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Munenori Kawasaki Rumors
Blue Jays Notes: D'Backs, Neshek, Gregerson
Here's the latest from Toronto…
- The Blue Jays asked the Diamondbacks about both left-hander Wade Miley and outfielder Mark Trumbo earlier this winter, Bob Elliott of the Toronto Sun reports. Arizona, in turn, asked for some of the Jays' young pitching in return. Interestingly, the Jays didn't plan on keeping Trumbo, but rather flipping him to the Mariners for Michael Saunders, a player Toronto landed anyway by dealing J.A. Happ to Seattle.
- Also from Elliott, the Jays have looked into signing free agent relievers Pat Neshek and Luke Gregerson. Sportsnet.ca's Shi Davidi also notes that the Astros and Yankees are among the other clubs interested in Gregerson's services.
- The Blue Jays are one of three teams who have spoken to veteran reliever Kyle Farnsworth, Davidi reports.
- Munenori Kawasaki has looked into options in Japan and may now be considering returning in North America on a minor league deal, according to Davidi. The Blue Jays would seem to be natural candidates to bring Kawasaki back, though manager John Gibbons wasn't sure what was going on between the team and the infielder.
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Full Story | Comments | Categories: Arizona Diamondbacks | Houston Astros | Kyle Farnsworth | Luke Gregerson | Mark Trumbo | Munenori Kawasaki | New York Yankees | Pat Neshek | Toronto Blue Jays | Wade Miley
Blue Jays Notes: Martin, Kawasaki, Phillies
The Blue Jays are in on several top free agents as the offseason kicks off. They'll meet with Pablo Sandoval's agent Gustavo Vasquez today, according to Shi Davidi of Sportsnet.ca. Reps for Victor Martinez spoke to the Jays recently, and there's reportedly a meeting on the books with Russell Martin's agent as well. Further details on Canada's team…
- Blue Jays GM Alex Anthopoulos preached flexibility yesterday. According to Davidi, Anthopoulos said, "We're going to try to take the best player available, and we're not locked into one thing, like we need a defender at first base, we need a pure DH. It depends on what becomes available to us." Edwin Encarnacion can be deployed at first base or DH, while third base could be opened up by using Brett Lawrie at second.
- Martin, a Canada native, turned down the Blue Jays before the 2010 season because the Yankees offered more playing time behind the plate, according to Davidi. Davidi feels that of all the Blue Jays rumors, Martin may be the one with the most substance.
- The Jays are looking at Anthony Gose and Kevin Pillar in center field next year, barring a trade.
- Infielder Munenori Kawasaki is leaning toward a return to Japan, but Davidi says he might be swayed by a Major League contract.
- The Jays called the Phillies about Cole Hamels, Chase Utley, and Antonio Bastardo, according to Bob Elliott of the Toronto Sun.
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Full Story | Comments | Categories: Antonio Bastardo | Chase Utley | Cole Hamels | Munenori Kawasaki | Pablo Sandoval | Philadelphia Phillies | Russell Martin | Toronto Blue Jays | Victor Martinez
Blue Jays Outright George Kottaras
The Blue Jays announced that they have outrighted catcher George Kottaras off the 40-man roster and officially announced the outrights of Munenori Kawasaki and Dan Johnson, both of which were made known earlier in the week.
Kottaras, 31, batted a strong .233/.351/.533 with three homers in 38 plate appearances between the Indians, Cardinals and Blue Jays this season. Two of those homers came as a member of the Indians in his first game of the season.
The journeyman catcher has always shown plus plate discipline and plus power but low batting averages, as evidenced by his .215/.326/.411 career batting line. Kottaras has struck out in 23.7 percent of his career plate appearances, but that number has jumped to 35.3 percent over the past two seasons (164 PA). Defensively speaking, he's thrown out just 18 percent of opposing base-stealers in his career, and pitch-framing metrics haven't been kind to him.
Kottaras and Johnson have both elected free agency, per the Blue Jays, while Kawasaki has yet to do so. Brendan Kennedy of the Toronto Star tweets that Kawasaki will likely do the same thing that he did last offseason: seek a Major League deal elsewhere but return to the Blue Jays as a minor league free agent if he is unable to find one.
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Full Story | Comments | Categories: Dan Johnson | George Kottaras | Munenori Kawasaki | Toronto Blue Jays | Transactions
Blue Jays Outright Munenori Kawasaki, Dan Johnson
The Blue Jays have outrighted infielder Munenori Kawasaki and first baseman Dan Johnson, according to the team's official transactions page.
Kawasaki, 33, batted .258/.327/.296 in 274 plate appearances in his second season with the Blue Jays. The Japanese infielder's outgoing nature and quirky sense of humor have made him popular with both fans and teammates, but he hasn't hit much in either of his two seasons in the Majors. He does grade out as a solid defender at shortstop, and both Ultimate Zone Rating and Defensive Runs Saved gave positive reviews to a small sample of work at third base this season.
The 35-year-old Johnson saw some action with Toronto this season as a replacement for the injured Adam Lind. The AL East veteran (he's also been with the Rays, Orioles and Yankees) batted .211/.333/.342 with a homer in 48 trips to the plate. Johnson posted yet another gaudy OBP total at Triple-A, slashing .232/.381/.434 with 18 homers in 459 PA. In parts of 11 seasons at the Triple-A level, the former seventh-round pick is a .281/.401/.509 hitter, so he should be able to find a home rather easily this winter if he wishes.
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Full Story | Comments | Categories: Dan Johnson | Munenori Kawasaki | Toronto Blue Jays | Transactions
Blue Jays Designate Marcus Walden, Outright Jeremy Jeffress
The Blue Jays have issued a press release to announce a series of roster moves: Right-hander Marcus Walden has been designated for assignment in order to clear a 40-man roster spot for Munenori Kawasaki, who has been promoted to the Majors to take the 25-man roster spot of Maicer Izturis. Izturis, who is most likely out four to six months with a torn LCL, has been placed on the 15-day DL. Additionally, the club announced that right-hander Jeremy Jeffress, who was designated for assignment last week, has cleared waivers and been outrighted to Triple-A Buffalo.
Walden, who turned 25 near the end of the 2013 season, began the year at Buffalo but pitched just four innings prior to today's news. The former ninth-round pick allowed six runs in those four frames but posted a strong 3.71 ERA in 162 1/3 innings at Double-A New Hampshire in 2013. Walden misses few bats but has solid command, as evidenced by career ratios of 5.4 K/9 and 2.9 BB/9 in his minor league career.
The 32-year-old Kawasaki appeared in 96 games for the Blue Jays last season, quickly winning over fans and teammates with his quirky personality and his sense of humor. On the field, he batted .229/.326/.308 with a homer and seven stolen bases while appearing at both middle infield positions.
Jeffress has seen MLB time in five seasons, but has never logged more than 15 1/3 innings in any one season. The former No. 16 overall pick (Brewers) has yet to harness his big arm, as his career 6.7 BB/9 tally in the bigs would indicate. He did put up outstanding results last year, as he yielded one earned run with a 12-to-5 K:BB ratio in 10 1/3 Major League innings in addition to registering a 1.39 mark in his 32 1/3 minor league innings (8.4 K/9 against 3.6 BB/9).
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Full Story | Comments | Categories: Jeremy Jeffress | Munenori Kawasaki | Toronto Blue Jays | Transactions
Blue Jays Re-Sign Munenori Kawasaki
The Blue Jays announced that they've re-signed infielder Munenori Kawasaki to a minor league contract with an invitation to Major League Spring Training. Kawasaki is represented by Relativity Baseball (formerly known as SFX).
The 32-year-old Kawasaki batted .229/.326/.308 with a homer and seven stolen bases in 96 games (289 plate appearances) for the Blue Jays in 2013. He appeared at both second base and shortstop, providing Toronto manager John Gibbons with solid defense at each position. Kawaski's big personality made him a favorite both in the Blue Jays' clubhouse and with Toronto's fans.
A career .294/.345/.378 hitter in Nippon Professional Baseball, Kawasaki has batted at a .218/.306/.276 clip in 404 Major League plate appearances between the Mariners and Blue Jays since coming to the United States.
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Full Story | Comments | Categories: Munenori Kawasaki | Toronto Blue Jays | Transactions
Blue Jays Notes: Catching, Arencibia, Kawasaki, Davis
Here's the latest on the Blue Jays, who look set for another busy offseason…
- The Jays have made inquiries about such catchers as Carlos Ruiz, Jarrod Saltalamacchia and A.J. Pierzynski, Sportsnet.ca's Shi Davidi reports. Davidi also suspects Toronto GM Alex Anthopoulos has checked in on Brian McCann, to boot.
- The Jays were known to be looking to improve behind the plate this winter and current catcher J.P. Arencibia has drawn trade interest from other teams. Davidi says there is some feeling that Arencibia has too much "accumulated baggage" in Toronto and might not reach his potential in a Blue Jay uniform. Arencibia is projected to earn $2.8MM as a first-time arbitration eligible player this winter and the Jays would certainly prefer getting something back for him in a trade than simply non-tendering him.
- Ervin Santana, Tim Hudson and Hiroki Kuroda have all received calls from the Blue Jays, Davidi reports, noting that Hudson and Kuroda probably don't have any mutual interest. Hudson is being courted by over 10 teams while Kuroda seems to be set on either re-signing with the Yankees, returning to pitch in Japan or retiring.
- Also from Davidi, Munenori Kawasaki could sign a new minor league deal with the Jays that would pay him more than the $600K base salary he earned last season.
- In another piece from Davidi, Melky Cabrera is looking much healthier and fit after a tumor was surgically removed from his spine, Anthopoulos said. Cabrera looks to be the Jays' everyday choice in left field, though obviously that could change if he suffers a setback in his rehabilitation.
- Rajai Davis is likely to leave the Jays for a team that can offer him more playing time, Davidi reports. The club's hope is that Anthony Gose or Moises Sierra can be a low-cost replacement for Davis as a backup outfielder.
- Sierra is out of options and "is a prime candidate to be shopped," MLB.com's Gregor Chisholm writes. Brad Lincoln could also be part of a trade package, as Chisholm breaks down possible scenarios for the Jays' nine out-of-options players.
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Full Story | Comments | Categories: A.J. Pierzynski | Brad Lincoln | Carlos Ruiz | Ervin Santana | Hiroki Kuroda | J.P. Arencibia | Jarrod Saltalamacchia | Munenori Kawasaki | Rajai Davis | Tim Hudson | Toronto Blue Jays
Blue Jays Exercise Janssen, Lind, DeRosa Options
6:50pm: The Jays have exercised their options on Lind and DeRosa, while declining their option on Kawasaki, Sportsnet.ca's Shi Davidi writes. Lind hit .288/.357/.497 while splitting his time between first base and DH in 2013. DeRosa hit .235/.326/.407 while playing first, second, third and DH. Kawasaki provided a feel-good moment or two for the Jays in a season in which they had very few, but he split his time between Toronto and Triple-A Buffalo and only hit .229/.326/.308 in the Majors. Davidi notes that the Jays could re-sign him to a minor-league deal.
