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The Nebraska Huskers earned a berth in the NCAA basketball tournament, the NCAA announced on Sunday.
The Huskers (19-12) will travel to San Antonio to play Friday against Baylor (24-11), matching up two of the hottest teams in the country.
Baylor has won 10 of its last 12 games. Nebraska won 10 of its last 13 games, including a 77-68 win over No. 9-ranked Wisconsin to end the regular season.
Nebraska finished fourth in the Big Ten, one of the best conferences in the country. Only three Big Ten teams finished with less than a .500 season record. (see below)
The Huskers lost Friday in the quarterfinals of the conference tournament, allowing No. 24 Ohio State to overcome an 18-point deficit and edge the Huskers, 71-67.
In other good Husker athletic news during the weekend, the No. 9 Nebraska women's gymnastics team captured a share of the regular-season Big Ten conference title Saturday.
Big Ten final standings
Michigan -------- -25-8
Wisconsin ------- 26-7
Michigan State - 26-8
Nebraska ------- 19-12
Ohio State ------ 25-9
Iowa ------------- 20-12
Minnesota ------ 20-13
Illinois ---------- 19-14
Indiana --------- 17-15
Penn State ---- 15-17
Northwestern --14-19
Purdue --------- 15-17
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HOLIDAY SPOILER ALERT: Because this item normally ships in its original packaging, it may be visible upon delivery. We apologize for any inconvenience this may cause.
Series 200 Hutch Storage Combo is inspired by the Victorian hands of architectural style and craftsmanship. Therefore, this storage hutch looks grand as well as elegant when placed within the four walls of your child's room. This piece is made with striking scalloped edge details and carved finery. Additionally, it's also a piece serving some of the important functions such as storage. This hutch consists of two large open shelves that allow plenty of storage space where you can keep large items such as towels, blankets, clothing, toys or diapers.
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Artist Kathleen Kelley has graciously allowed us permission to use her recent acrylic on canvas painting "Partners" for our latest t-shirt.
It is the perfect expression of the bond that is formed between one of our rescues and their new owner when they find their new home.
Other Kathleen Kelley paintings can be seen at her web page kkelleyfineart.com/home.html
Check it out!! Tom Pace, Megan Miller, and Madi Barker have written about us. Read about the adventures of Chester and Wendell at Horse Helpers in the new children's book — Chester's Barn: A Book about a Horse Rescue. All profits go to benefit Horse Helpers. It will be on sale at the barn for $24.95.
Chance is the newest Horse Helpers arrival. He is a very sick little boy—only a year old and missing about 90% of his hair. Chance was rescued when he was about 6 months old and was doing really well until around December. The vets think that because he never had a chance to thrive, that his immune system is shot and he has been unable to fight off any problems a normal horse would have. He began to lose his hair in handfuls. Horse Helpers paid for a vet to come and he did better for a while. But in March, he began going downhill again. The problem became too big for his rescuer to handle and she surrendered him to us.
Chance has been with us for about three weeks now. He has stopped losing hair and is putting on weight. The swelling in his back legs has gone down and the farrier has started working on the deformation in his hooves. Although if you saw him today, you would say he looks terrible, to us, his skin is starting to look better and you can see that his hair is beginning to grow back. Every warm day, he receives medicated baths, and he goes on daily walks to help with his movement. He is getting all kinds of things to help boost his immunity. Our Healing Touch practitioner works on him twice a week and the vets are on top of his traditional healthcare. Read more about Chance . . .
Please help us with his medical expenses if you possibly can.


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Having recently started my own business, I wanted a website up and running fairly quickly. Openglobal did this for me within days, and I have already had lot's of enquiries through the website which is great. I can highly recommend Openglobal for their efficient and professional service, and for their approachable and helpful manner.
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The Pension Protection Act of 2006 (PPA), which so radically redefined the rules for supporting organizations, also transformed the rules for donor-advised funds (DAFs). The PPA for the first time accords DAFs express recognition in the Internal Revenue Code, a tribute to the recent rapid success of DAFs as well as the charities and commercial firms that sponsor them. But DAFs are given this recognition merely so they can be subjected to new taxes and restrictions — and the act imposes more than its fair share of these:
there is a new tax imposed on what are called "taxable distributions" from DAFs;
there is a new tax imposed (at the sobering rate of 125 percent) on what are termed "prohibited benefits;"
the excise tax on "excess benefit transactions" is made expressly applicable to DAFs and their controlling charities, which the PPA terms "sponsoring organizations;"
the excise tax on the "excess business holdings" of private foundations is stretched to encompass DAFs;
changes are made to annual returns and applications for recognition of tax-exempt status by sponsoring organizations; and
rigorous new restrictions and limitations are imposed on the deductibility of contributions to DAFs under the income, gift and estate tax provisions
Even more alarming for donors and their advisors, the future deductibility of any contributions to DAFs is now under a cloud.
It's a lot to swallow. So let's break it into bite-size portions.
While DAFs vary widely in their provisions and particulars, generally a DAF is a fund or account held by a charitable organization, to which contributions are made by donors who enjoy the privilege of "advising" the sponsoring organization as to what use it may make of the DAF's income or principal, including what charities may ultimately receive distributions. Though they've been utilized since the 1930s1 and now hold billions in assets,2 DAFs have managed to accumulate very little law in these seven decades. The PPA certainly changes that. (See "Coping," this page.)
DAFs have been considered in a handful of decisions and rulings.3 They're given some discussion in the Treasury Regulations.4 But, surprisingly, before Aug. 17, 2006, DAFs were not even mentioned in the Code. In fact, given this dearth of law, DAFs may be said to have been relatively untested, even aggressive, charitable vehicles. Yet, their use is widespread by community foundations and, more recently, by other charitable organizations, as well as commercial firms.
Among the many reasons for the DAF's great success was its simplicity: A donor who might otherwise have created a private foundation or a supporting organization, with their attendant costs and hassles of establishment and compliance, can instead contribute assets to a DAF with a simple check or wire transfer. If the sponsoring organization qualifies as a public charity, the donor enjoys the highest deductibility thresholds for the contribution: 50 percent of adjusted gross income (AGI) for cash gifts, 30 percent for gifts of appreciated assets, with a five-year carryover of excess deductions. (This stands in sharp contrast to 30 percent for cash contributions to a private foundation, 20 percent for gifts of appreciated publicly traded stock, and a harsh "reduce to basis" rule for appreciated nonstock contributions).5 DAFs have been particularly attractive for year-end gifts, for which donors lack the time and often the information to make a careful selection of charitable organizations on which to bestow their contributions. Gifts too small to justify the creation of a private foundation make much more sense in a DAF setting. And while donors sacrifice the control they would have exercised over investments and distributions in a private foundation, the ease, simplicity and flexibility of contributing to a DAF often more than makes up for this loss.
So successful had been community foundations' experience with DAFs, that eventually other traditional charitable organizations created DAFs as a means of attracting new donors and expanding gifts from existing donors. In the 1990s, a number of commercial investment firms, including industry giants Fidelity and Vanguard, formed their own DAF-holding charitable entities.
