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- Prison Planet.com - http://www.prisonplanet.com -
Libertarian Party Candidate Michael Badnarik Suffers Heart Atttack
Posted By admin On December 23, 2009 @ 11:12 am In Multimedia | Comments Disabled
Kurt Nimmo
Prison Planet.com [1]
Wednesday, December 23, 2009
Badnarik campaigning in July 2004. | |
Michael J. Badnarik, the Libertarian Party nominee for President of the United States in the 2004 elections and a former software engineer and radio talk show host has suffered a heart attack. Badnarik is also the president of the 2009 Continental Congress.
Badnarik was in Madison, Wisconsin, attending a hearing regarding a raw milk case when he collapsed, according to Gary Franchi, the National Director of Restore the Republic. "After the hearing he got in a car to go to lunch with friends, He then slumped over. His friends attempted CPR and contacted the paramedics. They attempted to revive him 3 times with no success. Upon the 4th attempt his heart was revived yet with erratic behavior," writes Franchi in an email.
Michael was taken to a local hospital in Wisconsin and fitted with a temporary pacemaker and a balloon pump to ease stress on his heart. He remains in an unconscious state and his condition is listed as serious.
Alex Jones: Our Prayers Go Out to Michael for His Full Recovery
In November 2009, Badnarik was elected as one of three delegates from the State of Texas to attend the 2009 Continental Congress sponsored by the We The People Foundation, and subsequently elected parliamentary president of that body.
In October 2008, he began hosting a talk radio program, Lighting the Fires of Liberty, on the Genesis Communications Network.
Article printed from Prison Planet.com: http://www.prisonplanet.com
URL to article: http://www.prisonplanet.com/libertarian-party-candidate-michael-badnarik-suffers-heart-atttack.html
URLs in this post:
[1] Prison Planet.com: http://www.prisonplanet.com
[2] The Alex Jones Show – ARCHIVE – May 11th With Michael Badnarik: http://www.prisonplanet.com/the-alex-jones-show-archive-may-11th-with-michael-badnarik.html
[3] The Alex Jones Show – ARCHIVE – February 16th With Michael Badnarik: http://www.prisonplanet.com/the-alex-jones-show-archive-february-16th-with-michael-badnarik.html
[4] The Alex Jones Show – L I V E – April 8 With Michael Badnarik: http://www.prisonplanet.com/the-alex-jones-show-l-i-v-e-april-8-with-michael-badnarik.html
[5] Michael Badnarik: The Constitution is Still Relevant: http://www.prisonplanet.com/michael-badnarik-the-constitution-is-still-relevant.html
[6] The Long Battle for Liberty with Michael Badnarik: http://www.prisonplanet.com/the-long-battle-for-liberty-with-michael-badnarik.html
Click here to print.
Copyright © 2013 PrisonPlanet.com. All rights reserved.


text: Jaap Struyk wrote: > After spending almost a month trying to build a secure 64bit system I > begin to wonder why, will it be more secure than a 32bit system? > (will it be less vulrable to buffer overflows due to the larger buffers???) > It cannot be more secure. 64 bit machines has capabilities that some people need and its good to have a secure platform for them. I am working with in memory databases and 64 bit machines are ideal for this. -- Democracy is about two wolves and a sheep deciding what to eat for dinner. -------------- next part -------------- A non-text attachment was scrubbed... Name: rogelio.vcf Type: text/x-vcard Size: 333 bytes Desc: not available URL: <http://lists.linuxfromscratch.org/pipermail/hlfs-dev/attachments/20071205/1046dc38/attachment.vcf> -------------- next part -------------- A non-text attachment was scrubbed... Name: signature.asc Type: application/pgp-signature Size: 252 bytes Desc: OpenPGP digital signature URL: <http://lists.linuxfromscratch.org/pipermail/hlfs-dev/attachments/20071205/1046dc38/attachment.sig>