5:04pm: The Blue Jays have exercised their $4MM option on closer Casey Janssen, Chris Cotillo of MLB Daily Dish tweets. Janssen pitched 52 2/3 innings in 2013, posting a 2.56 ERA with 8.5 K/9 and 2.2 BB/9, so the decision was likely a relatively straightforward one. The option came as part of a two-year, $5.9MM deal signed prior to the 2012 season. Janssen made $3.9MM in 2013. He is eligible for free agency after the 2014 season.
The Jays have yet to announce decisions on options for first baseman / designated hitter Adam Lind ($7MM with a $2MM buyout), infielder Munenori Kawasaki ($1MM) and utilityman Mark DeRosa ($750K with a $25K buyout).
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Full Story | Comments | Categories: Adam Lind | Casey Janssen | Mark DeRosa | Munenori Kawasaki | Toronto Blue Jays | Transactions
Quick Hits: Lee, Papelbon, Kawasaki, White Sox, Appel
Jeff Passan of Yahoo Sports runs down the names to watch as the trade deadline approaches in the latest edition of his 10 Degrees column, and the list is topped by Cliff Lee and Chase Utley. Giancarlo Stanton, Andre Ethier, Carl Crawford, Justin Morneau, Jesse Crain, Oliver Perez and Matt Garza also appear on the list, along with Passan's rationale for shopping each. Here's more from around the league…
- Jon Heyman of CBS Sports writes that the price to acquire Lee from the Phillies would be "astronomical," and the same goes for Jonathan Papelbon. General manager Ruben Amaro Jr. told Heyman, "I never say never," but those two would be very difficult to replace. Utley and Michael Young are much more likely trade candidates, opines Heyman, given their impending free agency.
- The Blue Jays' decision on what to do with Munenori Kawasaki following Jose Reyes' return from the disabled list grows more difficult each day, writes Ben Nicholson-Smith of Sportsnet. Kawasaki's popularity among fans and teammates has soared. Mark Buehrle went as far as calling the Japanese infielder one of his favorite teammates of all-time. Kawasaki also has a .341 OBP and is hitting .270/.372/.486 over his past 15 games.
- Both Adam Dunn and Jake Peavy recognize that roster changes are on the horizon for the White Sox if they can't turn things around at the last minute, writes Dan Hayes of CSN Chicago. Dunn added that outside of Chris Sale — whom he said the White Sox would need to receive an entire MLB team to part with — everyone on the team is probably "fair game."
- Mark Appel could make his pro debut for Class A Tri-City in the first week of July, according to Brian T. Smith of the Houston Chronicle. The current plan for Appel is for him to begin a throwing program in Kissimmee, Fla., as he currently hasn't thrown in about three weeks.
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Full Story | Comments | Categories: Chicago White Sox | Chris Sale | Cliff Lee | Houston Astros | Jonathan Papelbon | Mark Appel | Munenori Kawasaki | Philadelphia Phillies | Toronto Blue Jays
Quick Hits: Profar, Rodriguez, Kawasaki, Cubs
The Rangers should seriously consider trading Jurickson Profar, Randy Galloway of the Fort Worth Star-Telegram writes. Galloway argues that, despite Davis' strong 2012 and brilliant start in 2013, he won't criticize Jon Daniels' 2011 trade of Chris Davis (and Tommy Hunter) for Koji Uehara, because the trade was intended to position Texas for a World Series run, and the Rangers did in fact make it to the World Series. If the Rangers can arrange a Profar trade that sets them up for another run at a title, Galloway argues that they should make the deal and live with the results. Rangers assistant GM Thad Levine, however, tells ESPN's Jim Bowden that, while the Rangers will likely be active at this year's trade deadline, they plan to keep Profar, Elvis Andrus and Ian Kinsler, rather than dealing one of them (both links via Twitter).
As a side note, Galloway calls the Davis/Uehara deal "the worst MLB trade of this decade," even though he refrains from criticizing Daniels for it. Uehara was excellent for the Rangers, particularly in 2012, but he's since moved on, and Davis is currently hitting .357/.440/.754 with 20 home runs for the Orioles. Here are more notes from around baseball.
- Yankees GM Brian Cashman discusses Alex Rodriguez's ten-year, $275MM contract in an interview with ESPN's Buster Olney. Rodriguez and the Yankees are currently in the sixth year of the deal, and Rodriguez will make $86MM from 2014 through 2017. Rodriguez has not yet played in 2013. "Alex would even tell you he couldn't live up to [the contract]," Cashman says. "Hopefully he can return to being, at the very least, an above-average player at that position."
- When Jose Reyes returns, the Blue Jays will have to decide what to do with Munenori Kawasaki, Richard Griffin of the Toronto Star writes. Due to the Jays' contractual obligations to Maicer Izturis and the presence of Emilio Bonifacio and Mark DeRosa, there would appear to be no space for Kawasaki once Reyes returns. Griffin suggests that the trade market for Izturis could be better than that of Kawasaki, though the Jays might have to pay some of the approximately $9MM remaining on Izturis' contract.
- Cubs manager Dale Sveum is hoping for an infusion of arms in this week's draft, Fred Mitchell of the Chicago Tribune reports. "Obviously pitching is what you want to get in the organization as much as you possibly can," says Sveum. When the Cubs make the No. 2 overall selection, either Oklahoma's Jonathan Gray or Stanford's Mark Appel, or perhaps both, will still be on the board.
- Twins GM Terry Ryan discusses the role of general managers in the draft in an interview with 1500ESPN's Phil Mackey. GMs generally get credit or blame for their draft picks, but other front office personnel may be more responsible for those picks. "My role would be to take the blame when we don't do well, but I also get the praise when we do well. That's not fair," says Ryan. For example, Ryan discusses his role in the selection of Ben Revere, the No. 28 overall pick in the 2007 Draft. "That's a pick that I got praise for I think at the time. I didn't have anything to do with Ben Revere. (Our scouts) did. They all had seen him a lot. I get the praise. 'Good pick, there you go Terry.' Hell, I never even saw (Revere)."
- Quintin Berry, who was recently designated for assignment by the Tigers, could make it through waivers and wind up back with Triple-A Toledo, MLB.com's Jason Beck tweets. Given that Berry is 28 and has hit just .168/.278/.234 so far for Toledo this season, that seems to be a fairly likely scenario.
- When the Blue Jays begin a series in San Francisco Tuesday night, Melky Cabrera will face Giants fans for the first time since being suspended last August for failing a PED test, MLB.com's Gregor Chisholm reports. Cabrera vanished after receiving word of the suspension, not talking to the San Francisco media. He then signed a two-year, $16MM contract with the Jays in the offseason. Cabrera says he isn't concerned with how the fans will react to his return. "I don't worry about that, it's up to the fans. It's nothing I have control of," Cabrera explains. "I'm just going to play the game. If they decide to boo, that's fine. If they decide to cheer, that's fine with me, too. But, I'm not going to worry about that."
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Full Story | Comments | Categories: 2013 Amateur Draft | Baltimore Orioles | Chicago Cubs | Chris Davis | Detroit Tigers | Jurickson Profar | Maicer Izturis | Melky Cabrera | Minnesota Twins | Munenori Kawasaki | New York Yankees | Quintin Berry | San Francisco Giants | Texas Rangers | Toronto Blue Jays


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It has been 14 years since the release of the hard Christian Rock album "Time Will Tell", and 13 years since the stripped down acoustic Rock album "I Think I Can". I felt I should I should let the Christian community know That I am still alive and well. After my mother passed away of a drug overdose in 1995, I turned my back on Christ. For thirteen years I lived in excess, drug addiction, and drank like a fish. Have been divorced twice, and spent some time in mental institutions, and homeless shelters. I give to you "Red Road" an album that I started writing wile homeless, granted the content is not exactly what we would call totally Spiritually uplifting, but these are songs written and recorded wile God was really tugging on my heart. through it all God has been faithful and full of mercy. I am currently writing a new album, that I believe would make my Heavenly Father proud! The "Red Road" is the beginning, this album is John the baptist in a sense, the voice in the wilderness if you will. God bless you all!
your friend Glenn
2008-10-03 00:36:04

subset: commoncrawl


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How to Make a Barn Cake
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This cake is adorable and makes a great presentation at an outdoor dinner or potluck. This video shows how to create this cake, using cake, ice cream, chocolate-cookie "dirt," and real flowers and gummy worms. Dig in! See more cake decorating ideas and amazing specialty cake videos.


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May 4, 2011
Conversation with freshman Katerina Ruzickova prior to the Aggies' first day of competition at the NCAA West Regional at the Washington National Golf Club in Auburn, Washington.
You thrived in your first conference championship with a second-place individual finish, and now you and your team are getting ready for your first NCAA regional tournament. Are you excited about the challenge you and the Aggies will face in Washington?
KR: "I am very excited about regional tournament. The course is beautiful and we will bring the momentum from Big 12 Championship, especially the last round and we'll be just fine."
Does the regional qualifying format change your mindset since everyone's No. 1 goal is simply reaching the NCAA Championships by finishing in the top eight?
KR: "I don't think so. It's just another tournament on our schedule. We cannot concentrate on outcome, or how the other teams will do. We will stay in process and trust all we do and the rest will take care of itself."
This regional will be the fourth of your teammate Sarah Zwartynski's career. It will be your first. What has she told you about what to expect?
KR: "We did not really have a chance to talk about this. I am so sure Sarah will give her best and enjoy this last regional tournament she will ever play. I will take it as another tournament, do my job to contribute to the team's work and have fun out there."
What do you know about the golf course? What are you expecting with the weather conditions. There's a rumor that it rains a lot in Seattle...
KR: "The golf course is so beautiful, the greens are big and soft, perfect speed as well. It was awesome weather for today's practice round but it supposed to rain in next days. We don't mind rain. We will choose to be positive no matter what the conditions are while the others will complain."
What do you think about the field at the NCAA West Regional? There are several teams that the Aggies have already played against and beaten this year.
KR: "I did look at the field and I think it is awesome chance for us. When we stick to the plan and let the birdies come, we can beat any team in the country."
What the funniest way any of your teammates have mis-pronounced your last name? Are you used to it?
