rules for Oversight of Derivatives, NY Times, May 13, 2009. This is a good move, since derivatives are risky and speculative and also very useful in engineering some kinds of tax deals. Now if Congress can just resist the overtures of ISDA and the other securities lobbies to make this repeal of the Gramm Christmas surprise happen....And then move on to put the rest of the shadow banking system under the glass, by regulating hedge and private equity funds.
May 14, 2009 | Permalink
Comments (5)
TrackBack (0)
The Tax Foundation is one of those purported think tanks that preaches (I use the word calculatedly) a strong "free marketarian" ideology. Most of the materials produced come out very anti-tax, anti-government, and pro-big business. Most of the material makes one want more information about who is really paying the Tax Foundation's bills.
Not surprisingly, the Tax Foundation has now issued a "special report" challenging the Obama administration proposals on international taxation as "a step in the wrong direction" because they "would put U.S.-based companies at a competitive disadvantage in their competition with multinational firms based in other major trading nations." See Carroll, Bank Secrecy, Tax havens and international Tax Competition, Special Report No. 167, May 13, 2009.
Let's be clear. When the Tax Foundation argues for tax competition among countries (i.e., lowering of tax rates and losses of revenues in order to attract MNEs from other countries to establish some kind of token presence, usually, in the low-tax country), as it does here, it is not arguing for a policy that benefits ordinary Americans. It is arguing for a policy that would benefit major multinational enterprises located in the United States, ones that want the protection of the U.S. flag (and its flagships) but not the corresponding burden of helping to pay the price for the stability at home and the armed and diplomatic forces abroad that are so important to US MNEs when they do business offshore.
Similarly, when the Tax Foundation argues, as it does in the email message sending out the report, that the U.S. tax system is "out-of-line internationally" because it "has made no major change in its corporate tax in over 20 years", it is just plain wrong. When I began practice at Cleary Gottlieb in late 1995, there was a good bit of discussion in the Clinton administration and among congressional representatives about corporate tax shelters and the need to crack down. Doggett began proposing his economic codification bill, but the corporate lobbyists were able to defeat it, time after time. There was at the same time quite a long "wish list" of items that corporate lobbyists wanted to see passed in the tax code. Many in that corporate wish list were passed by the Bush Administration working with a Republican congress in the 2004 tax bills. One heard there'd even been an explicit tradeoff--the Republicans planned to pass their huge individual tax cuts in the 2003 bills (the one that gave the wealthiest Americans tens or hundreds of thousands in annual reductions of tax bills), and then the corporations will get what they want in the 2004 bill. What kinds of things were passed to favor corporations? How about the 2004 erroneously named "Jobs Act" provision permitting repatriation of long-held overseas profits at a pittance of the tax rate that should apply? That was a meritless giveaway for no purpose other than lowering (even further) the already low tax liabilities of U.S. MNEs. The US MNEs that had been "good" citizens, repatriating their profits regularly and paying at least some share of the appropriate burden, were stiffed by the competitive disadvantage created by this provision for the "bad" citizens. Companies that had held out and lobbied for the repatriation provision were able to bring back billions with extraordinarily low taxation, and then plan to hold out on any further repatriation until they could get a similar bill passed again in the future. The bill claimed it would create jobs. But there was no job creation requirement for getting the low tax rate! In fact, many of the companies that made a killing out of repatriating large sums at very low tax also laid off workers. Similarly, the enormous expansion of the expensing provisions under section 179 and section 168 have provided a gigantic tax writeoff for U.S. MNEs--upfront expensing does not comport with the economic decline in value of property and operates as a huge tax cut. The same is true of the R&D credit and the "manufacturing" deduction. There have, in fact, been a series of provisions that are "tax expenditures" favoring corporations amounting to billions of dollars. All of these things the Tax Foundation glibly disregards.
The Tax Foundation argues too that the OECD harmful tax practices initiative is itself problematic, suggesting that the paltry amendments by various nations to their information exchange problems have addressed the issues. Not so. If it were true, we would not be in a battle with Swizterland to force disclosure of names, where the Swiss banks says they can't provide information unless the request is made for specific accounts, but there can't be requests for specific accounts if the swiss banks have served to hide the information from the U.S. The information exchange provisions that the Tax Foundation suggests are sufficient, in other words, are merely window dressing. They do not do the job that is needed to prevent wealthy taxpayers from hiding their assets offshore to avoid taxation.
Similarly, the Tax Foundation insists that low tax rates should not be considered a harmful tax practice because it "is a legitimate way to expand a nation's tax base and increase the living standards of all residents." The latter, of course, is highly questionable in the case of tax havens like Bermuda or the Cayman Islands--those whose living standards are increased are generally the owners and managers of the MNEs taking advantage of the low tax rates to stiff their home country on the taxes due or the various parasitic law firms and others that make millions off of facilitating that stiffing. Competition between countries for the business of MNEs who treat countries as fungible entities so that they can pay labor the least and owners the most possible is not a public good.
The Tax Foundation also continues to compound the misrepresentation of the US comparative tax burden by emphasizing the statutory corporate tax rate rather than the average effective tax rate or the overall tax burden in the US and other countries. This is problematic for several reasons. The US statutory rate provides a very misleading picture of the relative tax burden of the US compared to other countries, because of the large amount of subsidy provided to US corporations through tax expenditures. Moreover, overly aggressive tax planning by large MNEs significantly reduces the corporate tax burden, since these sheltering transactions may not be found on audit or may not be adequately reviewed to find the aggressive position taken, resulting in companies paying taxes on a lesser amount of income than would be the case if the standards for reporting were stiffer and enforcement harsher. In fact, the average effective tax rate on large US corproations that do pay tax is substantially lower than the 39.25% combined national and subnational statutory rate that is cited in the Tax Foundation report. Additionally, other countries typically have a significant VAT tax as well as the corporate income tax (and often many additional excise-type taxes). Accordingly, the overall tax burden is very different from that portrayed solely by looking at corporate income tax rates. The Tax Foundation claims that the same "trends" apply to overall tax systems, relying on its own study that looked at the effective marginal tax rates, and asserts that average tax rates is not adequate, since it disregards the non-corporate sector. But this argument surely is a strawman--entities have a choice of form in the US. There are advantages to operating in the corporate form, and a corporation that chooses those advantages should bear a fair share of the costs of providing them (from regulatory apparatus to general law enforcement to defense apparatus).
The Tax Foundation implies that US MNEs pay the high US corporate tax rate on their foreign source income. However, that disregards the fact that US MNEs actually game the system to use foreign tax credits to reduce their US source income taxation--a reason for some of the rules proposed by the Obama administration.
Tax competition is merely one more tool in the corporatist agenda toolbox. It is not a public good, but a harmful result of globalization and the fungibility of money and, increasingly, labor. Capital owners benefit, but everybody else loses when countries' ability to raise appropriate revenues from the business sector is undermined by tax competition.
May 13, 2009 in Corporate Taxes, International Taxation | Permalink
Comments (13)
TrackBack (0)
This is what I intend to be the first in a series of postings on the various intertwined issues of health care reform, the impact of the increasing costs of medical care on the ability to provide universal access, and the appropriateness of continuing exemptions from taxation for hospitals.
Let's start with the latter. The focus in recent reports has been upon whether the tax exemption for hospitals is merited when they do not provide a significantly important differential amount of charity care--i.e., care for the indigent or those who are unable to pay, at no profit or even at less than the cost to the hospital. See e.g., Tax Exempt Hospitals--the American Hospital Association Response to the IRS Study, Feb. 24, 2009, and Tax Exempt Hospitals--do most exempt hospitals merit the exemption?, Feb. 17, 2009. It appears that much of the taxpayer subsidy of the exemption for hospitals has flowed through for the benefit of (as profits for) hospital managers and employee physicians rather than for patients. The tax exemption is accordingly a tax expenditure that, like most such tax subsidies, has been hidden in the tax code and perhaps not assessed fully by those most expert in health care and the relative merits of different incentives in that area. It may be that the tax exemption should be eliminated in our current system, since it appears to provide an irrationally inconsistent advantage for some hospitals over others that may have had a rational origin but whose parameters have changed so much over time that it is no longer justifiable.
Note that the tax exemption for not-for-profit hospitals is not the only element of the tax expenditure in the Internal Revenue Code. Individuals can make tax-deductible charitable contributions to such hospitals, receiving a tax benefit for their own tax returns. Hospitals may be beneficiaries of tax-exempt financing as well.
This is a matter that requires new consideration if there are actual steps towards reform of our current health care system so that there is universal coverage. For example, we may ultimately move to a single-payer, single-provider system, which would resemble the health care systems of most developed nations like the EU countries and Canada. Such a change is increasingly supported by Americans, as demonstrated by two recent surveys summarized on Sustainable Middle Class Blog. Polls Show Strong Support for Single Payer Health Program. In that case, hospitals would no longer be expected to provide charity care to the uninsured, since all would be covered. The tax exemption would appear to be an anachronism in such a universal coverage system--perhaps all hospitals should be considered public and nontaxable entities that are part of a single-provider system, or none should be eligible for special status as a tax-exempt organization.
Senator Grassley has already put this issue on the radar screen for the Senate Finance Committee. BNA quotes his comment today that "tax exempt hospitals appear more likely to provide services for those with insurance than [for] the poor and indigent. If as a result of health care reform everyone has health insurance, presumably hospitals should see a steep decline or the elimination of their uncompensated care." BNT Daily Tax RealTime, 051209 at 7:22pm. Grassley intends to release a revised standard for tax-exempt hospitals within the next two or three weeks.
May 12, 2009 in Tax Exempt Organizations | Permalink
Comments (4)
TrackBack (0)