subset: commoncrawl


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If you're looking for bigger motor home living, in a smaller more prestigious package, you'll find it in the all new 2014 fuel efficient Prism class C motor home by Coachmen.
The Coachmen Prism class C motorhome is your go to coach when it comes to long or short trips. Come select your model today!
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Automotive / Exterior / Construction
Electrical / Heat / A/C
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See us for a complete list of features and available options!
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Sneakers41 - I wanted to say that more colleges are offering an online business administration degree program in order to reach more nontraditional students.
Many people have gotten a degree this way which allows them the opportunity to obtain the degree by studying at home and working at their own pace. The only drawback with online education is that some people underestimate the time commitment for many classes and don't give themselves enough time for each class.
The general rule of thumb that applies to traditional classes applies online classes as well.
For example, for every three credit hours you take, you have to factor an additional ten hours of weekly homework in order to do well.
I know that Florida International University has expanded their online business administration degrees to include finance, human resources management, management, and international business.


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The province and the B.C. Medical Association are promising a family doctor for every B.C. resident who wants one, a goal they say can be achieved within two years.
That might be good news for the 176,000 British Columbians who don't have a family physician, yet a Kamloops family doctor said it would be impossible to achieve in this city.
Health Minister Margaret MacDiarmid announced on Friday $132 million more in funding to expand A GP for Me, a pilot program provincewide that has already matched 9,000 patients with doctors over the past two years.
Some of that funding, which begins on April 1, will pay doctors $15 per patient phone call to a limit of 500 telephone consultations each year.
The plan will also encourage doctors with family practices to get together in their own communities to create new ways to ease their caseloads, such as by using government funding to recruit new doctors or bring in more registered nurses.
"This new program will make it easier for physicians to provide high-quality care to their patients, and in many cases ease their workload so that they can accept more patients into their practices," MacDiarmid said in a news release.
The innovative approach has been tested in Cowichan Valley, Prince George and White Rock.
Dr. Rob Baker, a family physician who has practised for 33 years in Kamloops, said there are simply too few doctors to go around.
"I'm afraid we've heard this before in this province," Baker said. "It can't happen. It's impossible."
He said advice given over the phone is a risky practice at best and he doesn't believe GPs can take on more patients.
"I can't speak for other communities, but physicians in Kamloops are going as hard as we can and we're already seeing more patients than we want to," he said.
Other features of the new program include:
* Incentives for physicians to take on more patients with complex conditions such as cancer.
* Funding in support of local physician groups to work collaboratively with health authorities to support better local access to primary care.
A separate and complementary program is intended to support hospitalized patients in receiving care from family doctors.
MLA Terry Lake said the goal to ensure all citizens have a family doctor was promised by former finance minister Kevin Falcon a few years ago.
"It's a challenge. We're training way more doctors, but I know in Kamloops that it's still an issue," he said. The addition of nurse practitioners should also help to alleviate the shortage, he said.
He said 38 new doctors arrived in Kamloops last year, eight of whom are general practitioners. Other initiatives - Interior Health Authority is rolling out its red-carpet service again to attract and retain MDs - should also improve access.
But Baker questioned the number of new GPs cited. He said he's aware of only one additional doctor other than those who have replaced retiring physicians. A lot of physicians listed as family doctors are "hospitalists" who have no effect on the community, he said.
Part of the issue is financial. When Baker started in 1980, he could earn a living seeing four patients an hour. Now he has to see seven an hour. That's not good for the quality of care and it's not the pace doctors want to maintain, he said.
While more doctors are in training, many in the field may have only a few years until retirement.
"I'm afraid, from a Kamloops perspective, this is going to get a lot worse before it gets better."
© Copyright 2015 Kamloops Daily News