KR: "I am used to it. I think it is really not that hard to pronounce it. You can practice it by pieces.. RU-ZI-KOVA. Julia (Boland) tries hard to say it in Czech and I appreciate it. I think Nat (Reeves) called me RUZAKOVSI or something like that. But overall I appreciate their effort!"
You're from the Czech Republic. You went to high school in Arizona before coming to Texas A&M. What's been the biggest adjustment for you since coming to the U.S.?
KR: "It was very easy for me to adjust to American culture. There is so many opportunities and options here compared to the Czech Republic, however the biggest change for me was the very different education system."
What about Texas surprised you?
KR: "Actually it pretty much fulfills my imaginations. People are super-friendly and open. What is interesting to me is how much people in Texas love to drive the trucks and can't park it any other way than backing up...all the respect to track drivers though!"
There's lot of "celebrities" on the A&M campus these days with the national champions in several sports and people getting drafted high for professional teams. Who among your fellow Aggie athletes do you want to meet the most and why?
KR: "It is awesome to be part of this amazing community of student-athletes. I would love to meet Danielle Adams. I like the way she dominates and nothing will get in her way. Meeting Von Miller would be sweet too! I am personally most inspired by the men's golf team. Jordan Russell's story motivates me much."
Besides your coaches and teammates, who has helped ease your transition in your first year of college at Texas A&M?
KR: "Transition in my first year here at Texas A&M was pretty easy thanks to all the helpful people around. My brother helped me as well even though he was 6,000 miles away."
Besides your family and friends, what do you miss the most about the Czech Republic?
KR: "My Mom's cooking, real traditional Czech food."
Favorite place to eat out at College Station?
KR: Traditions dorms... hah NO WAY! Coach Trelle's house
Describe Coach McCombs in one word: meticulous
Describe Coach Wiese in one word: enthusiastic


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Hi, I'll be heading in from Illinois to Salida for a day in a few weeks. I'm starting out doin some whitewater down at the play park then would like to bike xc for a few hours, followed by a trail run. Pretty much have most of the day, just have to be in Denver that night for a wedding rehersal dinner. So far I've seen some stuff on the board about the Monarch Pass trail. Any other suggestions for a good trail? Not looking to beat myself up with super technical stuff, just wanting to put in a good workout with good scenery. I guess I can run the same trail too, but if you have any suggestions.
After the wedding we'll be in Avon for the next week. Any trails there you can suggest?
Thanks in advance.
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About This Activity
Students will continue their dance experience working through an age appropriate graded tap and ballet system. Students will also learn hip-hop/funk technique; all while dancing to fun and popular music. Class is taught using mirrors to provide students with self-correction opportunities.
Map & Direction
Monday, January 7, 2013
Community Center 1811 Allouez Ave. Green Bay, WI, United States of America 54311Get Directions


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I recently bought a set of the 2007 XTR rapidfire trigger shifters to go with my matching front and rear 2007 XTR derailleurs and noticed an odd behavoir when I shift to a larger rear cog (high normal rear setup) on the right hand shifter. A few times when I shift down (larger rear cog) with the aluminum shift lever (push) it will move say one gear and then break away like something broke inside and not actually move the cable further. Once I release the lever it's fine and operates normally. It has done this two or three times in 4 or 5 hours of riding. Is there a designed in break away feature (due to high loading or something) in the mechanism or is my rear (right side) trigger shifter malfunctioning?
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OMJ Pharmaceuticals, Inc. v. United States of America
Filing 53
OPINION AND ORDER, Granting Summary Judgment for Defendant and Denying Summary Judgment for Plaintiff. Signed by Judge Gustavo A. Gelpi on 10/19/12.(CL) Modified on 10/19/2012 as to title (er).
1 IN THE UNITED STATES DISTRICT COURT 2 FOR THE DISTRICT OF PUERTO RICO 3 4 OMJ PHARMACEUTICALS, INC., 5 Plaintiff, 6 7 v. Civil No. 11-1312 (GAG) UNITED STATES OF AMERICA, 8 Defendant. 9 10 OPINION AND ORDER 11 12 13 14 15 16 17 Nothing is certain except death and taxes. This case tests this theory in a most complicated fashion, at least as it pertains to taxes. OMJ Pharmaceuticals Inc., ("OMJ") brings suit against the United States of America ("USA") seeking a refund of federal income taxes and related interest for the taxable years ending on November 30, 1999 and November 30, 2000. (See Docket No. 1 at 1.) OMJ brings suit pursuant to the Internal Revenue Code of 1986, as amended and codified in Title 26 of the U.S. Code. (See id.) The court has jurisdiction pursuant to 26 U.S.C. § 7422 and 28 U.S.C. §§ 1340, 1346(a)(1). 18 19 20 21 22 23 24 25 26 27 28 Currently before the court are the parties' cross-motions for summary judgment. (Docket Nos. 41 & 42.) OMJ's motion (Docket No. 41) was opposed by USA (Docket No. 43). OMJ filed a reply (Docket No. 49). USA's motion (Docket No. 42) was opposed by OMJ (Docket No. 46). USA filed a reply (Docket No. 50). After reviewing the submissions and pertinent law, the court GRANTS USA's motion for summary judgment at Docket No. 42 and DENIES OMJ's motion for summary judgment at Docket No. 41. I. Standard of Review Summary judgment is appropriate when "the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter 1 Civil No. 11-1312 (GAG) 2 of law." Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). See FED. R. CIV. P. 56(a). "An issue 3 is genuine if 'it may reasonably be resolved in favor of either party' at trial, and material if it 4 'possess[es] the capacity to sway the outcome of the litigation under the applicable law.'" Iverson 5 v. City of Boston, 452 F.3d 94, 98 (1st Cir. 2006) (alteration in original) (internal citations omitted). 6 The moving party bears the initial burden of demonstrating the lack of evidence to support the non- 7 moving party's case. Celotex, 477 U.S. at 325. "The movant must aver an absence of evidence to 8 support the nonmoving party's case. The burden then shifts to the nonmovant to establish the 9 existence of at least one fact issue which is both genuine and material." Maldonado-Denis v. 10 Castillo-Rodriguez, 23 F.3d 576, 581 (1st Cir. 1994). The nonmovant may establish a fact is 11 genuinely in dispute by citing particular evidence in the record or showing that either the materials 12 cited by the movant "do not establish the absence or presence of a genuine dispute, or that an adverse 13 party cannot produce admissible evidence to support the fact." FED. R. CIV. P. 56(c)(1)(B). If the 14 court finds that some genuine factual issue remains, the resolution of which could affect the outcome 15 of the case, then the court must deny summary judgment. See Anderson v. Liberty Lobby, Inc., 477 16 U.S. 242, 248 (1986). 2 17 When considering a motion for summary judgment, the court must view the evidence in the 18 light most favorable to the non-moving party and give that party the benefit of any and all reasonable 19 inferences. Id. at 255. Moreover, at the summary judgment stage, the court does not make 20 credibility determinations or weigh the evidence. Id. Summary judgment may be appropriate, 21 however, if the non-moving party's case rests merely upon "conclusory allegations, improbable 22 inferences, and unsupported speculation." Forestier Fradera v. Mun. of Mayaguez, 440 F.3d 17, 21 23 (1st Cir. 2006) (quoting Benoit v. Technical Mfg. Corp., 331 F.3d 166, 173 (1st Cir. 2003)). 24 "Cross-motions for summary judgment do not alter the summary judgment standard, but 25 instead simply require [the court] to determine whether either of the parties deserves judgment as 26 a matter of law on the facts that are not disputed." Wells Real Estate Inv. Trust II, Inc. v. 27 Chardon/Hato Rey P'ship, S.E., 615 F.3d 45, 51 (1st Cir. 2010) (citing Adria Int'l Group, Inc. v. 28 Ferré Dev. Inc., 241 F.3d 103, 107 (1st Cir. 2001)) (internal quotation marks omitted). Although 1 Civil No. 11-1312 (GAG) 2 each motion for summary judgment must be decided on its own merits, each motion need not be 3 considered in a vacuum. Wells Real Estate Inv. Trust II, Inc., 615 F.3d at 51 (quoting P.R. Am. Ins. 4 Co. v. Rivera-Vázquez, 603 F.3d 125, 133 (1st Cir. 2010)) (internal quotation marks omitted). 5 "Where, as here, cross-motions for summary judgment are filed simultaneously, or nearly so, the 6 district court ordinarily should consider the two motions at the same time, applying the same 7 standards to each motion." Wells Real Estate Inv. Trust II, Inc., 615 F.3d at 51 (quoting P.R. Am. 8 Ins. Co. v. Rivera-Vázquez, 603 F.3d 125, 133 (1st Cir. 2010)) (internal quotation marks omitted). 9 II. 3 Relevant Factual Background 10 A. OMJ's Corporate History as a Section 936 Entity 11 Johnson & Johnson is a U.S. corporation that is the parent company of various subsidiaries 12 that develop, manufacture, and distribute healthcare products in the consumer, pharmaceutical, and 13 medical devices and diagnostics markets. (See Docket Nos. 41 ¶ 1; 43-1 ¶ 1.) OMJ is a Johnson & 14 Johnson subsidiary that manufactures and sells these healthcare products in over 100 countries. (See 15 id.) For decades, U.S. corporations operating in Puerto Rico have received preferential tax treatment 16 as an incentive to locate and operate their businesses in Puerto Rico. (See Docket Nos. 41 ¶ 3; 43-1 17 ¶ 3.) In 1976, a modification to this structure was enacted as part of Section 936 of the Internal 18 Revenue Code ("Section 936"). (See Docket Nos. 41 ¶ 4; 43-1 ¶ 4.) Section 936 allowed a 19 qualifying U.S. corporation to claim a credit for income attributable to its active operations in a U.S. 20 possession, i.e., Puerto Rico. (See Docket Nos. 41 ¶ 5; 43-1 ¶ 5.) This credit could be applied to 21 reduce federal income tax owed by the corporation. (See id.) 22 Since 1976, subsidiaries of Johnson & Johnson have been engaged in manufacturing 23 operations in Puerto Rico, and Johnson & Johnson has claimed credits pursuant to Section 936. (See 24 Docket Nos. 41 ¶ 6; 43-1 ¶ 6.) Johnson & Johnson was conducting manufacturing operations 25 through twelve or more subsidiaries, but in 1993, many of these subsidiaries were consolidated into 26 OMJ. (See Docket Nos. 41 ¶¶ 7-8; 43-1 ¶¶ 7-8.) OMJ is incorporated in Delaware and its principal 27 place of business is Puerto Rico. (See Docket Nos. 41 ¶¶ 10-11; 43-1 ¶¶ 10-11.) For the taxable 28 1 Civil No. 11-1312 (GAG) 2 years of 1993 through 2000, OMJ elected to be treated as a possessions corporation under Section 3 936. (See Docket Nos. 41 ¶ 14; 43-1 ¶ 14.) Between 1993 and 1998, OMJ reported and claimed 4 Section 936 credits for its manufacturing operations based in Puerto Rico. (See Docket Nos. 41 ¶ 5 15; 43-1 ¶ 15.) OMJ conducted the manufacturing operations of Janssen Products ("Janssen"), Ortho 6 Biologics ("Ortho"), Lifescan, Iolab, Orthos Pharmaceuticals ("Lifescan"), and McNeil 7 Pharmaceutical business division ("McNeil"). (See id.) 4 8 In 1996, Congress repealed the tax incentives contained in Section 936, but allowed 9 corporations a ten-year transition period to continue to claim the credits before the repeal took full 10 effect. (See Docket Nos. 41 ¶ 16; 43-1 ¶ 16.) During the transition period, the maximum credits 11 allowed pursuant to Section 936 were capped at the claimant's "adjusted base period income." (See 12 Docket Nos. 41 ¶¶ 17-18; 43-1 ¶¶ 17-18.) It is undisputed that OMJ remained eligible to claim 13 Section 936 credits throughout the ten-year transition period. (See Docket Nos. 41 ¶ 19; 43-1 ¶ 19.) 