As is sometimes the case with charitable vehicles,6 their stunning success carries within it the seeds of the new restrictions and limitations later imposed. With DAFs, perhaps most provocative of scrutiny and reform was the fact that they were openly marketed as, in effect, substitutes for private foundations. If DAFs permitted donors to avoid the hassles of private foundations, at the same time they also avoided the protections against abuse that were rather painstakingly drafted as part of the Tax Reform Act of 1969. Indeed, DAFs were attractive precisely because they avoided these protections. When the large commercial institutions entered the fray, concerns arose as to whether a DAF created by such an institution might be said to inure to the benefit of the founding enterprise.
The proper characterization of the ownership of the DAFs, too, became something of a sticky business. Should contributions to a DAF be considered contributions to the sponsoring organization, as part of meeting its "public support" test requirements?7 Or should the contributions be attributed to the ultimate recipient charity, to meet its own "public support" test requirements? Should both charities be allowed to garner the "public support" test benefits of these DAF contributions?8
And what about the advisory rights and powers retained by the donor? Were they sufficient to constitute an effective limitation on the sponsoring organization's dominion and control over the DAF assets? Were they essentially a form of prohibited private inurement9 to the donors and their family members? Worse, could donors and their advisors find the means to retain effective donor control over the DAF assets, which were supposed to be controlled by the sponsoring organization? And just how real was the charity's dominion and control over the DAF assets, when many sponsoring organizations repeatedly assured their donors that the donor's advice would be followed in virtually all cases (except where a donor advised a grant to a nonqualifying recipient)?
These growing concerns began to surface in pronouncements from the Internal Revenue Service. Strongly worded warnings found their way into the IRS Exempt Organization Continued Professional Education (CPE) Texts.10 In the IRS CPE Text for Fiscal Year 2001, for example, the Service expressed concerns about whether the fact that in many DAFs, "distributions from donors may be triggered only by donor recommendations" meant that the charity "lacks dominion and control or 'ownership' over the property." Similar concerns were expressed in the document as to the lack of minimum payout requirements in many DAFs, with the suggestion that a 5 percent payout, similar to the requirement applicable to private foundations, should be applied to DAFs.
Ultimately, while Congress was considering the legislation that emerged as the PPA, the General Accounting Office (GAO) issued a report to the House Ways and Means Committee on DAFs.11 This report noted a number of abuses associated with DAFs. In one instance, the Tax Court found a DAF had been offering what the fund called a "loan program," under which donors to the DAF were able to repossess their donations, with no obligation for repayment.12 In another case, a DAF donor was able to achieve control over the DAF funds by virtue of his control position at the charity that was the ultimate recipient of DAF grants.13 In that situation, the report noted that, if the DAF form did not exist, the recipient organization likely would have been classified as a private foundation, as it probably could not have met the "public support" tests.14 The preparers of the report were troubled by examples of websites describing DAFs "as a giving option with all the benefits and advantages of a private foundation, which may mislead potential donors into believing they can retain control over their donation."15
The report noted the GAO's difficulties in attempting to gather information and data about DAFs, noting that "donor-advised fund data are limited because organizations that maintain the funds are not required to separately report fund data from other financial data on Form 990."16 The report also complained that the "IRS faces challenges gathering evidence or addressing activities that do not seem to benefit charities, but do not violate any law or regulation".17 The report continued: "Promoters, who are individuals or entities who facilitate abusive schemes, further complicate IRS's examination efforts."18
The PPA often reflects the concerns raised in the report, in earlier IRS pronouncements and positions, and the solutions these materials proposed. Hence, these concerns provide a basis for understanding what might otherwise be fairly opaque provisions of the PPA.
The PPA may imperil the very deductibility of future contributions to DAFs. Section 1226 provides that the Treasury Department is to undertake a study on the organization and operation of DAFs, which shall specifically consider whether the income, gift and estate tax deductions for contributions to sponsoring organizations of DAFs are appropriate, considering the use of the contributed assets (including the type, extent and timing of such use), or the use of sponsoring organizations' assets for the benefit of the donor or related persons.19 If the Treasury study concludes that contributions to DAFs are no longer deductible, that would certainly be within the province of the PPA provision. Perhaps, though, this study might draw a distinction here between "commercial" and "noncommercial" DAFs. It would seem unlikely that the study would recommend some sort of retroactive disqualification of deductions for contributions to DAFs, beginning Aug. 17, 2006 — but that, too, is at least a remote possibility. Of course, Congress might not reflect all of the study's recommendations in new legislation; then again, Congress might go farther than the study recommends. In any event, the PPA's "study" provision is not very encouraging for donors. Contributions to DAFs may well drop in coming months, as advisors come to understand the provision's unpleasant implications.
The study also considers whether DAFs should be required to distribute a specified amount, based on income or assets, to ensure the sponsoring organization is operating consistently with its exempt purposes or function.20 There may well emerge from this aspect of the study a minimum annual distribution requirement similar to the private foundation requirement under IRC Section 4942, under which at least 5 percent of the value of the assets of a particular DAF may be required to be distributed each year to public charities.21
Yet another goal of the study will be to consider whether donors' retention of rights and privileges as to donated amounts, "including advisory rights or privileges with respect to the making of grants or the investment of assets," is consistent with treatment of donations to DAFs as completed gifts that qualify for the charitable deduction.22 If a donor's retention of a "right and privilege" to advise with regard to a DAF is to be enough to deny the donor a charitable deduction, then clearly this would spell the end of DAFs as we know them. Perhaps the statutory provision is intended merely to give the widest scope and berth for the Treasury's study and recommendations, rather than suggesting that the study draw this conclusion. Given the Service's sensitivity on the issue of DAFs in recent years, however, the Treasury could well interpret this provision as a mandate to recommend changes that reach to the boundaries of the study provision.
The study is to be submitted to the Senate Finance Committee and the House Ways and Means Committee by Aug. 17, 2007.23 Until it is submitted and Congress acts on it, contributions to DAFs will remain under something of a cloud. For this reason, this study provision is arguably the harshest aspect of the new DAF legislation.
The remaining DAF provisions are gathered into Title XII, Subtitle B, Part 2 of the PPA, which is pointedly entitled, "Improved Accountability of Donor Advised Funds." The first provision of this Part 2 adds two new IRC Sections: Section 4966 relates to taxes on a DAF's taxable distributions"and Section 4967 to taxes on a DAF's prohibited benefits.
Tax on "Taxable Distributions": New IRC Section 4966 officially adds a number of terms to the DAF lexicon, including, for the first time, a statutory definition of a DAF itself. A "donor-advised fund" is defined as a fund or account that:
is separately identified by reference to contributions of one or more donors;
is owned and controlled by a sponsoring organization (another new term); and
a donor (or a donor's appointee or designee) has, or reasonably expects to have, advisory privileges as to the distribution or investment of amounts held in the fund by reason of the donor's status as a donor.24
Expressly excluded from the definition of a donor-advised fund is any fund or account that makes distributions only to a single identified organization, or to a governmental entity.25 Similarly, a fund or account is excluded from the donor-advised fund definition if the donor (or the donor's appointee or designee) gives advice about individuals who are to receive grants for travel, study or other similar purposes, if:
the advisory privileges are performed exclusively in the donor's capacity as a member of a committee appointed by the sponsoring organization;26
no combination of donors or related persons directly or indirectly control this committee;27 and
all grants from the fund or account are awarded on an objective and nondiscriminatory basis following a procedure approved in advance by the sponsoring organization's board of directors;28 the procedure being designed to ensure that all grants meet the requirements of IRC Section 4945(g).29 This section describes grants made by private foundations to individuals who are awarded on an objective and nondiscriminatory basis under a procedure approved in advance by the Service, and who meet other specified criteria.30
Treasury has the authority to exempt a fund or account from treatment as a donor-advised fund if the fund or account is advised by a committee that is not controlled, directly or indirectly, by the donor (or the donor's appointee or designee or related parties), or if the fund benefits a single identified charitable purpose.31
The new term "sponsoring organization" is defined as any organization described in IRC Section 170(c) (other than IRC Section 170(c)(1)) that is not a private foundation, and that maintains one or more donor-advised funds. The term "fund manager"32 is defined as an officer, director or trustee of the sponsoring organization (or a person with similar powers or responsibilities).33 The term "fund manager" also includes, with regard to a specific act or failure to act, the employees of the sponsoring organization having authority or responsibility as to such act or failure to act.