text:
Cove Bay Water Treatment Plant Pilot Project to begin this summer
When you're passing by Grafton Lake this summer, you may notice a new structure sitting by the dam just off the side of the road. This container, expected to be fully installed mid-July, will house a mini water purification system that will serve as a pilot project to establish whether a proposed water treatment technology – ceramic ultra-filtration membrane process – will effectively treat Cove Bay water.
The overall goal of the project is to help provide clean, clear and safe drinking water to the more than 600 households that use the Cove Bay Water System.
The project was set in motion earlier this year when Bowen Island Municipality received a $3,890,367 grant from the joint Federal/Provincial Building Canada Fund – Small Communities Component. The grant represents a 2/3 share of the cost of the full-scale water treatment plant.
The pilot project is expected to be operational until the end of November, during which time water samples treated with the ceramic ultra-filtration membrane process will be analyzed, and municipal staff trained on the operation and maintenance of the system. The ceramic ultra-filtration membrane process – a technology developed in Canada – filters out bacteria, pathogens and organic matter in the water. This means less chlorine is required to be added to the water in order to meet Vancouver Coastal Health Authority's Drinking Water Treatment Objective.
If the ceramic ultra-filtration membrane process is determined to be successful, Council will move forward with construction of the full-scale water treatment plant in 2018. In fall 2017, Council will consider options for funding the municipal 1/3 contribution to overall project costs.