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The hot tub is here and will be up and running this weekend! It's bigger and better than the last and we're excited to re-introduce it to our guests! Evenings have begun cooling off a bit to that perfectly comfortable temperature and you can start to feel the autumn air ever so slowly move in. The hot tub adds that extra element of relaxation we hope all our guests experience while they're here. If you're thinking now isn't the right time to come to the beach for a vacation because summer is over I beg to differ!! My absolute favorite months on Folly Beach are September and October. The crowds have dispersed and the beaches open up to afford more solitude and peace. The weather is still pleasant and warm during the day and the water's still a comfortable temperature to swim in. You can still find a plethora of live music and restaurants open without the waiting time and the crowds. Make your reservations early so you're sure to be here during some of the upcoming Fall events on Folly as well as in and around the Charleston area:
Friday, 9/20: Shagging on the pier — don't know how to shag? Not a problem. The DJ plays a wide genre of music for a variety of tastes and dance moves.
Friday, 9/20 – Sunday, 9/22: Folly Turns 40! We're all looking especially forward to this new exciting celebration of Folly's 40th birthday. Expect carnival games and rides, a sort of throwback to the good ol' days, live music along Center Street and a roaring good time! We'll be there too, serving our world famous Folly Punch.
9/25 – Sigur Ros performs at the North Charleston Performing Arts Center.
9/27 Southern Living's Taste of Charleston. This 3-day culinary celebration has been named one of the "Top 20 events in the southeast" by Southeastern Tourism Society.
10/8 Latin American Festival – Celebrate this fun and vivacious culture at Wannamaker Park in North Charleston. Try out the salsa dancing and authentic cuisine!
And this is only a few of your options while visiting Charleston. For more information go to Charleston's Visitor Bureau or the Charleston City Paper's Event Calendar.


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- - http://www.sportstalkflorida.com -
Bucs Rookie Mini-Camp: Deveron Carr
Posted By Matthew Sardo On May 7, 2013 @ 1:52 PM In Florida News,main feature,NFL,watch now | 1 Comment
Cornerback Deveron Carr didn't get an invite to the NFL Scouting Combine or hear his name called on draft day, but nothing has slowed the former Arizona State standout from realizing his NFL dream.
Carr was one of several rookies who impressed during Bucs rookie mini-camp this past weekend.
For more on this story visit: Deveron Carr Channels Frustration Into a Positive Result [1] by Bucs Insider Jenna Laine
[youtube_sc url="http://youtu.be/8j2Q5rrHTek" autoplay="1″]
Bucs Rookie Mini-Camp: Deveron Carr by Matthew SardoArticle printed from : http://www.sportstalkflorida.com
URL to article: http://www.sportstalkflorida.com/bucs-rookie-mini-camp-deveron-carr/
URLs in this post:
[1] Deveron Carr Channels Frustration Into a Positive Result: http://www.sportstalkflorida.com/draft-deveron-carr/
Click here to print.
Copyright © 2011 ESPN Florida. All rights reserved.


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Posted: Tuesday, January 22nd 2013 at 8:49am
pBy Ken Stanford Staff I was surprised & sincerely humbled to received the "Drum Major For Justice Award" today from the NewTown Florist Club and local NAACP. Our struggle for Progress continues - and with great humility I'll stay, stand and push with you every step of the way.
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© Copyright 2015 AccessNorthGa.com
All rights reserved. This material may not be published, broadcast, rewritten, or redistributed without permission.


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"BUILDING BLOCKS of HIB"
About "Building Blocks of HIB"
"Building Blocks" was developed by Chase Wilson Education's Director of Educational Programs Andrew Yeager, and is an unparalleled tool that helps teachers, counselors, and school administrators address bullying by understanding and confronting the issue like never before...
The Building Blocks of HIB: Bullying Re-Defined was designed for students in grades 6-12 and is comprised of three distinct sections:
Part One: "The Building Blocks of Bullying"
We redefine bullying – dispelling common myths and exposing the underlying roots of bullying behavior. The curriculum provides a detailed description and analysis of the 20 "Building Blocks" that lead to harassment, intimidation, and bullying (HIB). This information allows educators and students to understand and interpret the true motivations behind bullying like never before.
Part Two: "Core Lessons, Classroom Infusion Lessons, & Film Analysis"
Using the "Building Blocks" as a foundation; this highly detailed section provides teachers with a wide variety of lessons to use in the classroom.
Core Lessons: An introduction and detailed description of the "The Building Blocks," including a Building Blocks Checklist and Behavioral Assessment Worksheet, to be used in conjunction with multiple Case Studies for student analysis.
Classroom Infusion: A variety of lessons that subtly "infuse" anti-HIB education within a variety of subject areas. Lessons are provided for English Language Arts, Math, Science, History, Physical Education and Health, World Languages, Music, Visual Arts, and accommodations for Special Education.
Film Analysis: Using the highly effective anti-bullying film "Sticks & Stones," students address specific issues such as cyber-bullying, homophobia, hate speech and peer pressure.
Part Three: "Counseling the HIB-Involved Student"
This section provides detailed therapeutic strategies for counseling HIB-involved students and includes assessment forms and guidelines for creating effective treatment plans and documenting student progress.
"BUILDING BLOCKS of HIB"
Book Sections
Order Now
Total Cost for Book $799.99 + $10 Shipping/ Handling
Click here to download order form or