This new IRC section imposes a tax of 20 percent of the amount of each taxable distribution, which is to be paid by the DAF's sponsoring organization.34 In the familiar pattern of the private foundation excise tax provisions,35 a secondary tax is imposed on "the agreement of any fund manager to the making of a taxable distribution," if the manager knows that it is a "taxable expenditure."36 This tax of 5 percent of the amount of the taxable expenditure is imposed on the fund manager "who agreed to the making of the distribution." In cases in which more than one fund manager is responsible, the PPA provides for joint and several liability37 to help ensure collection. The maximum amount of tax imposed on fund managers with regard to any one taxable transaction is limited to $10,000.38
New IRC Section 4966 goes on to define a "taxable expenditure" as "any" distribution from a DAF to a natural person, or to any other person if the distribution is for any purpose other than an IRC Section 170(c)(2)(B) purpose,39 or if the sponsoring organization does not exercise "expenditure responsibility" as to the distribution, in accordance with IRC Section 4945(h).40 "Expenditure responsibility" consists of seeing that the expenditure is spent solely for the purpose for which it was made, obtaining full and complete reports from the recipient as to how the funds are spent, and making full and detailed reports with respect to such expenditures to the Service.41 The term "taxable expenditure" does not include a distribution from a DAF — to any organization described in IRC Section 170(b)(1)(A), other than a "disqualified supporting organization" to the DAF's own sponsoring organization; or to any other DAF.42
A "disqualified supporting organization," in turn, is defined as any Type III supporting organization (other than a "functionally integrated" Type III supporting organization).43 Hence, it now is crucial for a DAF to determine the precise nature of its intended grant recipients to avoid the new IRC Section 4966 tax. Briefly stated, a Type III supporting organization (SO) is an IRC Section 509(a)(3) organization that is "operated in connection with" one or more supported public charities. While many Type III SOs are essentially grant-making organizations, which support their supported public charities through direct grants, other Type III SOs support their public charities by carrying on their own charitable activities which, but for the supporting organization's involvement, would normally be carried on by the supported charity itself. The PPA renames these "activities" Type III SOs as "functionally integrated" Type III SOs — and this variety is exempt from the definition of "disqualified supporting organizations" under new IRC Section 4966(d)(4)(A)(i).44 However, Type III SOs have long been permitted to vary their operations from year to year from grantmaking to carrying on their own activities. So how can a DAF and its sponsoring organization determine with any certainty whether a Type III is of the "not so good" grant-making variety, or the "good" activities variety? This is not clear from the PPA, and a further complication is that IRS letters of determination that are issued to SOs do not usually specify whether a supporting organization is a Type I, Type II or Type III SO — let alone whether a Type III is an activities Type III versus a grant-making Type III. Perhaps the DAF's sponsoring organization can attempt to secure a statement from the Type III SO, or from counsel, as to which variety of Type III it is. Faced with these difficulties, it may well be that sponsoring organizations may simply opt for the easier alternative: declining as a matter of policy to make gifts to any Type III SOs. Of course, this is a more conservative approach than the PPA calls for.
Grant-making Type III SOs are not the only types of SOs that fall within the new IRC Section 4966(d)(4) disqualified supporting organization category. Type I SOs45 and Type II SOs46 also do, if the donor (or the donor's designee with regard to advising on distributions) or related parties control the SO, directly or indirectly, or the Secretary determines by regulations that a distribution to an SO is otherwise inappropriate.47
The new IRC Section 4966 tax applies to taxable years beginning after Aug. 17, 2006.48
Tax on "Prohibited Benefits": New IRC Section 4967 imposes a tax on what are termed "prohibited benefits" involving a DAF. This new provision imposes a very steep tax on the advice of certain persons to have a sponsoring organization make a distribution from a DAF that results in a direct or indirect benefit to a noncharity that is more than an incidental benefit. This new tax is imposed at the rate of 125 percent of the benefit, and is imposed on the person who advises as to the distribution, or who receives the benefit as a result of the distribution.49 The category of persons subject to the tax are the persons described in IRC Section 4958(f)(7), a new subsection of the excess benefit transaction provisions that the PPA also added.50 The category consists of persons described in new IRC Section 4966(d)(2)(A)(iii), namely: advising donors (or their appointees or designees). Also included in this category are members of the family of the advising donors or their surrogates,51 and entities that are 35-percent controlled entities with regard to the advising donors.52
A lesser tax of 10 percent of the benefit is imposed on the agreement of any fund manager to the making of the offending distribution from the DAF in circumstances in which the fund manager knew that the distribution would confer the taxable benefit, and the tax is to be paid by that fund manager.53 No tax is to be imposed under this new provision54 if a tax has been imposed on the benefit distribution under IRC Section 4958, the "excess benefit transaction" provision. Joint-and-several liability is applied to the advising donor and related parties, as well as to the fund managers who agreed to the distribution.55 The tax imposed on any one distribution upon fund managers is limited to $10,000.56 But there is no equivalent limit for the advising donor category.
This new tax applies in taxable years beginning after Aug. 17, 2006.57
Note that new IRC Section 4967 offers precious little guidance as to exactly what sorts of DAF distributions may be treated as conferring a taxable benefit upon the "advising" donor or related parties, or precisely what sorts of benefits will be treated as involving a direct or indirect benefit that is more than an incidental benefit. While this might be construed as a drafting oversight, it's probable that the danger category was intentionally left vaguely defined. Presumably, the purely psychological rewards to a donor who feels good about advising a DAF grant are not enough by themselves to trigger the new tax, and are "incidental." Would the benefit of being able to brag to friends, neighbors and business associates be sufficient? Probably not, though it is conceivable that a business owner's use of the DAF distribution to boost the business's goodwill or prestige and to help it in the marketplace in general or in a pending transaction specifically, might just possibly be enough. Hopefully, authoritative guidance will emerge quickly on this key issue; without it, virtually any DAF distribution might conceivably trigger the new tax, and this uncertainty could prompt some DAFs, their donors and their sponsoring charities, to refrain from making DAF distributions altogether, which would defeat other goals of the new legislation.