14 B. 15 OMJ transferred a portion of its assets in Janssen, Ortho, and Lifescan to OMJ Ireland Ltd. 16 ("OMJ Ireland"). (See Docket Nos. 41 ¶¶ 21-22; 43-1 ¶¶ 21-22.) OMJ Ireland is a wholly owned 17 subsidiary of OMJ. (See Docket Nos. 42-2 ¶ 6; 46-1 ¶ 6.) This transfer occurred on November 30, 18 1998 and became effective at midnight on December 1, 1998 (the "1998 Transfers"). (See id.) 19 These transfers took place in two steps. First, OMJ made three transfers. OMJ transferred a portion 20 of its assets in Janssen to Janssen Ortho, LLC in exchange for a 100% membership interest in 21 Janssen Ortho, LLC. (See Docket Nos. 41 ¶ 23(A); 43-1 ¶ 23(A).) Janssen Ortho, LLC became a 22 separate and distinct entity from OMJ for federal tax purposes. (See id.) OMJ transferred a portion 23 of its assets in Ortho to Ortho Biologies, LLC in exchange for a 100% membership interest in Ortho 24 Biologies, LLC. (See Docket Nos. 41 ¶ 23(B); 43-1 ¶ 23(B).) Ortho Biologies, LLC became a 25 separate and distinct entity from OMJ for federal tax purposes. (See id.) OMJ transferred a portion 26 of its assets in Lifescan to Lifescan, LLC in exchange for 100% of the Class A and Class B 27 membership interests in Lifescan, LLC. (See Docket Nos. 41 ¶ 23(C); 43-1 ¶ 23(C).) Lifescan, LLC 28 OMJ Transfers on November 30, 1998 1 Civil No. 11-1312 (GAG) 2 became a separate and distinct entity from OMJ for federal tax purposes. (See id.) Janssen Ortho, 3 LLC, Ortho Biologics, LLC and Lifescan, LLC (collectively "the LLCs") were all formed in 4 September 1998 and had no assets or liabilities prior to the stated acquisitions. (See Docket Nos. 5 42-2 ¶¶ 2-3; 46-1 ¶¶ 2-3.) 5 6 The second part of this transfer also occurred on November 30, 1998, when OMJ transferred 7 its interests in Janssen Ortho, LLC, Ortho Biologies, LLC, and Lifescan, LLC to OMJ Ireland in 8 exchange for 2000 shares of common stock in OMJ Ireland. (See Docket Nos. 41 ¶ 24; 43-1 ¶ 24.) 9 The transfers were considered asset transfers from OMJ to OMJ Ireland. (See Docket Nos. 41 ¶ 25; 10 43-1 ¶ 25.) The parties disagree as to whether any assets retained by OMJ are material for purposes 11 of summary judgment, but the parties do agree that OMJ did not transfer all of its assets to OMJ 12 Ireland through these transfers. (See Docket Nos. 41 ¶ 26; 43-1 ¶ 26.) After these transfers, OMJ 13 continued to manufacture products in Puerto Rico. (See Docket Nos. 41 ¶ 27; 43-1 ¶ 27.) OMJ 14 continued to report and claim Section 936 credits on its U.S. federal income tax returns throughout 15 the ten-year transition period. (See Docket Nos. 41 ¶ 28; 43-1 ¶ 28.) The parties agree these 16 transfers represent a transfer of the major portion of each particular business. (See Docket Nos. 42-2 17 ¶ 7; 46-1 ¶ 7.) 18 Janssen Ortho, LLC, acquired a plant in Gurabo, Puerto Rico, that produced pharmaceutical 19 products. (See Docket Nos. 42-2 ¶ 10; 46-1 ¶ 11.) Janssen Ortho, LLC manufactured seven 20 products, four of which were under contract with OMJ. (See Docket Nos. 42-2 ¶ 12; 46-1 ¶ 13.) 21 Ortho Biologics, LLC acquired a plant located in Manati, Puerto Rico, along with machinery and 22 equipment associated with the plan. (See Docket Nos. 42-2 ¶ 8; 46-1 ¶ 8.) The parties disagree 23 whether Ortho Biologics, LLC acquired certain liabilities from OMJ, such as accounts payable and 24 accrued salary and wages of employees that worked at the plant. (See Docket Nos. 42-2 ¶ 10; 46-1 25 ¶ 10.) Lifescan, LLC acquired a plant in Cabo Rojo, Puerto Rico that produced test strips used for 26 testing glucose levels. (See Docket Nos. 42-2 ¶ 14; 46-1 ¶ 15.) 27 There is considerable disagreement between the parties regarding which entity employed the 28 workers at these plants, which entity was responsible for paying these employees and whether the 1 Civil No. 11-1312 (GAG) 2 LLCs were ever an employer prior to December 31, 1998. (See Docket Nos. 42-2 ¶¶ 15-16; 46-1 3 ¶¶ 16-17.) However, it is uncontested that OMJ charged the LLCs for the wages it paid the workers 4 at the plants and for the amounts it paid for federal employment taxes. (See Docket Nos. 42-2 ¶ 17; 5 46-1 ¶ 18.) The LLCs filed federal employment tax returns for periods beginning in the first quarter 6 of 1999. (See Docket Nos. 42-2 ¶ 18; 46-1 ¶ 19.) The LLCs used the shared services group of OMJ 7 to provide payroll and human resource support. (See id.) 6 8 C. OMJ Ireland 9 OMJ Ireland was incorporated in Ireland in 1998 as a subsidiary of OMJ and has always been 10 a foreign corporation. (See Docket Nos. 41 ¶ 32; 43-1 ¶ 32.) During the relevant time period, the 11 taxable years ending on November 30, 1998, 1999, and 2000, OMJ Ireland was ineligible to claim 12 Section 936 credits and did not become eligible to do so due to the 1998 Transfers. (See Docket 13 Nos. 41 ¶¶ 33-34; 43-1 ¶¶ 33-34.) Whether OMJ Ireland qualified as an existing credit claimant of 14 Section 936 credits is disputed. (See Docket Nos. 41 ¶ 35; 43-1 ¶ 35.) Prior to 1998 and during the 15 relevant years, OMJ Ireland was not subject to the U.S. internal revenue tax contained in Chapter 16 1 of subtitle A of the Internal Revenue Code. (See Docket Nos. 41 ¶¶ 36-37; 43-1 ¶¶ 36-37.) 17 D. Consequences of the 1998 Transfers 18 At this juncture the parties begin to dispute the ramifications of the 1998 Transfers. It is 19 contested whether OMJ Ireland was subject to any internal revenue tax immediately after the 1998 20 Transfers. (See Docket Nos. 41 ¶ 38; 43-1 ¶ 38.) It is contested whether the employees were 21 transferred from OMJ prior to January 1, 1999. (See Docket Nos. 41 ¶¶ 39-40; 43-1 ¶¶ 39-40.) OMJ 22 asserts OMJ Ireland first became responsible for paying the U.S. internal revenue tax on January 7, 23 1999, while USA claims taxes were owed beginning on December 1, 1998. (See Docket Nos. 41 24 ¶ 42; 43-1 ¶ 39.) For the taxable years ending on November 30, 1998, 1999 and 2000, OMJ Ireland 25 was not required to, and in fact did not, file any U.S. federal income tax returns. (See Docket Nos. 26 41 ¶ 43; 43-1 ¶ 43.) 27 E. Taxable Year Ending in November 30, 1999 28 The parties agree that OMJ was eligible to claim Section 936 credits for the taxable year 1 Civil No. 11-1312 (GAG) 2 ending on November 30, 1999. (See Docket Nos. 41 ¶ 44; 43-1 ¶ 44.) For the three years preceding 3 the November 30, 1999 taxable year, OMJ derived at least 75% of its gross income from active trade 4 or business within Puerto Rico and 80% of its gross income from sources within Puerto Rico. (See 5 Docket Nos. 41 ¶ 44(B & C); 43-1 ¶ 44(B & C).) For the first ten months of 1995, when annualized 6 and without regard to any extraordinary items, OMJ had an inflation adjusted possession income of 7 $726,590,114. (See Docket Nos. 41 ¶ 45; 43-1 ¶ 45.) If no decreases due to the 1998 Transfers were 8 required, this figure would represent OMJ's adjusted base period income. (See Docket Nos. 41 ¶ 9 45; 43-1 ¶ 45.) 7 10 OMJ earned $662,819,287 of taxable income for the 1999 taxable year, with $631,273,838 11 qualifying as taxable income for purposes of Section 936. (See Docket Nos. 41 ¶ 46; 43-1 ¶ 46.) 12 OMJ claims this amount should not decrease due to the 1998 Transfers. If the 1998 Transfers do 13 not require a decrease, OMJ would be entitled to $88,378,337 in Section 936 credits. (See Docket 14 Nos. 41 ¶ 47; 43-1 ¶ 47.) If, as USA claims, OMJ was required to decrease their base period income 15 due to the 1998 Transfers, then OMJ would be entitled to on $58,710,540 in Section 936 credits. 16 (See id.) In late October 2004, OMJ filed an amended U.S. corporation income tax return claiming 17 a refund of $27,537,675 for the taxable year ending on November 30, 1999. (See Docket Nos. 41 18 ¶ 48; 43-1 ¶ 48.) This was later revised in 2011 to claim a refund of $22,874,764. (See Docket Nos. 19 41 ¶ 49; 43-1 ¶ 49.) The Internal Revenue Service ("IRS") denied the amended income tax return, 20 claiming OMJ was not entitled to this refund due to the 1998 Transfers. (See Docket Nos. 41 ¶ 51; 21 43-1 ¶ 51.) 22 F. Taxable Year ending on November 30, 2000 23 The facts pertaining to the taxable year ending in 2000 are similar to those of 1999, with only 24 the monetary figures changing. In this year, the parties agree OMJ was eligible to claim Section 936 25 credits. (See Docket Nos. 41 ¶ 52; 43-1 ¶ 52.) For the three years preceding the November 30, 2000 26 taxable year, OMJ derived at least 75% of its gross income from active trade or business within 27 Puerto Rico and 80% of its gross income from sources within Puerto Rico. (See Docket Nos. 41 ¶ 28 52(B & C); 43-1 ¶ 52(B & C).) For the first ten months of 1995, when annualized and without 1 Civil No. 11-1312 (GAG) 2 regard to any extraordinary items, OMJ had an inflation adjusted possession income of 3 $726,590,114. (See Docket Nos. 41 ¶ 53; 43-1 ¶ 53.) If no decreases due to the 1998 Transfers were 4 required, this figure would represent OMJ's adjusted base period income. (See Docket Nos. 41 ¶ 5 45; 43-1 ¶ 45.) 8 6 OMJ earned $747,040,140 of taxable income for the 2000 taxable year, with $700,587,457 7 qualifying as taxable income for purposes of Section 936. (See Docket Nos. 41 ¶ 46; 43-1 ¶ 46.) 