text:
Hotels in Bedford, United Kingdom
Search & Compare Bedford Hotels
Collect 10 nights, get 1 free night
And look out for Secret Prices on select hotels
Best hotels in Bedford
Bedford overviewVisitors can plan a fun excursion to Colmworth and North Bedfordshire Golf Club and Wyboston Lakes Golf Course while in Bedford. There's plenty more to see, including local sights like St. Paul's Church and Bedford Park. If you're looking for a new favorite getaway, look no further than Bedford.
Where to stay in BedfordWhether you're planning to stay for a night or for the week, the area around Bedford has accommodations to fit every need. Search for hotels in Bedford with Hotels.com by checking our online map. Our maps display the areas and neighborhoods around all Bedford hotels so you can see how close you are from landmarks and attractions, and then refine your search within the larger area. The best Bedford hotel deals are here with our lowest price guarantee.
How to get to BedfordFly in to London (LTN-Luton), 18.4 mi (29.6 km) from downtown Bedford. Cambridge (CBG) is the next closest major airport, 28.4 mi (45.7 km) away. Bedford Station is the closest train station.
What to see around BedfordFun outings can include a visit to:
- • Colmworth and North Bedfordshire Golf Club
- • Wyboston Lakes Golf Course
- • Bedford Autodrome
- • Woburn Safari Park
- • St. Paul's Church
- • Church of Saint Peter
When to visit BedfordCurious about when's the best time to visit? Here are the seasonal norms to help with your planning:
Seasonal temperature averages
- • January-March: 50°F day, 31°F night
- • April-June: 68°F day, 37°F night
- • July-September: 68°F day, 46°F night
- • October-December: 60°F day, 32°F night
- • January-March: 0.20 inches
- • April-June: 0.20 inches
- • July-September: 0.20 inches
- • October-December: 0.31 inches