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November 23, 2010
Thank you in Spanish
I took three years of Spanish in high school and four semesters in college and I still can't speak it very well.
But I can make a pretty good taco if I tried. If I ever moved away from Texas I think I'd miss Mexican food the most.
It is difficult to tell from the picture but I used some dimensional dots to make the taco shell look more 3D on this card.
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Active Older Adults
Older adults are some of our most loyal YMCA members. Here at the North Suburban Y, seniors have a chance to keep active and grow in spirit, mind and body. New friends and new opportunities add joy to life. The Y also gives older adults a chance to volunteer their time and talents with others, such as children and teens.
Physical activity is essential in maintaining a higher quality of life and independence among seniors. Regular exercise provides many practical benefits, including reducing the risk of diseases and conditions such as diabetes, osteoporosis, coronary artery disease and high blood pressure. Stronger muscles, better balance and coordination, and higher energy levels all work together to maintain or improve basic living skills.
Programs include group exercise classes, social events, low impact water exercise, community education and more!


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Don't see your question? Visit our help section.
Get access to great in-store deals and local pick-up
Sign up for our email deals newsletter!
12th Annual Interactive Achievement Awards Winner: Outstanding Achievement in Game Play Engineering Maxis, makers of The Sims, present the next big bang - SPORE. Create your unique creature and guide it on an epic journey through a universe of your own creations. Play any way you choose in the five evolutionary stages of Spore: Cell, Creature, Tribe, Civilization, and Space. How you play and what you do with your universe is entirely up to you. Spore gives you a variety of powerful yet easy-to-use creation tools so you can create every aspect of your universe: creatures, vehicles, buildings, and even starships.
The download version* of this product is not eligible for refunds and is only available for purchase in the United States, Canada and Mexico. *PC compatible only.
PC compatible only.