8 If the 1998 Transfers do not require a decrease, OMJ would be entitled to $98,082,244 in Section 9 936 credits. (See Docket Nos. 41 ¶ 47; 43-1 ¶ 47.) If, as USA claims, OMJ was required to decrease 10 their base period income due to the 1998 Transfers, then OMJ would be entitled to on $58,710,540 11 in Section 936 credits. (See id.) At the same time OMJ filed an amended tax return for the 1999 12 taxable year, OMJ also filed an amended tax return for the 2000 taxable year. (See Docket Nos. 41 13 ¶ 56; 43-1 ¶ 56.) OMJ sought a refund of $37,928,839, which was later amended in March 2011 to 14 be $30,094,104. (See Docket Nos. 41 ¶¶ 56-57; 43-1 ¶¶ 56-57.) The IRS denied OMJ's revised 15 refund claim and mailed notice of that decision on March 28, 2011. (See Docket Nos. 41 ¶ 59; 43-1 16 ¶ 59.) 17 G. Procedural History 18 OMJ filed its original complaint on April 1, 2011, which was later amended on December 19 19, 2011. (See Docket Nos. 41 ¶ 60; 43-1 ¶ 60.) The amended complaint contains two counts, one 20 for each year, 1999 and 2000, in which the IRS denied OMJ's refund. The first count pertaining to 21 the 1999 taxable year seeks a refund of $22,874,764 and the second count for the taxable year of 22 2000 seeks a refund of $30,094,104. (See Docket Nos. 41 ¶ 61; 43-1 ¶ 61.) The taxes at issue in this 23 case have been fully paid by OMJ and OMJ only seeks a refund of these amounts. (See Docket Nos. 24 41 ¶ 62; 43-1 ¶ 62.) 25 III. Legal Analysis 26 Before analyzing the merits of the case, the court notes the First Circuit has previously dealt 27 with the statute involved in the present dispute, albeit not in this exact context. See MedChem 28 (P.R.), Inc. v. C.I.R., 295 F.3d 118, 122-23 (1st Cir. 2002). MedChem is instructive in two 9 1 Civil No. 11-1312 (GAG) 2 preliminary matters. First, the MedChem court quoted the Supreme Court as stating, "'It is well 3 established in the tax law that an [IRS determination that a taxpayer owes the Federal Government 4 a certain amount of unpaid taxes] is entitled to a legal presumption of correctness -a presumption that 5 can help the Government prove its case against a taxpayer in court.'" See MedChem, 295 F.3d at 6 123 (quoting United States v. Fior D'Italia, Inc., 536 U.S. 238 (2002)) (alteration in original). The 7 court notes that while an IRS decision does not require the court's blind allegiance, the IRS 8 determination that OMJ was not entitled to a refund of the payments at issue in this case is given a 9 presumption of correctness. (See Docket No. 41-1 at 7.) The second preliminary matter for which 10 the MedChem decision is instructive is that the First Circuit held "income tax deductions and credits 11 are matters of legislative grace; the taxpayer bears the burden of proving entitlement to any 12 deduction or credit claimed." See MedChem, 295 F.3d at 123 (citing INDOPCO, Inc. v. Comm'r, 13 503 U.S. 79, 84 (1992)). OMJ attempts to distinguish the present case from this precedent. (See 14 Docket No. 46 at 7.) Again, while this precedent does not control the outcome of the present case, 15 the court does consider the spirit of the holding in making its determination. 16 Turning to the merits, the critical issue in this case is the applicability of the various 17 provisions of Section 936. Section 936 allows corporations that elect the application of this statute 18 to receive "a credit against the tax imposed by this chapter" in an amount determined by a formula 19 also contained in the statute. 26 U.S.C. § 936(a)(1). In 1996, due to amendment Congress phased 20 out this credit over a ten year period. See MedChem, 295 F.3d at 119; 26 U.S.C. § 936(j). Section 21 936(j)(5)(D) requires a corporation to increase or decrease the amount of the tax credit when a 22 corporation either acquires or disposes of major portions of businesses. See 26 U.S.C. § 936(j)(5)(D) 23 ("Acquisitions and dispositions. – Rules similar to the rules of subparagraphs (A) and (B) of section 24 41(f)(3) shall apply for purposes of this subsection."). This section effectively adopts the provisions 25 contained in 26 U.S.C. § 41(f)(3), which is a similar research credit statute. That section states: 26 (3) Adjustments for certain acquisitions, etc. –Under regulations prescribed by the Secretary– 27 (A) Acquisitions. –If, after December 31, 1983, a taxpayer acquires the major portion of a trade or business of another person (hereinafter in this 28 1 Civil No. 11-1312 (GAG) 10 7 paragraph referred to as the "predecessor") or the major portion of a separate unit of a trade or business of a predecessor, then, for purposes of applying this section for any taxable year ending after such acquisition, the amount of qualified research expenses paid or incurred by the taxpayer during periods before such acquisition shall be increased by so much of such expenses paid or incurred by the predecessor with respect to the acquired trade or business as is attributable to the portion of such trade or business or separate unit acquired by the taxpayer, and the gross receipts of the taxpayer for such periods shall be increased by so much of the gross receipts of such predecessor with respect to the acquired trade or business as is attributable to such portion. 8 (B) Dispositions. –if, after December 31, 1983– 9 10 (i) a taxpayer disposes of the major portion of any trade or business or the major portion of a separate unit of a trade or business in a transaction to which subparagraph (A) applies, and 11 (ii) the taxpayer furnished the acquiring person such information as is necessary for the application of subparagraph (A), 12 then, for purposes of applying this section for any taxable year ending after such disposition, the amount of qualified research expenses paid or incurred by the taxpayer during periods before such disposition shall be decreased by so much of such expenses as is attributable to the portion of such trade or business or separate unit disposed of by the taxpayer, and the gross receipts of the taxpayer for such periods shall be decreased by so much of the gross receipts as is attributable to such portion. 2 3 4 5 6 13 14 15 16 26 U.S.C. § 41(f)(3). The applicability of these provisions to OMJ ultimately answers the question 17 posed to the court. 18 USA first argues Section 936 requires OMJ to reduce the cap on its credit because it disposed 19 of a major portion of its businesses -namely, the LLCs. (See Docket No. 42-1 at 10.) The cap is 20 calculated based on a corporation's adjusted base period income for a qualifying period.1 On the 21 other hand, OMJ argues the statute does not require a reduction because the statute only requires a 22 corporation to decrease its cap when there is a corresponding increase in the acquiring corporation's 23 cap. (See Docket No. 46 at 13.) OMJ points to Section 936(j)(5)(D) to support this correlative 24 argument. (See Docket No. 46 at 13.) For the reasons discussed below, the court does not find the 25 26 27 28 1 The parties do not dispute the calculation of the base period income, only whether the disposition of the LLCs required a reduction of the cap. 11 1 Civil No. 11-1312 (GAG) 2 statute necessitates such a correlative relationship. 3 A close examination of the statute and repercussions of any interpretations of such is required 4 under these circumstances. OMJ points to language contained in Section 41(f)(3)(B)(i), which states 5 that for a disposition of a business asset to require a cap reduction, it must occur "in a transaction 6 to which subparagraph (A) applies, and . . . ." 26 U.S.C. § 41(f)(3)(B)(i). OMJ argues that because 7 OMJ Ireland is not a taxpayer and subparagraph (A) requires a taxpayer to acquire the business, the 8 provision does not apply to the dispositions of the LLCs. (See Docket No. 46 at 12-13.) This 9 argument is composed of two separate parts: (1) whether the statute applies when the acquiring party 10 is not a taxpayer; and (2) whether the statute requires a correlative increase in the acquiring party's 11 credit when the disposing party's credit decreases. 12 A. Whether the Statute Requires the Acquisition to be Made by a Taxpayer 13 OMJ argues that it is not required to reduce its Section 936 credit because OMJ Ireland is not 14 a taxpayer. OMJ reaches this conclusion because subparagraph (B)(i) states a reduction is only 15 required when subparagraph (A) applies, and subparagraph (A) applies when "a taxpayer acquires 16 . . . ." Therefore, because OMJ Ireland, as the acquiring corporation, is not a taxpayer, the statute 17 does not apply. However it is clear from the statutory language of subparagraph (B) that a taxpayer 18 could dispose of a major portion of a business to a non-taxpayer and still be required to reduce its 19 qualifying credit. Subparagraph (B)(ii), also dealing with dispositions, states, "the taxpayer 20 furnished the acquiring person such information as is necessary for the application of subparagraph 21 (A)." 26 U.S.C. § 41(f)(3)(B)(ii). The use of the terms 'taxpayer' and 'acquiring person' within the 22 same sentence demonstrates Congress intended this provision to apply to all dispositions of a major 23 portion of a business, including transactions between a taxpayer and a non-taxpayer. The term 24 'person' encompasses a broader audience than the term 'taxpayer.' If Congress intended for the cap 25 reduction provision contained in subparagraph (B) to apply only to transactions between taxpayers, 26 then Congress could have used the term 'acquiring taxpayer' rather than 'acquiring person.' 27 This analysis is in harmony with subparagraph (A), which also discusses transactions 28 between a taxpayer and an acquiring person. There is no requirement in subparagraph (A) that a 12 1 Civil No. 11-1312 (GAG) 2 taxpayer acquire the major portion of a business from another taxpayer; rather, a taxpayer could 3 acquire such a business from a foreign corporation and still increase its cap. As both subparagraph 4 (A) and (B) refer to taxpayers either acquiring or disposing of businesses with 'persons' as opposed 5 to 'taxpayers,' the court finds it is not necessary that the transaction occur between two taxpayers. 6 This conclusion leads to a sensible interpretation of the statute. If the court adopts OMJ's 7 interpretation, a corporation could dispose of the major portions of its businesses within a U.S. 8 possession to a foreign corporation and remain entitled to a tax credit for those businesses. Reading 9 the statute as a whole, it is clear Congress intended for corporations to receive a credit for income 10 earned within a possession of the U.S. When the credit began to be phased out, the amount of the 11 credit was set to fluctuate, increasing when the corporation acquired additional qualifying businesses 12 and decreasing when the corporation disposed of qualifying businesses. See 26 U.S.C. § 936. The 13 fact that OMJ Ireland is not a taxpayer will not allow OMJ to evade a reduction of its Section 936 14 credit. 