Application of excess benefit transactions tax to DAFs: PPA Section 1232 extends the IRC Section 4958 tax on excess benefit transactions" expressly to DAFs. Two new subsections are added to the IRC Section 4958(f) definition of the term "disqualified person." The first new subsection adds the category of DAF advisor donors (and their surrogates), as well as family members and 35-percent controlled entities.58 The second new subsection adds the category of investment advisors, their family members, and 35-percent controlled entities.59 An "investment advisor" is defined as any person, other than an employee of a sponsoring organization, who is compensated by the sponsoring organization for managing the investment of assets held in the sponsoring organization's DAFs, or providing investment advice with respect to such assets.60
IRC Section 4958(c) also is amended to add "Special Rules for Donor Advised Funds."61 These new provisions define "excess benefit transaction" to include any grant, loan, compensation or other similar payment from a DAF to an advisor donor or surrogate, family members or 35-percent controlled entities.62 Similarly, the term "excess benefit" is defined to include the amount of a grant, loan, compensation or other similar payment.63
IRC Section 4958(f)(6) defines the terms "correction" and "correct" to mean, as to any "excess benefit transaction," undoing the excess benefit to the extent possible, and taking any additional steps needed to place the organization in a financial position not worse than had the highest fiduciary standards been observed. Under an amendment to this provision, in the case of a correction of an excess benefit transaction involving a grant, loan or compensation to an advisor donor and related parties, no amount repaid in a manner prescribed by Treasury may be held in any donor-advised fund.64 Despite the relative lack of clarity of the drafting (the term "repaid" in the amended language has no referent in the older language in IRC Section 4958(f)(6)), this appears to mean that, if an excess benefit in the form of a grant, loan or compensation is repaid to the sponsoring organization, it cannot be placed back into the DAF (or any other DAF). This is presumably designed to help avoid the temptation to repeat the excess benefit transaction by the same donor from the same (or another) DAF, at least as to that particular amount that is repaid.
These new DAF excess benefit transaction provisions apply to transactions occurring after Aug. 17, 2006.65
Application of excess business holdings tax to DAFs: IRC Section 4943 imposes an excise tax on the excess business holdings of a private foundation. To summarize: a private foundation's ownership interest in a business enterprise that, when added to the holdings in an enterprise owned by disqualified persons, exceed 20 percent of the ownership of the enterprise, constitute excess business holdings.66 A de minimis safe harbor is recognized for a private foundation's holdings of up to 2 percent of the enterprise.67
The PPA amends IRC Section 4943 to treat DAFs as private foundations for purposes of the tax on excess business holdings. Consequently, DAFs now must determine whether their assets include excess business holdings,68 and if so, must divest these holdings down to permissible levels. In applying IRC Section 4943 to DAFs, the term "disqualified person" is defined as an "advisor" donor or surrogate, a family member and a 35-percent controlled entity.69 Some relief from the severity of this extension of the tax on "excess business holdings" is afforded by the provisions relating to the five-year period to dispose of certain holdings, under IRC Section 4943(c).70
These changes apply to taxable years beginning after Aug. 17, 2006.71
Charitable deductions for contributions to DAFs: Anticipating the Treasury's deductibility study, PPA Section 1234 adds new restrictions and limitations on the deductibility of contributions to DAFs under the income, gift and estate tax provisions. For income tax purposes, IRC Section 170(f) is amended to add new IRC Section 170(f)(18), under which deductions for contributions to DAFs are allowed only if certain conditions are met:
The DAF's sponsoring organization must not be a type of organization described in IRC Sections 170(c)(3), (4), or (5).72 This eliminates the deductibility of contributions to DAFs operated by posts or organizations of war veterans or affiliated organizations, by fraternal lodges and similar organizations, or by cemetery companies.
The DAF's sponsoring organization must not be a grant-making Type III SO (but may be an "activities," or "functionally integrated" SO).73
In addition, the taxpayer seeking the deduction must obtain a contemporaneous written acknowledgment from the sponsoring organization that has exclusive legal control over the assets contributed to the DAF.74
Similar new changes are made to the estate tax charitable deduction provisions,75 and to the gift tax charitable deduction provisions.76
These changes to the deductibility of contributions to DAFs apply to contributions made after 180 days following Aug. 17, 2006.77
Returns and applications of sponsoring organizations: The PPA amends IRC Section 6033 to provide for additional requirements relating to the annual returns filed by sponsoring organizations. The returns must meet these new requirements:
they must list the total number of DAFs owned by the sponsoring organization at the end of the taxable year;
they must indicate the aggregate value of assets held in the DAFs at the end of the taxable year; and
they must indicate the aggregate contributions to and grants from the DAFs during the taxable year.78
These changes apply to returns filed for taxable years beginning after Aug. 17, 2006.79 Presumably, the Service will revise Form 990 before 2007.
Finally, as to applications filed for recognition of tax-exempt status of sponsoring organizations, such organizations now are required to give notice to the Treasury (in the manner that the Treasury has provided) as to whether the organization maintains or intends to maintain DAFs, and the manner in which the organization plans to operate the DAFs.80
These changes apply to organizations applying for tax-exempt status after Aug. 17, 2006.81 Form 1023 will be revised to request this additional information.
- "Tax-Exempt Organizations: Collecting More Data on Donor-Advised Funds and Supporting Organizations Could Help Address Compliance Challenges," United States Government Accountability Office Report to the Chairman, Committee on Ways and Means, House of Representatives (July 2006), p. 6 (GAO Report).
- GAO Report, at p. 1.
- See, for example, Fund for Anonymous Gifts v. Internal Revenue Service, 194 F.3d 173 (DC Cir. 1999); Private Letter Ruling 200037053 General Counsel Memoranda 39875.
- See, for example, Treasury Regulations Section 1.170A-9(e)(11).
- See Internal Revenue Code Section 170.
- For example, charitable remainder trusts (CRTs) and, more recently, supporting organizations (SOs), come to mind as having fallen within this unfelicitous category.
- See IRC Section 170(b)(1)(A)(iv).
- For a good discussion of these and other DAF concerns, see Bruce R. Hopkins, The Law of Tax-Exempt Organizations, John Wiley & Sons (8th ed. 2003), at pp. 307-17.
- See IRC Section 501(c)(3).
- See, for example, IRS Exempt Organizations Continuing Professional Education (CPE) Text for Fiscal Year (FY) 2000,
- Part P, 2C; IRS Exempt Organization CPE Text for FY 2001, Topic G(3), at pp. 143-44.
- GAO Report.
- GAO Report, at p. 26.
- GAO Report, at p. 27.
- GAO Report, at pp. 27-28.
- GAO Report, at p. 35.
- GAO Report, at p. 1.
- GAO Report, at p. 1.
- GAO Report, at p. 1.
- PPA, Section 1226(a)(1).
- PPA, Section 1226(a)(2).
- See IRC Section 4942(e).
- PPA Section 1226(a)(3).
- PPA Section 1226(b).
- New: IRC Section 4966(d)(2)(A).
- New: IRC Section 4966(d)(2)(B)(i).
- Presumably in the case of a sponsoring organization organized as a charitable trust rather than as a nonprofit corporation, it is the trustee or trustees that are to approve of this procedure.
- New: IRC Section 4966(d)(2)(B)(ii).
- Under IRC Section 4945(g), these grant making procedures are demonstrated to the satisfaction of the Service to constitute either: (1) a scholarship or fellowship grant to be used for study at an educational institution described in IRC Code Section 170(b)(1)(A)(ii), a prize or award subject to IRC Code Section 74(b) if the recipient is selected from the general public or a gr ant made to achieve a specific objective, produce a report or improve or enhance a literary, artistic, musical, scientific, teaching or similar capacity, skill or talent of the grantee.
- New: IRC Section 4966(d)(2)(C).
- New: IRC Section 4966(d)(1).
- New: IRC Section 4966(d)(3)(A).