text:
Following Iskander Makhmudov's Ural Mining and Metal Company, the MECHEL steel group is considering building a clinker plant, with a capacity of 1Mt, in Beloretsk, Bashkortostan (clinker is a raw material for cement production)
The plant will be built next to the Pugachev limestone deposit, owned by MECHEL. Production is scheduled to begin in late 2008 or early 2009. Analysts believe MECHEL will have time to earn on the project, despite the large number of the ongoing projects in the industry. Gross profit margins on cement production now average between 55% and 80%, while the Affordable Housing national project will ensure markets for cement makers in upcoming years.
Published under Cement News


text:
Patna, Dec 3 (UNI) Bihar Chief Minister Nitish Kumar today announced that Meena Singh, wife of late JD(U) MP Ajeet Singh, will contest the coming byelections to Bikramganj parliamentary constituency, slated for December 29.
The Bikramganj Lok Sabha seat fell vacant following the death of JD(U) MP Ajeet Singh, who was killed in a road accident near Siwan in Bihar.
After a Janta Durbar, Mr Kumar told reporters here that the decision had been taken to field Ms Singh as its candidate in the by elections, as her late husband was popular in the area and contributed a lot towards the development of the constituency.
''There was immense support from the people of Bikramganj in favour of Meena Singh, and the local unit of the party had also recommended for her candidature,'' he said, adding she would definitely emerge victorious.
''The kind of support that Ms Singh was getting from all sections of society in Bikramganj, it would not be an exaggeration to call her the people's candidate,'' he said.


text:
Results 1 to 5 of 5
05-30-07, 10:13 #1Registered User
- Join Date
- Apr 2004
- Posts
- 13
Unanswered: SQL Server deadlock on resources??
We've got a 3rd party application that periodically runs SQL commands throughout the day. We've been getting issues with this application showing a sql error:
Transaction (Process ID 71) was deadlocked on lock resources with another process and has been chosen as the deadlock victim. Rerun the transaction.
In checking the processes on SQL Server, there were a lot, and process ID 71 was actually hitting a completely different database.
Is there a way to streamline how SQL Server handles processes, and what's the limit at any given time?
05-30-07, 10:40 #2Registered User
Provided Answers: 17
- Join Date
- Jan 2003
- Location
- Massachusetts
- Posts
- 5,862
I think you need to do a bit more research on deadlocks in SQL Server. When a SPID is determined to be the victim of a deadlock, that SPID is immediately killed. What you saw in a different database was likely some new connection that jumped into the gap.
05-30-07, 12:32 #3Registered User
- Join Date
- Nov 2005
- Posts
- 122
Deadlocks are usually the result of bad programming practise.
If I remember correctly you can trace deadlock events in SQL Server Profiler.
Use it to track down the sql statements that are causing the deadlock. Most likely someone will have to re-program something.
05-30-07, 14:17 #4Registered User
- Join Date
- Jan 2003
- Location
- Nottinghamshire, UK
- Posts
- 364
Yup - I'd start with SQL Profiler - first try to configure the filter so it only looks at the third party app.
It's possible the app is opening numerous SPIDS / Connections to do it's job - this could cause one SPID to be working on the same data as a seperate SPID from the same application.
can you get the 3rd party app to cause an error whenever you want - if so it won't be as difficult as looking at everything it does via Profiler and trying to work out where a deadlock would likely get created.
Good Luck
GW"Everything should be made as simple as possible, but not simpler." - Albert Einstein
"Everything should be made as complex as possible, so I look Cleverer." - Application Developer
05-31-07, 03:37 #5Registered User
- Join Date
- Nov 2005
- Posts
- 122
I've checked Profiler now, and what you should do is to start a trace with the Lockseadlock graph, Lock: events. When the deadlock occurs it will tell you which objects are involved. You could also add the Lockseadlock event to see which spid (and application) that was chosed as the victim.