15 B. Whether the Statute Requires Correlative Adjustments Under Subparagraphs (A) and (B) 16 Next, OMJ argues the statute does not apply to its transactions because the statute 17 necessitates a correlative relationship between the acquisition of a business and the disposition of 18 a business. Essentially, OMJ's argument is that no reduction of Section 936 credit can occur unless 19 there is a correlative increase in the acquiring party's Section 936 credit. (See Docket No. 46 at 12- 20 13.) USA disagrees and asserts the is no statutory support for this assertion and that this assertion 21 is contrary to other subsections of Section 936. (See Docket No. 50 at 7.) 22 OMJ's argument rests on the inclusion of the phrase "in a transaction to which subparagraph 23 (A) applies . . . ." 26 U.S.C. § 41(f)(3)(B)(i). Subparagraph (A) explains how an acquiring party 24 may increase its cap. OMJ argues that by including this language, dispositions can only lead to a 25 reduction in the cap when the acquiring party may claim an increase in its cap. (See Docket No. 46 26 at 13.) This would mean, in circumstances such as this, when the acquiring party is a foreign 27 corporation, the disposing party has no obligation to reduce its cap. Admittedly, the court finds it 28 13 1 Civil No. 11-1312 (GAG) 2 difficult to reconcile the inclusion of this phrase within the context of the statute. On the one hand, 3 this language infers that any decrease in cap should correspond with an offsetting increase for the 4 acquiring party. On the other hand, the statute strictly prohibits corporations from using the tax 5 credit against organic growth from within the corporation, a result that would occur if OMJ's 6 interpretation is applied. See generally, 26 U.S.C. § 936. To resolve this conflict, the court turns 7 to accepted rules of statutory interpretation. 8 Courts should interpret statutory provisions in harmony with one anther, if possible. See 9 YULE KIM, CONG. RESEARCH SERV., 97-589, STATUTORY INTERPRETATION: GENERAL PRINCIPLES 10 AND RECENT TRENDS 6 (2008) ("A cardinal rule of construction is that a statute should be read as 11 a harmonious whole, with its various parts being interpreted within their broader statutory context 12 in a manner that furthers statutory purposes."). On occasion, provisions within a statute may be 13 ambiguous, or its meaning unclear when analyzed in isolation. See United Sav. Ass'n of Texas v. 14 Timbers of Inwood Forest Assocs., Ltd., 484 U.S. 365, 371 (1988) ("Statutory construction, 15 however, is a holistic endeavor. A provision that may seem ambiguous in isolation is often clarified 16 by the remainder of the statutory scheme -because the same terminology is used elsewhere in a 17 context that makes its meaning clear . . . or because only one of the permissible meanings produces 18 a substantive effect that is compatible with the rest of the law.") (internal citations omitted). Section 19 936 is a comprehensive statute, enacted to provide an incentive for U.S. corporations to locate their 20 research and development plants in U.S. possessions. When this incentive was phased out, Congress 21 made clear it intended to limit the use of this credit to existing credit claimants only. Both Sections 22 936(j)(5)(D) and 936(j)(9)(B) strictly limited the use of this credit for corporations having disposed 23 of a major portion of a business or corporations that created new lines of business. When Congress 24 decided to phase out the tax credit, it specifically decided to cap the amount of qualifying income 25 to income previously earned during the base period. See 26 U.S.C. § 936 (j)(5). In so doing, 26 Congress made the decision that organic growth of corporations located in qualifying territories 27 would not be shielded from income taxes. The phase out period was instituted as a means to notify 28 those corporations currently located in a U.S. possession and enjoying the credit to decide whether 14 1 Civil No. 11-1312 (GAG) 2 they wanted to slowly shift their operations elsewhere. At the same time, this statute did not allow 3 additional future earned income on top of the base amount to qualify for these credits. Supporting 4 this cap is Section 936(j)(9)(B), which contains a clause prohibiting an existing credit claimant from 5 adding a new line of business and still retaining its Section 936 credits. 26 U.S.C. § 936(j)(9)(B).2 6 To allow OMJ to continue to benefit from this credit would manifestly undercut various other 7 provision within the statute. As such, the court finds the statute does not require a corresponding 8 increase in the acquiring corporation's cap in order to require the disposing corporation to decrease 9 its cap. 10 As previously discussed, the court has found it unnecessary for the acquiring party to be a 11 taxpayer. The court has also found it unnecessary for there to be a correlative increase in the 12 acquiring party's cap in order for there to be a decrease in the disposing party's cap. Therefore, the 13 court need not further analyze the parties' remaining arguments. 14 IV. 15 16 Conclusion For the foregoing reasons, the court GRANTS USA's motion for summary judgment at Docket No. 42 and DENIES OMJ's motion for summary judgment at Docket No. 41. 17 SO ORDERED 18 In San Juan, Puerto Rico this 18th day of October, 2012. 19 S/Gustavo A. Gelpí 20 GUSTAVO A. GELPÍ 21 United States District Judge 22 23 24 25 2 26 27 28 Section 936(j)(9)(B) states, "If, after October 13, 1995, a corporation which would (but for this subparagraph) be an existing credit claimant adds a substantial new line of business (other than in an acquisition described in subparagraph (A)(ii)), such corporation shall cease to be treated as an existing credit claimant as of the close of the taxable year ending before the date of such addition." 26 U.S.C. § 936(j)(9)(B).


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The 3M 2091 P100 Filters fit on the 3M 6000 and 3M 7500 series half masks, as well as the 3M 6000 full face respirators. HEPA filtration is rated to remove 99.9% of particles .3 microns and larger. This includes most welding fumes (burnt metal), toxic dusts like asbestos and lead, and folks with allergies to many environmental dusts. Sometimes called a 3M P100 pancake filter, they are attached directly to the mask. A simple 1/4 turn locks them on. No retainers or other attachment methods are needed.
This filter is also available as an assembly paired with the 3M 6000 half mask. When bought together, this 3M 6000 Lead and Asbestos Mask is one of our most popular items.
*If the hazard is mold, or if you are arc welding, then we would suggest the 3M 2097 P100 HEPA Filter that has a layer of charcoal. Active mold growth produces Volatile Organic Compounds (VOCs) that won't be absorbed by the 2091. Arc welding produces ozone, which also won't be absorbed.
Part Number:
3M P100 Particulate Filters (Pair) 2091 3M 2091 P100 Particulate Filter
3M 2091 P100 Particulate Filter Video Transcript
Hi! This is Rick Pedley and welcome to PK Safety Supply!
Today we're talking about the 3M 2091 P100 Particulate Filter. The 3M P100 fits onto the 6000 series respirators, both half, full face and the 3M 7500 half mask respirator. Now, P100 is the current name for HEPA or High Efficiency Particulate Air filter.
Now, the P in P100 means that it's oil-proof. Now, what's interesting about that is that these filters are electrostatic filters. That is, they have a static charge. This static charge attracts and traps the dust that comes through. So what they're giving you here are two filters. You have both on the mask at one time and they're soft! We call them a pancake filter. They're made of a kind of polypropylene material. They have a little bit of fuzzy stuff inside to keep them from crushing. But they're very comfortable and extremely lightweight. You can put these on your mask and it's easy to breathe through and hardly feels like anything's there. And if you do brush up against something, they do bend a little bit.
For instance, if I were wearing a welding helmet, this would be a very convenient filter to be wearing. One thing we do want to watch out for when we're welding is sparks. Because it's a polypropylene material, it will burn. And when I say burn, I mean that they'll char. So, if you've got a spark here, it'd put a little hole in it. They will not catch fire. They're self-extinguishing. but that's kind of important. If that comes up, if that's an application you're thinking about, where there are flying sparks… maybe you're grinding metal for instance… if those sparks might hit the filters, I'd suggest using their model 7093, which has a plastic case -- shaped a little differently. But uh, we wear these filters in particular… the big ones are asbestos and lead.
Now, asbestos… if you're a home owner and you're working on some duct work, maybe you're working on your car and you've got some old style brake linings with asbestos in them, this'd be the thing to wear. It's gonna protect you from that.
In the case of lead, we have a few different things. You know, lead dust around the house… thinking in terms of grinding paint… anyone with an older home is most likely going to have lead paint on the windows and so forth. Anywhere there's the glossy paint close to the walls… pretty likely to have lead. And then, some people will also burn that off. That is, to remove the paint, they'll heat it. This can be inside the house, this can be outside the house, but these are gonna be good for that. What's important, though, is that you have ventilation, because when you're heating the paint to take it off, you're probably also creating carbon monoxide, which isn't a good thing. Odorless, tasteless… filter's not going to stop that. The other thing is, when you're burning paint, there's also a fair amount of organic material that is going to be generated. Once again, that may not be taken care of by this. There are other filters… if I was burning paint, and I didn't have a lot of ventilation… I mean, you've got to have something, trust me… but their model 60926, which we'll look at in a different video, would be a good item to use.
So, those are kind of the main uses for it. HEPA filter, though, is good for a lot of things. Anybody who has got severe allergies, this is something to look at. It's gonna stop all but the very tiniest particles… cigarette smoke… it won't get all the odor, but all the particulate in the air is going to get taken out. It's a really interesting filter.