- New: IRC Section 4966(d)(3)(B).
- New: IRC Section 4966(a)(1).
- See IRC Sections 4941-4945.
- New: IRC Section 4966(a)(2).
- New: IRC Section 4966(b)(1).
- New: IRC Section 4966(b)(2).
- IRC Section 170(c)(2)(B) lists "religious, charitable, scientific, literary, or educational purposes, or to foster national or international sports competition… or for the prevention of cruelty to children or animals."
- New: IRC Section 4966(c)(1).
- IRC Section 4945(h).
- New: IRC Section 4966(c)(2).
- New: IRC Section 4966(d)(4)(A)(i).
- For a discussion of these and other aspects of the treatment of supporting organizations under the PPA, see Gerald B. Treacy, Jr., "What's Left of SOs?" Trusts & Estates (October 2006), pp. 28.
- A Type I SO is one that is operated, supervised or controlled by one or more supported charities; typically this variety is characterized by the right of the supported charities to designate a majority of the members of the SO's governing body.
- A Type II SO is one that is supervised or controlled in connection with one or more supported charities; this variety is often characterized by having common control exercised by the governing bodies of both the SO and its supported charity; it is relatively uncommon.
- New: IRC Section 4966(d)(4)(A)(ii).
- PPA, Section 1232(c).
- New: IRC Code Section 4967(a)(1).
- Act, Section 1232(a)(2).
- New: IRC Code Section 4958(f)(7)(B).
- New: IRC Code Section 4958(f)(7)(C).
- New: IRC Code Section 4967(a)(2). Apparently this secondary tax would not apply to a fund manager who did not actually know, but reasonably should have known, that the distribution would confer the taxable benefit.
- New: IRC Code Section 4967(b).
- New: IRC Code Section 4967(c)(1).
- New: IRC Code Section 4967(c)(2).
- Act, Section 1231(c).
- IRC Section 4958(f)(1)(D), added by PPA Section 1232(a)(1). See IRC Section 4958(f)(7), added by PPA Section 1232(a)(2).
- IRC Section 4958(f)(1)(E), added by PPA Section 1232(a)(1). See IRC Section 4958(f)(8), added by PPA Section 1232(a)(2).
- IRC Section 4958(f)(8)(B), added by PPA Section 1232(a)(2).
- PPA Section 1232(b)(1), adding new IRC Section 4958(c)(2).
- New: IRC Section 4958(c)(2)(A).
- New: IRC Section 4958(c)(2)(B).
- IRC Section 4958(f)(6), as amended by PPA Section 1232(b)(2).
- PPA Section 1232(c).
- IRC Code Section 4943(c).
- IRC Code Section 4943(2)(C).
- IRC Code Section 4943(e)(1), added by PPA, Section 1233(a).
- IRC Code Section 4943(e)(2), added by PPA, Section 1233(a).
- PPA Section 1233(a).
- PPA Section 1233(b).
- IRC Code Section 170(f)(18)(A)(i), added by PPA Section 1234(a).
- IRC Section 170(f)(18)(A)(ii), added by PPA Section 1234(a).
- IRC Section 170(f)(18)(B).
- IRC Section 2055(e)(5), added by PPA Section 1234(b).
- IRC Section 2522(c)(5), added by PPA Section 1234(c).
- PPA, Section 1234(d).
- IRC Section 6033(k), added by PPA Section 1235 (a).
- PPA, Section 1235(a)(2).
- IRC Section 508(f), added by PPA Section 1235(b).
- PPA Section 1235(b)(2).
This should be your immediate response to the sweeping changes imposed on donor-advised funds by the Pension Protection Act
The thousands of donor-advised funds (DAFs) in the nation must consider these eight steps at once. And donors who give to DAFs should ask what's being done.
Until the Treasury study proscribed by the Pension Protection Act is presented on Aug. 17, 2007:
All DAFs should begin making annual distributions of at least 5 percent of the value of their assets. It's unclear whether such payouts ultimately will be mandated. But it's safer for DAFs to embrace this minimum payout requirement now, as a temporary, defensive move.
It also would be prudent for DAFs to immediately limit donor's advice on distribution matters, as opposed to investments.
As for the cloud on deductibility created by the impending study, it would be impractical as well as overly conservative for sponsoring organizations to decline to accept contributions to DAFs for a year, though some may opt for this approach to provide maximum temporary protection against the possible defeat of donors' expectations.
Regardless of the study, DAFs and their sponsoring organizations should promptly take these actions:
Adopt policies to ensure they handle distributions in such a manner that will avoid triggering the new tax on "taxable distributions."
Strive to eliminate the incidence of anything that might look like a "prohibited benefit" to a donor or related party, at least until firmer guidance emerges. No payments to a donor or related party of a grant, loan, compensation, or similar payments should ever be made, to avoid triggering the tax on "excess benefit transactions.")
Review all DAFs' assets quickly to determine whether they have "excess business holdings," and if so, divest these holdings.
Do not make DAF grants to grant-making Type III supporting oranizations; DAFs and their sponsoring organizations will need to adopt a protocol to enable them to identify the precise nature of exemption of grant candidates.
Conform annual returns and applications for new sponsoring organizations fully with the PPA's requirements, even if the Service is not able to develop new forms within the deadlines imposed by the PPA.
— Gerald B. Treacy, Jr.


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Lee Mazin, Dutch ReBelle, Nyemiah Supreme & G.L.A.M. – MTV RapFix Freestyle (Video)
It's Woman's History Month and in honor of the fairer gender, MTV RapFix held down an all-ladies show hosted by their own Nadeska Alexis and featuring appearances by Angie Martinez, Mona Scott-Young, Lee Mazin, Heather B,Read More »
G.L.A.M. – BPH (Video)
G.L.A.M. makes "Beats Per Hour" in her latest visual. Check out the video after the jump as well as her latest EP, The Feel! **Bonus: The Feel EP (Stream/Download)**Read More »


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Cherrytree Records
Your Pop Alternative Source
The Get Deap! EP offers fans their first taste of what's to come on the band's upcoming full-length album, which is near completion and will be released later this year. The EP includes 4 tracks, including the band's debut single single Gonna Make My Own Money, which NME hailed by saying "Deap Vally draws on the unrepentant strut of Ike and Tina and the heavyweight clatter of Led Zeppelin, as…
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Added Apr 29, 2011
Perth, Australia
This is a sample top I made for a friend (that's her in the picture) to test out my newest pattern for my line of maternity sewing patterns.
I love how it turned out – and she is one gorgeous pregnant woman!
I'm having a giveaway over at my blog this week if you'd like to win one – DIY Maternity
Apr 9, 2013, 02.36 PMby leokadia
Ein tolles Shirt für die Schwangerschaft!!
Apr 13, 2012, 07.58 AMby serinekake
May 6, 2011, 11.09 PMby shirosh
Very nice, good work:)
Add to Favorites 13 people added it
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The oversized shape has a cool bell shaped silhouette with a wide body and fitted sleeves
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Sterling Financial Corp. today announced new investments that could fulfill the Spokane institution's need for additional capital.
Thomas H. Lee Partners, which last week committed $134 million to the recapitalization effort, will increase its investment to $170 million.
Sterling said it will also offer, in a private placement, $555 million in common and convertible preferred shares to accredited private investors.