text:
Justin Rose
2016- Olympic Men's Golf Tournament Gold Medal
2015- Zurich Classic of New Orleans
2015- UBS Hong Kong Open
2014- Quicken Loans National
2014- Aberdeen Asset Management Scottish Open
2013- U.S. Open
2012- WGC-Cadillac Championship
2011- BMW Championship
2010- The Memorial Tournament presented by Nationwide Insurance
2010- AT&T National
2007- Volvo Masters
2007- Mastercard Masters
2002- Victor Chandler British Masters
2002- Dunhill Championship
Played a leading role in The Ryder Cup at Gleneagles in 2014, when the Englishman formed a formidable partnership with Henrik Stenson over the first two days on the way to remaining undefeated and claiming four points out of a possible five, as Europe cruised to a 16 ½ – 11 ½ victory. Arguably the 35 year old's finest Ryder Cup moment came in the "Miracle at Medinah" in 2012, when he secured a vital point in the Sunday Singles against Phil Mickelson. 2016 saw Rose become a history maker becoming golf's first Olympic Champion since 1904 with his two shot victory over Henrik Stenson in Rio. Made his Major Championship breakthrough winning the U.S. Open in 2013 at Merion Golf Club. Rose has won eight events on The European Tour, including the WGC Cadillac Championship in 2012.


text:
Asbestos MDL Ship Owners Waived Jurisdiction Objections, 3rd Circuit Rules
(Opinion available. Document #01-160831-003Z.)
Lionel Wilson, Joseph Braun and Thomas Guiden filed separate suits seeking damages under the Jones Act, 46 U.S. Code...
To view the full article, register now.
Try for FREE for fourteen days
Already a subscriber? Click here to login


text:
Refine Search
Save your search
Your search was saved!
Photos view · List view
How to Earn Rs.25000 every month in internet without Investment?$1,299.00
Posted Dec 09, 2014 to Work at Home
You can earn Rs.25000 very month from internet. This is easy form filling jobs.Just a copy paste work in Online. Work less than 1 hr daily. No investment. Please visit the website http://onlinedataposShare Add to favorites Remove Favorite Details Contact


text:
The road to the finals for Harvey was much difficult than Crenshaw's. Harvey defeated Beau Cutts of Henderson 3&1 in the morning quarterfinal. Harvey then faced Carter Page of Waynesville in the afternoon semifinals. Page, who will attend N.C. State this fall, held a 1 up advantage standing on the 18th tee. Harvey was able to win the 18th hole with a birdie to force extra holes. Harvey and Page tied the first four playoff holes with pars. On the 23rd hole, Page's approach shot sailed over the green into the fringe and he was unable to convert an up-and-down from behind the green. Harvey then two-putted to win the match.
Crenshaw beat Chad Cox of Charlotte 3&2 in the quarterfinals. He then outlasted Western Carolina University's JT Poston of Hickory 2&1 to advance to the finals.
View results for North Carolina Amateur Match Play Golf Championship
View Complete Tournament Information
Amateurgolf.com, Inc.6965 El Camino Real 105-631Carlsbad, CA 92011
Home | Tournaments | Courses | Equipment | Players | Rankings | Writers | About Us
About Us
The Majors
Now Playing
By State
AmateurGolf Tour
Men's Ranking
Women's Ranking
Senior Ranking
Privacy PolicyCopyright ©2017 Amateurgolf.com. All rights reserved.


text:
Mission School Trailer (2015)
15 November 2015 Drama 62 mins
Ba-Wool is a student at Daemyung High School which is Christian School. Every morning, a hymn resounds throughout the high school. Ba-Wool is a student president, but he is also non-Christian. He is unable to accept the required religious services and classes that all students have to attend. Ba-Wool talks to the principal, but the principal doesn't listen to Ba-Wool. Making things worse, Ba-Wool's only counselor, the school chaplain, is kicked out of the school. Ba-Wool's friends and his parents do not understand Ba-Wool. Finally, Ba-Wool refuses to take religious services and he begins a one person protest, while going on a hunger strike.
Watch the official Mission School 2015 trailer in HD below or find more Mission School videos on Vidimovie.


text:
Detalii loc de munca - Anglia
Descrierea jobului - Anglia
Position: Registered Nurse Hours: Full Time Salary: £14 - £15 per hour Our Client offers respite or permanent care to individuals with conditions such as brain injury, Motor Neurone disease, Multiple Sclerosis, Parkinson disease and Huntington's disease. You will be expected to work independently and safely whilst using your own initiative, training will be provided. Benefits:
Cost of Flight to the UK paid by employer. Accommodation secured for arrival. They will collect you from the airport if necessary. Simply Health Recruitment has exciting opportunities for nurses in the UK. We are working with leading independent healthcare providers in the UK.