So, flat pad. Got this little connector in the back and this clicks on with a quarter turn. We looked at that on some of our other videos, so I won't belabor that. It comes in a sealed pack with a pair… you get some instructions, not all that helpful I must say…
There you go! That's the 3M 2091! Thank you very much!
|Product Weight (lbs.)
|Ship Weight (lbs.)
|Protection From
|Most Dusts, Lead and Asbestos
Back up set Review by DLS of KY
I ordered the filters as a back up for the half mask I ordered that had them on it already. I am very pleased with the way they kept the saw dust, insulation dust and demolition dust out of ME! (Posted on 11/3/14)
A+ Review by Rob
I recently was able to convert my civilian Israeli 40mm gas mask to accept 3M filters and was seeking a P100 HEPA rated filter to provide possible protection from airborne pathogens. My order came through exceptionally well. The 2091 filter was exactly what I was looking for and I was very happy with the quality of the product. (Posted on 10/29/14)
Great quality Review by Lizzie
I have been very pleased with these filters & all of the supplies that I ordered! I can not say enough good things about the customer service that I received! They are awesome! (Posted on 10/6/14)
Worked for us Review by Wild Investment
We were using filters that were really for fumes and we needed to block out dust and what could have potentially been asbestos. These worked great in keeping and filtering all dust and fibers. Would buy them again. (Posted on 8/14/14)
Will buy again Review by Steve
Use for construction demo. Feel protected. Nothing negative.
(Posted on 8/22/13)
Particulate Filter Review by Paula Rueter
Easy to use and place on your respirator. Item quickly shipped.
Easy to install on your respirator.
I do not dislike anything about this item.
(Posted on 8/22/13)
Filter review Review by Marvin
Hope it is working -- it fits fine and is easy to change out -- using it to filter asbestos, so again -- HOPE it is working
(Posted on 8/22/13)
Exceptional filter Review by Micheal Hamilton
Have used in lost wax cast Bronze Foundry for 10 years. Handles the fine silica dust in the slurry room and external sand blasting, handles metal fumes from pouring and welding, particles from grinding and chasing and most fumes from the patina chemicals. Highly Recommend.
Newer filter seem to de-laminate faster than the older ones.
Comments from PK Safety:
Hi Michael,
Thanks for taking the time to write a review. We like knowing the 2091 filters perform so well in your foundry work.
About the delamination issue - we are wondering if you have tried the 3M 7093 filters. The 7093s provide the same level of filtration, but have a protective exterior that might protect the filter better in your work environment.
They are also slightly less expensive.
Thanks again for the review, and an extra thanks for attaching the excellent photo.
Best regards,
PK Safety
(Posted on 8/22/13)
Seem to do what they're suppose to do Review by Dwight L.
I do woodworking as a hobby. I was asked to make some pieces from Pacific yew. Found out the stuff can be on the nasty side to work with. Marc Spagnuolo, The Wood Whisperer, did a video on the effect of dust on one's well being. He uses these filters in his shop. What's good enough for Marc should be good enough for me. I worked the yew using the filters and did not have any problems is all I can say.
Can't go wrong with a 3M brand.
Well--they are pink!
(Posted on 8/22/13)
Great stuff! Review by Greg
These filters were just what I needed to do a very dusty, dirty job safely.
(Posted on 8/22/13)
Filter Review by Sande
Easy to attach to mask.
(Posted on 8/22/13)
Just What I Needed Review by Justin
These filters were perfect for doing a very dusty, dirty job safely. Very satisfied with this purchase. (Posted on 2/26/13)
The P100 HEPA (which stands for High-Efficiency Particulate Arresting) filters trap dust and particles like a strainer. Once the filters have successfully blocked a large amount of particulate matter, they still won't let that material into your lungs. They do however start allowing less air to past through, and breathing will become more and more difficult.
You may not notice it at first, but as the filters clog up, it will become harder to suck in a breath. Trust us, you'll notice eventually. That's when you know it's time to replace the filters.
- This Item: 3M P100 Particulate Filters (Pair) 2091
3M 6000 Lead & Asbestos Respirator Combination
Lead and Asbestos Removal Pro Kit
Price for all: $51.25
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BW Honeywell GasAlert Clip Extreme H2S Monitor GA24XT-H
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Posts tagged: Anne Kirkpatrick
Good morning, Netizens…
[portions from Spokesman-Review, KHQ]
Well, I'll be fiddled and diddled!
Spokane Police Chief Anne Kirkpatrick was issued a $154 speeding ticket by a Spokane County deputy sheriff over the weekend for driving 13 mph faster than the speed limit.
She was in an unmarked car heading for a picnic when she was pulled over on Upriver Drive in her unmarked police car.
"He told me I was speeding … I said, 'Then you've gotta write me the ticket,' " Kirkpatrick told KHQ. "I didn't give him an option to not write me a ticket."
Kirkpatrick apologized to the citizens of Spokane and the mayor, KHQ reported.
I remember a number of off-duty Spokane Police Detectives who have been pulled over, but instead of accepting a speeding ticket, have shown the nice officer their badges, and thus received no ticket.
"It's a professional courtesy," one of them said, when asked about the situation.
I could name names but then someone would have to shoot or Taser me.
Nice job being honest, Chief! You occasionally amaze even me.
Good evening, Netizens…
[Portions from KXLY-TV and their respective web site]
I am certain there are some who will
shake their sage heads at me and complain I must have gone "over to
the other side" or some other claptrap, but such is not the case. Police Chief Anne
Kirkpatrick celebrated her 50th birthday by climbing Mount
Rainier, which I know from years spent hiking around Mount Hood, is
no simple feat at all.Yet hardly anyone noticed her achievement, something I found lacking.
Climbers, even experienced climbers, have encountered technical challenges climbing Ranier in the past, and have been forced by foul weather and climbing conditions to return to base camp, but in Chief Kirkpatrick's favor is her will to achieve her goals.
According to KXLY-TV Chief Kirkpatrick
hiked the nine and one-half miles from the Paradise Visitor's Center
to the Ranier crater over two days, she reached the peak at
approximately 12,500 feet just shortly after sunrise.That is some serious climbing.
Before anyone mutters some deprecations about who paid for her climb, Chief Kirkpatrick paid for it all herself; after all, it was her birthday present to herself.
Only half of the 9,000 people who set out to climb Mt. Rainier last year actually reached the summit, because it is treacherous and not an easy climb. This year Anne Kirkpatrick added her name to those that had made it to the top.
Happy Birthday, Chief Kirkpatrick and congratulations on a successful and safe climb.


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A look at Super Tuesday web ads and strategies from the GOP campaigns.
The Newt Gingrich campaign shifted its online advertising away from his homestate of Georgia yesterday to focus on Tennessee and Oklahoma. Meanwhile, pro-Gingrich Super PAC Winning Our Future bought around $190,000 in online ads recently, aimed at voters in Super Tuesday primary states including Oklahoma, Ohio, Tennessee, Georgia, Virginia, North Dakota, Massachusetts, and Alaska. The group has spent millions online since January to slam Mitt Romney and help Gingrich.
On this important primary day, GOP presidential candidates and their Super PAC proxies are pointing web ads at voters reminding them who to vote for, and in some cases where to vote.
"We are running an aggressive online effort today including paid online ads in Tennessee and Oklahoma on Google and Facebook," said Vincent Harris, digital consultant for the Gingrich campaign. "We were running ads in Georgia but shifted resources as of yesterday into Tennessee and Oklahoma," he added. Gingrich has emphasized winning Georgia, which he represented in Congress and has the most delegates of any of today's primary states.
The former House Speaker's team also features a Super Tuesday tab on his Facebook page, which pushes a "Newt surging in super Tuesday states" message. Facebook users can click their state on a U.S. map to find polling places and download regional support buttons to post on their walls. Some images feature local sports teams such as one that cheers, "Georgia Bulldogs with Newt."
States voting today are Alaska, Georgia, Idaho, Massachusetts, North Dakota, Ohio, Oklahoma, Tennessee, Vermont, and Virginia.
"Newt surging into first place...Every vote counts," declare ads aimed at primary voters today. Ads targeting Oklahoma voters on Facebook use space usually reserved for an image to tout endorsements of Gingrich from JC Watts, Fred Thompson, Herman Cain, and Rick Perry. Watts is a former congressman from Oklahoma. "Today's election day in Oklahoma and polls show Newt surging. Help ensure he wins!" say the ads.
Mitt Romney's campaign and pro-Romney Super PAC Restore Our Future are also aiming get-out-the-vote ads online to residents of Super Tuesday states today. Restore Our Future, which has been attacking Gingrich and Rick Santorum in support of Romney, spent around $466,000 on web ads recently in Ohio, Oklahoma, Georgia, and Tennessee, as well as Mississippi and Alabama, which vote later this month.
Ads from Restore Our Future promote NewtFacts.com and RickFacts.com, both attack sites opposing Gingrich and Santorum, respectively. "Newt Is Not A Conservative. He's A Washingtonian Insider," states a Restore Our Future ad linking to NewtFacts. An ad for RickFacts promotes a "shocking video" purporting that Santorum increased the "US Debt Over $3 Trillion."
While the other Republican campaigns are using online advertising today specifically to drive voters to the polls, the Ron Paul camp is running persuasion ads in key primary states. Ads seen on Vermont and Tennessee news sites today call Santorum a "Fake" and link to a video of an anti-Santorum TV spot the campaign also ran before the Michigan and Arizona primaries in February.
However, Paul is asking supporters on Facebook to vote for him and to make phone calls to remind others to do the same.
What's New for 2015?
You spoke, we listened! ClickZ Live New York (Mar 30-Apr 1) is back with a brand new streamlined agenda. Don't miss the latest digital marketing tips, tricks and tools that will make you re-think your strategy and revolutionize your marketing campaigns. Super Saver Rates are available now. Register today!
Kate Kaye was Managing Editor at ClickZ News until October 2012. As a daily reporter and editor for the original news source, she covered beats including digital political campaigns and government regulation of the online ad industry. Kate is the author of Campaign '08: A Turning Point for Digital Media, the only book focused on the paid digital media efforts of the 2008 presidential campaigns. Kate created ClickZ's Politics & Advocacy section, and is the primary contributor to the one-of-a-kind section. She began reporting on the interactive ad industry in 1999 and has spoken at several events and in interviews for television, radio, print, and digital media outlets. You can follow Kate on Twitter at @LowbrowKate.
February 9-11, 2015
March 24-25, 2015
March 26, 2015
Mar 30-Apr 1, 2015
Singapore, 3-4 November
Hong Kong, 8-9 December
Hong Kong, 8-9 December
Google My Business Listings Demystified
To help brands control how they appear online, Google has developed a new offering: Google My Business Locations. This whitepaper helps marketers understand how to use this powerful new tool.