If that offering is successful – a spokeswoman said she could not comment on whether there were buyers for the new stock – the combined investment of $725 million would bring Sterling and its principal subsidiary, Sterling Savings Bank, into compliance with regulatory capital requirements.
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Posts tagged: Ben Wick
The race between incumbent Councilman Richard Rush and former Councilman Mike Allen for Rush's south Spokane City Council seat was sent within recount margins by counting on Tuesday.
Only 92 votes now separate the two, and if the race remains within a half percentage point, it will be recounted by computer. If it gets within a quarter of a percentage point, it will be recounted by hand.
Currently, Allen leads Rush 50.22 percent to 49.78 percent.
There are 369 votes to count. Rush needs to capture about 63 percent of them to win.
Also in Spokane, Proposition 1, the Community Bill of Rights, finally went to defeat on Tuesday. It trails by a little over 1,000 votes. It captured 49.1 percent of the vote. The group that worked to place it on the ballot, Envision Spokane, might consider the neck-and-neck outcome a victory since its first attempt to pass a different Community Bill of Rights was defeated with only 24 percent support in 2009.
The results for Spokane mayor haven't changed much from election night. David Condon had 52.4 percent of the vote to Mary Verner's 47.6 percent after Tuesday's count.
In Spokane Valley, Ben Wick definitively captured a seat on City Council in Tuesday's count. He leads Marilyn Cline by 360 votes. There are only 364 votes left to count in the race.
Countywide, there are about 2,600 votes left to count.
A race for Spokane City Council inched closer to an automatic recount on Monday in the fourth day of ballot counting from the Nov. 8 election. Former Councilman Mike Allen's lead over incumbent Richard Rush for a seat representing south Spokane fell by 17 votes to 135.
There are about 1,143 votes left to count in the contest, and if it tightens to within a half percentage point, an automatic computer recount will occur. Allen currently has 50.33 percent to Rush's 49.67 percent.
Spokane Proposition 1, the Community Bill of Rights, appears to be headed to defeat after the fourth day of counting. It lost ground and is trailing by 1,013 votes with 2,777 left to count.
In Spokane Valley, Ben Wick's lead over Marilyn Cline for City Council position 6 grew to 354 votes. There are 1,120 votes left count.


text: Also has smoked tail lights and clean, clear blackout headlights, or halo projector headlights.(can choose either set of headlights) Has a nice aftermarket sound system with a amp and 10inch subwoofer and pioneer 6x9 speakers inside which are wired to the amp and has a aftermarket radio with a AUX port. Car sounds awesome! Has 150k miles on dash but engine and trans I got from a GS with 100k and changed the timing soon after. I do have the receip for the timing but I lost most of the other ones. Has a nice clean interior and is tinted about 25% all around and on sunroof. Also car is tagged 12/12 . Nothing at all is wrong with this car. Runs and drives perfectly. Price is 3200 obo but im very negotiable contact me and let me know I'm negotiable but depending on offer depends on what I take out. reason for selling is becuz i want either a gst/gsx or a maxima or 98+ passat Also have 2 white fenders left and right side for sale for $30 obo and a set of 400+400w pyramid 6x9 speakers for sale I want like $100 obo they are brand new and cost way more.. and a 500w legacy 2 way amp used but still works great.. best offer on everything Contact me asap if interested. Names andy 267-506-4702 the car had a problem before but i fixed it just needed the clutch fluid line bleed, nothing big and has already been taken care of


text:
Jason Kint
Revolving Door (0)
Sightings (5)
Facebook Likes Publishers, But Will They Like It Back? - Posted November 10, 2014
Facebook has been working on improving ... [AllFacebook]
SBJ Unveils 2011 '40 Under 40.' Which Media Execs Made the Cut? - Posted March 21, 2011
One of Sports Business Journal's most hotly-anticipated features was released this week, with the publication of the trade magazine's annual "40 under 40" list (subscription required). The list ranks 40 sp... [SportsNewser]
South Carolina @ No. 2 Ohio St. to Tip Off CBSSports.com, CBS Sports Mobile College Basketball Live - Posted December 15, 2010
Select college-basketball games from the Big East, Big Ten, and Southeastern Conference will once again be live-streamed by CBSSports.com and CBS Sports Mobile, starting with the 2010-... [WebNewser - SocialTimes.com]
'FarmVille Meets Fantasy Sports:' CBS Takes Fantasy Football to Facebook - Posted August 30, 2010
CBSSports.com has long had its own fantasy football league, but now the company is expanding its fantasy presence to a new platform: Facebook. The network is launching "Franchise Football," a new variation of fantasy football, which will be available exclusively on the social networking site. Calling it "... [SportsNewser]
CBSSports.com Signs Steve Nash To Cover FIFA World Cup - Posted June 2, 2010
CBSSports.com has added NBA superstar Steve Nash to its roster. Nash will be traveling to South Africa to cover the 2010 FIFA World Cup for the sports site. The basketball player will file eight video reports for CBSSports.com ... [WebNewser - SocialTimes.com]


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A collection of
Espresso based
ultimate recipes
A grand classic prepared just right – unadorned and simple, allowing the purity of the ingredients to fully express themselves.
Prepare 2 capsules of Grand Cru Ristretto or Indriya from India in espresso (40ml).
Pour the coffee, cold milk and ice cubes in a tall glass.
Add ice cubes or crushed ice and stir well.


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Cameras Ready For Jewel The Bear To Give Birth
January 15, 2012 7:49 PM
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MINNEAPOLIS (WCCO) – A family of Minnesota bears that's been getting a lot of attention is preparing for another big debut on the web.
Remember Lily?
She's the black bear who gave birth to a cub named Hope in 2010. The Wildlife Research Institute in Ely said Lily's younger sister, Jewel, is pregnant.
Researchers say she could give birth any day now. They've rigged up her den with web cams. This is the third year the North America Bear Center has broadcast from bear dens.
To see Jewel's den, click here.


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Leading Travel Document Expediting Service Sites RushMyPassport.com And RushMyTravelVisa.com Expand Fast-Tracking Passport And Visa Solutions To Entire Travel Industry
"We make it easy for our affiliates with no special training required because our highly skilled document specialists work directly with the affiliate's customers. We provide professional customer service and complete step-by-step instructions for preparing their Passport and Entry Visa Documents." Brezenoff also said, "Our Affiliate Program offers top industry commissions and or specially reduced corporate pricing, account management tools, customized co-branded web pages, real-time client and commission tracking software, web services for Enterprise Integration and free banners and links for travel-related websites."
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Please. dont put gel/mousse/cream/wax whatever you decide, in your hair to go the gym. sick of guys pi$$ing around with their hair instead of gettin down to it.
your face would suit a clean cut high...
Type: Posts; User: Petey1; Keyword(s):
Please. dont put gel/mousse/cream/wax whatever you decide, in your hair to go the gym. sick of guys pi$$ing around with their hair instead of gettin down to it.
your face would suit a clean cut high...
Amateur Boxing status : retired
i also have a 2nd Dan Black Belt in FSK Freestyle
use a disc from the stack and clasp it to your chest
i would also be interested to know what has prompted this desire to gain so much so quickly?
are you in an open class of fighting weight and your fighting much bigger guys?
just asking as that...
try using the EZ bar so the bend in the bar misses your under carriage
do dumbell shrugs from your sides
thanks a lot for this.
i wont beat myself up quite as badly after each session then..
i am on a cut at the moment and am finding that limiting my food is seriously affecting my lifting is this normal does anyone else experience this.
i am eating good macro's and on WBB1, so resting...
do you know if you are performing the exercises correctly.?
my shoulders used to crack doing oh presses but i adjusted my form
just a thought?
have a look at this
he meant that turnip gave you the answer but you didnt pick up on it thats all.
i wasnt been cocky with you but your question was
'what kind of gains could i expect by mid november which is when i go to p.r for a couple months"
to be able to give you a better answer we...
from the info youve given us id say youd gain somewhere between nothing and absolutely loads..
how you doin?
looks good - you got all the main exercises in there doing squats, deads and benching. youve got rest days in between those core sessions.
I would say yes youve got enough isolation...
i used to box from an early age, and so was very confident of my ability. however, what we do is not normal, so your body is preparing you.
the older i got the more nervous i became as reality...
i think what your asking is:-
do you train if you are still sore from the previous workout?
let us know what your program is then we can help.?
for all we know you could be training the same...
haemorrage in your eye, bites on your bicep - !
remind me to decline a nght out with you and your mates.
go to get it checked, from what you have said you could have a golf ball under your...
OK then..................erm...!!!!!!!!!??????
maybe not but i feel as if im being challenged if im on a limit.
im not talking about running round like a knob, losing form etc..
but just think your body will respond better to the increased...
hi there.
although very different sports i am from a boxing background.
i was just over the heavyweight (lower) limit and so was fighting guys bigger than me a lot of the time.
so i faced the...
exactly the same happened to me on monday. same routine (WBB1)
energy levels low, hard day at work, maybe ate a little to late..
also you didnt mention if you are changing round your routine within...


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Anji Mountain AMB0453-0 Gray Paper Shag Area Rug
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Gray Paper Shag Area Rug
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text: Next → 1901 and 1905: From the Unexpected to the Highly Celebrated Inaugurations of TR ← Previous Miller Center Panel: Immigration Reform Needed if U.S. to Compete in Global Battle for Talent, Ideas You might also like... Book Review: The End of Greatness (10/09/14) POTUS at Play (08/13/14) Reagan Officials Reflect on KAL 007 (07/18/14) Friday Feature: President Coolidge Not Riding a Tiger (08/30/13) Friday Feature: President Taft Not Riding a Tiger (08/23/13) Presidential Speech Archive American President: A Reference Resource Presidential Recordings Presidential Oral Histories ← Return to Riding The Tiger December 21, 2012 By Amber Lautigar Reichert Friday Feature: Reagans Riding the Yuletide Tiger In the spirit of Nancy Reagan and whoever might be under that beard, best wishes for a joyous and safe holiday. Stay tuned! Every Friday we'll highlight an interesting item from presidential history. Tweet Comments Rules for Comments We reserve the right to remove any post or user. Things that will get comments edited/deleted: Offensive or abusive language or behavior Misrepresentation (i.e., claiming to be somebody you're not) – using a "handle" is fine as long as it isn't offensive, abusive, or misrepresentative Posting of copyrighted materials Spam, solicitations, or advertisements of any kind We hope these rules will keep the discussion lively and on topic. Commenting is not available in this channel entry. ← Return to Riding The Tiger


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text:
I am also looking for this hat and glove patten. Did you ever find it? thanks, Joanne
No I never did find a pattern that was identical to the type I wanted, so ended up purchasing it for my daughter.
i found the exact hat. It was not a pattern. the person bought it from www.Breckenridge Hat Company. Looks like she didn't make it after all, she bought the hat and gloves, them posted that she made it herself. :(
Did you try Ravelry.com? I posted a link earlier in this thread to a similar hat on there, but there are several others as well.
I am also looking for a sock monkey hat with earflaps. Has anyone found on e yet?
I have found a few and some with ear flaps. I just googled Sock Monkey Hats, I also googled "hats". I still haven't located the one that I want, but these will work. Check out all the crochet and knitting sites.
I know I'm a little behind on this one, but this one might do for the sock monkey hat pattern you are looking for http://www.etsy.com/listing/76033149/cheeky-sock-monkey-hat-with-earflaps
Here's the pattern I think people are looking for.
if you cant find this pattern, i think you'll have to check the web for free pattern exactly what your trying to find.
Some site gives some patterns for free....
Hope you'll find it...
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text:
Many vital decisions, including the party's stand on alliance for the Assembly elections, may be taken at the Desiya Murpokku Dravida Kazhagam's People's Rights Retrieval Conference here on January 9.
Turning point
Party founder and actor Vijayakant, according to his wife and women's wing leader Premalatha, will consult the cadre before announcing the decision on alliance at the conference. After inspecting work at the venue, she said that after the 2005 Madurai conference, the present one at Salem would be a turning point for not only the DMDK but also Tamil Nadu politics.
The conference would be a prelude to a "change in the State," and would pave the way for emancipation of Tamils who "are languishing in darkness at present."
The massive podium of the one-day conference is coming up in Veerasamy Pudur village.
Keywords: DMDK conference


text:
A reader sez:
You ought to get a discussion going about the new Terminator movie. I saw it yesterday and it was actually quite good. I had this opinion formed before I read the review on Decent Films or the Bishops movie page. I must say that I think Steve's review was right on. I think this movie was actually better than Matrix Reloaded. I also think, like Steve, this series is ripe for a few more movies – though I betting they won't involve ah-nold. There were a lot of spiritual overlays and juxtapositions within the movie. Some of them I won't recognize until I see the movie again. Not quite sure how the Bishops can give this one an "O" and not give the Matrix Reloaded's (with its group sex orgy) an "A-IV". The Bishops' must have a different view of the world than I do.
Haven't seen it yet, but I mean to. One of the most unintentionally hilarious moments in all cinema history is the Big Speech in T2 where Linda Hamilton lectures us on Evil Violent Man and His Machines vs. Life-Giving Womb Woman (as she's standing over the guy whose house and person she has just riddled with bullets). For sheer unconscious Hollywood Deep Think sanctimony and hypocrisy, it's a scene without peer. I can't watch it without dissolving in laughter. The first time I saw it, we rewound the tape and played the scene again, nearly wetting ourselves with uncontrollable gales of mirth.


text:
Summer Broccoli Slaw Salad
Well, summer is officially here! Jesse and I enjoyed the summer solstice by taking a nice stroll up to the Mississippi area and finding an outdoor patio to enjoy a couple happy hour cocktails. Once we walked back home, it was time to start dinner. I didn't want to fuss with much and already decided prior we would have chicken breast and garlic scapes, but wanted a refreshing side salad to go with it. Luckily, I almost always have a bag of broccoli slaw in my fridge. Seriously, I love this stuff and its versatility. It works well for hot dishes or cold, and is one of my favorites in a veggie and meat sauté.
Normally, I think salads like this taste better the next day, but Jesse and I both liked it better the day I made it, after letting it marinate for about 20 minutes. It still tasted good the next day, but was a bit more mustardy tasting from the Dijon. It was more subtle on the day I made it and I guess we both liked it better that way.
- 3 Tbsp extra virgin olive oil
- 1 Tbsp white wine vinegar
- 1/2 Tbsp Dijon mustard
- 1 tsp raw honey
- Pinch of cayenne pepper
- Pinch of granulated garlic
- Sea salt and pepper to taste
- 12 oz bag broccoli slaw
- 1/2 large or 1 small avocado, sliced
- 2-3 chopped green onions, optional
- Pour the broccoli slaw in a large bowl.