5 Ways to Personalize Beyond the Subject Line
82 percent of shoppers say they would buy more items from a brand if the emails they sent were more personalized. This white paper offer five tactics that will personalize your email beyond the subject line and drive real business growth.


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Bishop Kenny rememberedSoutheast Catholics and other friends of the late Bishop Michael Kenny will celebrate the 75th birthday this weekend.
Silides leave JuneauThe priest of a downtown Juneau congregation that lost its church to arson has transferred to another parish.
Speaker preaches dedication, not settling for averageTV host and author Josh Shipp urged students from high schools in Juneau and Haines to take personal responsibility, look at every obstacle as an opportunity to get better at something, and be dedicated to success.
New director for Catholic Community ServiceA major Southeast social-service agency has a new top official. Jean Strafford will take over as executive director of Catholic Community Service on May 1st.
Holy Trinity, McPhetres celebrate new facility
Holy … more
First full-time Rabbi at Temple Sukkat Shalom
Dov Gartenberg will be the first year-around Jewish Rabbi in Juneau.
He says Dov is pronounced like the bird or the past tense of dive … more


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2011 Pride Interfaith Service, Thursday, July 7
Submitted by Steve Buescher on June 15, 2011 - 11:23am.
Cincinnatians from across the rainbow of spiritual and religious perspectives will gather to celebrate how their diverse faiths respect and embrace people of all sexual orientations and gender identities. The 2011 Pride Interfaith Service will be on Thursday July 7 at 7:00pm at St. John's Unitarian Universalist Church (320 Resor Avenue in Clifton). All are invited to join attend this very special multi-faith worship event! For more details, visit www.cinciuu.org.
2011 DIVAS GLAM Awards - Announced!
Submitted by mxchanak49 on June 8, 2011 - 10:45am.
Divas GLAM 2011 award results here!
Thanks to Brian McQueen and all the winners and supporters of the 2011 DIVA GLAM Awards.
June 2011 - GLBT Pride Edition!
Submitted by mxchanak49 on June 7, 2011 - 10:57am.
May GLBT News - Greater Cincinnati - Old Media & Older Vans
Submitted by mxchanak49 on May 2, 2011 - 7:59am.
Columbus Pride 2011
Submitted by Steve Buescher on May 1, 2011 - 3:14pm.
Ohio's capital city, known as one of the most gay- and lesbian-friendly destinations in the U.S., is making final preparations for its Columbus Pride Festival, which attracts more than 100,000 visitors. One of the 10 largest gay pride celebrations in the country, this year's festival is slated for Friday, June 17, through Sunday, June 19, while June is filled with Pride-related events around Columbus.
The Columbus Parade is on Saturday and the Festival runs Friday and Saturday at Goodale Park. Here's a map.
Cincinnati Pride 2011 is Friday, July 8, through Sunday, July 11. More info to follow.
Film: Stonewall Uprising, PBS American Experience - Monday, April 25
Submitted by Steve Buescher on April 22, 2011 - 7:31am.
In 1969, homosexual acts were illegal throughout the United States.
When police raided the Stonewall Inn, a popular gay bar in the Greenwich Village section of New York City on June 28, 1969, the street erupted into violent protests that lasted for the next six days. The Stonewall riots, as they came to be known, marked a major turning point in the modern gay civil rights movement in the United States and around the world.
The film airs on Monday, April 25, on PBS. Watch the trailer and find more information here.
Solidarity Walk for Bullycide - May 11th @ UC French Hall
Submitted by mxchanak49 on April 20, 2011 - 11:34am.
Solidarity Walk for Prevention of Bullycide
Location: The University of Cincinnati's School of Social Work (French Hall)
Presented by the School of Social Work's Graduate Student Association and Women's Center. Special thanks and kind assistance of Mother Chanak and the Greater Cincinnati Gay & Lesbian Community Center.
About the "Walk of Silence": The Walk of Silence is dedicated to those individuals who have been victims of bullying in hate crimes and to those who have committed suicide due to being bullied. Participants are welcome to create their own posters/flier(s) to use during the silent walk while providing the audience with their own personal experiences or statistics regarding victims of bullying.
Where: Participants will meet at The School of Social Work (French Hall). From there we will have a brief rally and then start the "Silent Walk" throughout campus, dedicated to those who have taken their lives due to bullying.
"People will forget what you said, people will forget what you did, but people will always remember the way you made them feel..." ~Maya Angelou
Any other comments/questions contact Felicia Gang.
Refuse to Lie
Submitted by Steve Buescher on April 5, 2011 - 6:15pm.
Each year the federal government demands that thousands of married couples lie.
The federal Defense of Marriage Act (DOMA) not only denies legally married gay couples the benefits of heterosexual marriage, but we are also told to disavow our spouses and file our taxes as "single."
The Federal Government must stop requiring legally married gay couples to deny the existence of our families and hide our marriages.
It is dehumanizing and it is wrong.
More info at RefuseToLie.org


text:
Any pics of Straight porn god Brian Pumper....he is friggin' AMAZING!!!! I love when he sticks it in the chick pussy and says.."do ya feel me...feel me inside you?"
Any pics of Straight porn god Brian Pumper....he is friggin' AMAZING!!!! I love when he sticks it in the chick pussy and says.."do ya feel me...feel me inside you?"
here's a link to one of his yahoo groups. hope this helps:http://groups.yahoo.com/group/BrianPumper/
^^^ Hot photos...especially the one were he gets rimmed
I had never heard of Brian Pumper until 2 days ago - now all I want to do is suck that cock until he explodes in my mouth. Man, that black boy is hot.
I know this is a long shot, but I had downloaded a video of Brian and I think the link may have been on JUB. He's and another guy are on their backs, legs in the air and a girl is rimming them and then starts to finger fuck them. Anyone have a link?
Porn for Patric: is my blog about porn sites and porn stars, guys I find hot and some of my photography
oh please post the pic of him getting his ass licked!!
anyone have
Brian pumper is the coolest guy. He has such a wonderfull body. I totaly love to watch his movies.
Brian is a nice looking guy. right up there with mr.marcus and matthew rush
I know him personally, he is even sexy in person.
Yeah, the bitch is BACK!
The name of the movie is "Two in the seat 2" ... but it looks like nobody got it
There's a new site about him ass well - if you're a fan, join
Robbie Anthony - what a HOT twink
I've just added many new photos and videos to the site
Robbie Anthony - what a HOT twink
I've updated the site again!
Many more photos and videos - check it out now and join!
Robbie Anthony - what a HOT twink
on the website, blackcrackaddicts.com brian pumper is in one of the newer videos getting rimmed by his girlfriend while sitting on her face.
check it out
man he is HOT HOT HOT!!!!!
Here's a link to another thread with an earlier compilation video I made of Brian. It's got some rimming clips in it...
he's fine as hell!!! i like him better in group scenes--the shit he says sometimes is HOT. there's one scene with him and 2 white guys all doing a creampie with a chick. the 2 white guys go 1st and leave relatively nothing to see...then my boy steps up and deposits a GUSHER!!! then he's like "That's what happens when i shoot MY loads"...
If you enjoy him, join our fanclub with THOUSANDS of photos and many videos of him!:
You can also add his MySpace-site:
We also have a YouTube-account:
Robbie Anthony - what a HOT twink
he likes getting his ass ate, he isnt str8
Quite simply one of the HOTTEST men alive!! Tierra, I am JEALOUS that you know him.
I'd love to have his cock pumping in and out of me...
We made many new updates on BRIANPUMPERBOARD, join now if you're not already a member!:
Robbie Anthony - what a HOT twink
I joined, good stuff man.
I'm joining now!
Nice pics. I like watching him and Mr. Marcus double team a hot white girl. They have the best interracial scenes.
he's got a nice cock
totally forgot about this guy he is so hot has he done anyting gay over the years?
A guy that lets his woman Lick his ass does NOT mean he's gay, it just means he has a great sex life with his woman...
Wow he's hot. Brian Pumper can "PUMP" me anyday, anywhere, anyway!!!
willing to do anything to get him in my mouth...I mean my bed!
so hot......
He is so HOT
can any one send me the pics of all of brian pumper? especially the pics of him gettin rimmed and his ass licked!


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*Must Buy* The grapes for this wine come mainly from the Awatere Valley where cooler nights and warmer days have helped accentuate the vibrant aromas. The palate has lime and apple fruit and crisp acidity. An intense, stylish and serious glass of wine.
Vivid and intense, with a burst of Key lime, green apple and fresh pepper and grass notes bursting through the smooth, juicy frame. Offers a lingering finish. (Web Only-2013)
91 points Wine Orbit: "Pristine and delightful, the fragrant bouquet shows lifted aromas of stone fruit, feijoa and dill, leading to a concentrated and textured palate that's refreshing and lingering. A beautifully expressed sauvignon offering plenty of appealing flavours. 6% of the juice was fermented in mature barrels, which added extra dimension and layer without taking away the varietal purity. At its best: now to 2017." Te Whare Ra is a small, organic, family-run winery in Marlborough's Wairau Valley. We love them so much that we decided to import them directly, which translates to an excellent value for our customers! Jason and Anna Flowerday are the Husband and Wife winemaking team behind TWR. All of their wines are hand-crafted with love and attention.The 2012 Sauvignon Blanc is sourced from the Lissaman Vineyard in the Upper Awatere Valley and TWR's home block in the Wairau Valley. The fruit was very gently pressed and is a large proportion of free-run juice. A slow cool ferment is used to preserve this wines bright aromatics and flavors while a small proportion of the juice was fermented in old Demi-muids (large neutral oak barrels) to give added texture and complexity on the palate. Te Whare Ra describes this wine as "white currant and passion fruit coupled with ripe tropical and citrus notes from the Wairau components. These follow through to the palate -- which is fine and soft with vibrant, fleshy fruit balanced by ripe, juicy acidity and lingering minerality."
Below is a listing of the wine review scores we frequently reference in our notes. While these sources remain an excellent source of information, we always recommend that you trust your own palate. Scores in these publications often represent the personal taste of an individual critic, which may not always coincide with your own. We have a huge team of excellent wine professionals that can match wines you've had in the past with new arrivals that meet your flavor profile.
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2014 Lake Chalice "The Nest" Sauvignon Blanc Marlborough New Zealand
2012 Mount Edward Pinot Noir Central Otago (Elsewhere $40+)
2012 Tongue In Groove "Clayvin Vineyard" Pinot Noir Marlborough (Elsewhere $40)
2011 Kumeu River "Mate's" Chardonnay Kumeu River New Zealand (Elsewhere $50)
2013 TWR (Te Whare Ra) Sauvignon Blanc Marlborough (Elsewhere $24+)