- In a separate small mixing bowl or dressing shaker, combine all the remaining ingredients, except the avocado and green onion. Mix well with a whisk or shake well if using a dressing shaker. Taste and adjust seasoning as desired.
- Pour dressing over the broccoli slaw and stir well. Add the avocado slices and chopped green onions, if using. Allow to marinate in the refrigerator 15-20 minutes. Serve with something grilled!
Yields: 4-5 side dish servings
3 responses to "Summer Broccoli Slaw Salad"
Paula says :
I love broccoli slaw and just bought a bag yesterday! I usually go with a mustard based dressing too. if I have homemade mayo on hand I mix that with the mustard but my other favorite is an Asian style dressing (sesame oil, coconut aminos, coconut or brown rice vinegar and even some of that mayo). Broccoli slaw is so convenient and versatile–it's a weekly grocery item for me
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Reviews for GMC Sierra 1500 years:
Owners' Reviews
2008 GMC Sierra 1500 Reviews and Owner Comments
4 ReviewsWrite Your Review
Overall Score (4 reviews)
2008 GMC Sierra 1500Visitor, Lepanto, AR, February 11, 2013 07:03its a great truck but only one problem! the wires for the headlights on the sierra always get shorts in them and everytime u get going down the road one is out!!!
2008 GMC Sierra 1500Visitor, Groves, TX, September 12, 2012 20:45I had the truck less than a yr and the transmission went out. A yr later the vent valve assembly and solenoid had to be replaced and moved and it was under warranty and still cost me over $300 to get it fixed. Now 2 yrs later the check engine light comes on and guess what its the vent valve assembly and solenoid again. Wow Chevy/GMC really use to mean quality but really not thinking so now. Previous 4 trucks were all Dodges and never had any issues!!! Looks like I'll be going back to the RAM soon!!!!
2008 GMC Sierra 1500Bassman0311, Benton, AR, February 21, 2011 15:40Transmission had to be rebuilt at 10K and again at 20K miles. No known "fix" for the problem. This truck is pampered and gets only 7K miles a year of driving. Professional Grade... Not hardly.Rookie
2008 GMC Sierra 1500Visitor, Camp Lejeune, NC, July 28, 2010 07:04love this truck no problems!!!


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Yea, I was wondering this. Anyone have any idea how much percent of your body weight you'd be pushing when you're doing pushups with perfect form? I tried using a scale, and it came out to 140, and I weighed 200 at the time. so that's 70%. But I could do 30 reps, and when I bench, i can only do 140 for 12 reps.
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text:
Seaweeds of the West Coast
with instructor Dr Bridgette Clarkston
July 11-13, 2014
Tofino, BC
This 3-day field course, based out of the Tofino Botanical Gardens, will introduce participants to the wonderful world of West Coast Seaweeds.
Topics to be covered:
• Introduction to seaweeds - what are they, and what is their role in coastal ecology?
• Biodiversity and ecology of west coast seaweeds
• Essentials of collecting and identifying seaweeds in the field
• Seaweed foraging and the relationship between seaweeds and people
• Pressing and preserving seaweeds
Friday, July 11th
Evening (7:30 - 9:00 pm) - Introductory presentation: An overview of west coast seaweeds, different seaweed groups, role of seaweeds in coastal marine ecosystems.
Saturday, July 12th
Morning (7:30 - Noon) – Field trip to explore seaweeds on Tofino's rocky coast and practice naturalist skills, including fundamentals of seaweed identification. Collection of seaweeds at field site - bring journals and cameras to record habitat info.
Afternoon (1:00 - 5:30 pm) – Seaweed identification and pressing workshop. Practice using dichotomous keys, field guides and online databases to identify unknown specimens. Create your own scientific and artistic seaweed presses.
Evening Presentation (7:30 - 8:30 pm) – Seaweeds and people: from traditional uses to modern foraging, and everything in between
Sunday, July 13th
Morning only (7:30 am - 1:00 pm) – Putting it all together: field trip to identify seaweeds and their communities in nature, including opportunities to share what you've learned with the group. Group lunch and course wrap-up.
About the instructor:
Dr Bridgette Clarkston is a seaweed biologist and science education consultant with Experience-Based Education. Her interests include seaweed biodiversity, outdoor education, science communication and photography. Connect with her on Twitter (@funnyfishes) and her website (bridgetteclarkston.com)
Course Registration is $240 per person (incl.tax), including breakfast & lunch on Sat. and Sun.


text:
Iraq Wars I and II were immoral for many reasons, and Iraq War III would be immoral for many reasons as well. One often-forgotten reason that Iraq War III would be immoral is because it is unwinnable. (Iraq Wars I and II were unwinnable and has already been lost. If Iraq War I had been won or winnable, a ten-year post-war starvation campaign against Iraq would not have been necessary.) But one central tenet of Just War theory is that war can only be justified if there is a reasonable chance of actual victory. That is, in order for war to be justified at all, there must be a clear wrong that needs righting, and the party proposing to solve the problem needs to have legitimate authority to do so.
Obviously, there is something wrong in Iraq, and some of that is thanks to the US government in the first place. But the US government does not have legitimate authority to invade a country on the other side of the planet that is no threat to the US. But even if it did have legitimate authority in this case, any moderately well-informed person can see that any US intervention in the conflict is unwinnable.
Just War Theory contends that war is unjust if unwinnable because, of course, to undertake an unwinnable war is to do nothing less than kill people for no reason at all. Everyone who died in the Iraq War died for nothing, and completely in vain. A new war there would be equally unwinnable. An unwinnable war cannot be morally fought, and under Just War Theory, it is better to let an evil endure than to add additional evils by waging a futile war in the name of righting it.
(I should note that Just Way Theory is too pro-war for my tastes, but since I'm such a reasonable fellow, I'll meet the war enthusiasts half-way on this one.)
John Zmirak, who has it out for libertarians, but often gets many things right, sums up the situation here:
10:28 am on June 19, 2014
I said so at the time, and I wish to say so again. Leave aside the vanishing "weapons of mass destruction" that provided the pretext for war. The reason we waged that war was simple and strategic: We saw in Iraq an unpredictable enemy whom we could not control, and we wished to replace its government with a friend whom we could. Nor were we satisfied with replacing one secular Arab tyrant with another — a project that might have succeeded. No, the neoconservatives who provided the brains of the Bush administration considered such "realist" goals petty and uninspiring.
These thinkers dreamed big: They called on Americans to transform the entire Middle East in our own self-image, to change the course of a 1300-year-old political culture in the Muslim world, seeding it with one tolerant democracy after another, until we had removed every grievance that produced religious extremism and terrorism, so there would never again be another attack like the one on September 11, 2001. One might as well respond to the next mass shooting by a maniac in America by dumping Prozac into the water supply, and confiscating every gun in the country…
We literally cannot win, which means that we should not fight — or even take sides in this fight. We have no more stake in which intolerant Muslim faction prevails in Iraq than we do in the intra-party struggles in Communist China. Any war which we launched to meddle in the Middle East would fail at least one criterion for a just war: It would have no solid prospect of success. It would be as futile as Guy Fawkes' bombing of Parliament, or a vigilante attack on an abortion clinic.Because it would be unjust, it would be sinful. And so Christians should oppose it — on principle.