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More reviews by carbonmonoxide
This lipstick goes on very uneven without something underneath, but it looks absolutely amazing with NYX Dolly Pink lip liner underneath.
Just saw that this product was discontinued, as is my luck. All my fave MAC lipsticks are! First Made With Love, then the Hello Kitty Cute-ster... sigh. In any case, I finally found the perfect way to wear this lipstick. I'm super pale with very pale lips, so I wasn't worried about this color not showing up. Originally, though, it came out chalky as some reviewers mentioned. What I do is prep my lips with either Labello Rose lip balm or the Nivea version, then apply a layer of this, blot, and apply again. I finish with the Labello Rose on top to soften it and make it melt into the lips, and I get the perfect nude lip to go with dark eye makeup and dark hair. A real winner! I feel very mod Mad-Men type with this lippie :-)
More reviews by xoxoprincesscandyxoxo
This is by far the best lipstick I have ever bought - a gorgeous light pink - the shade I have always been searching for! Having very pigmented lips, this colour looked amazing on me. Paired with a smokey eye, it looked so beautiful! Sadly, this lipstick was part of the MAC Fashion Flower limited edition range :( I've finished it all up and I can't find a similar colour anywhere! If it is repromoted, I will definitely stock up on it!
1 out of 1 people found this review helpful. Did you? Yes No
I purchased this at the beauty sample sale at my office so I did not pay full price. It looks absolutely terrible on me. I'm very pale skinned, my lips are not super pale though and they looked pinkish through this, I also have red tones in my skin which this emphasized.
However it is a great creamy formula and high quality like you expect from M.A.C. lipstick. So it's great for someone other than me.
I thought this was going to look like Pretty Please but it doesn't, similar colour but Mlle has much better coverage and better staying power. I think it might look like Pretty Please on someone with pale lips though. I love this colour!
This is one of the worst lipsticks I have ever bought from MAC. It looks like I applied chalk to my lips! It has a very dry texture too. Back it went.
This lipstick is a very pretty light pink color. For a glaze formula mlle gives exceptional coverage and is moisturizing. I think this would look best on lighter skin tones because of how light the coloring is. One of my favorite lipstick buys this year!
I just bought this today from the Fashion Flower collection and I absolutely love it! It's a very light pink, very creamy, moisturizing and a glaze finish. i'm very fair so it looks pretty great on me, but i can see it washing some people out. This is LE so i would go out and get my hands on it ASAP!!!! love it!
I'm so glad that this lipstick was repromoted in the Fashion Flower Collection! This limited edition lipstick is a light white pink color with a glaze finish. It is the perfect light pink lipstick that I've been searching for.
More reviews by DianaLaColombiana
I would buy a million of these if I had the chance. This pink is the color I have been searching for all of my life! It's my HG lipstick of all time. I have searched for a similar color and none can compare :(. I only have one pop too...I'm very sad. It's the perfect palest pink you'll ever find. It's very smooth and it moisturizes your lips. it's whitish pinkish and looks incredible with bright colored eyes or dark liner. Please bring this back, I promise to stock up like crazy!! The closest I have come to this color is strawberry milk mixed with nyx milk pencil, but even then, it doesn't do it. HELP me find this :(!


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Cytomegalovirus (CMV) Quantitation/Viral Load
Serial measurements of CMV viral load can be used to monitor the level of viral reactivation and/or disease activity, particularly in the post-transplant and chemotherapy settings.
CMV levels will be measured following DNA extraction from plasma, using quantitative real-time PCR.
Test Parameters
The lower limit of detection of this assay is 125 CMV genome copies/ml plasma. The lower limit of quantitation of this assay is 250 CMV genome copies/ml plasma. CMV detected below that level will be reported as "low positive." CMV DNA is rarely detected in the plasma of healthy immunocompetent individuals.
Turnaround Time
3 days
Sample Requirements
2-5 ml peripheral blood in lavender top (EDTA) tube.
CPT Codes
The CPT codes provided are based on AMA guidelines and are for informational purposes only. CPT coding is the sole responsibility of the billing party. Please direct any questions regarding coding to the payer being billed.


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Welcome to the nEDM experiment.
The goal of the nEDM experiment at the Spallation Neutron Source (SNS) is to search for a neutron electric dipole moment (EDM) with a sensitivity below 5 x 10^(-28) e-cm as a signature of Charge-Parity (CP) violation. The experiment uses spallation neutrons from the SNS at Oak Ridge National Laboratory that are cooled with superfluid 4He. A novel 3He co-magnetometer is also a key component of the experiment in order to limit systematic uncertainties.


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Syracuse, NY — Evan Rankin netted the game-winning goal at 8:21 of the third period, helping the Syracuse Crunch to a 2-1 victory against the Albany Devils Friday at the War Memorial at Oncenter. The teams were tied 1-1 after two period and Rankin followed up on his own rebound to end a three-game losing streak against Albany.
With the loss and a Providence (83 pts) shootout win, the Devils move to seventh place in the Eastern Conference with a 35-22-4-8 record (82 pts.). Albany also lost ground on fifth-place Wilkes-Barre/Scranton (86 pts), which won against Bridgeport.
Harri Pesonen scored the Devils goal, which opened the scoring at 11:30 of the second period. Entering the slot, he fired a shot wide right, but the puck deflected off the end board and popped back in front where he buried his 13th goal of the season. Alexander Urbom and goaltender Scott Wedgewood were credited with the assists.
Syracuse tied the game when Cedric Paquette scored off a rebound with 2:02 remaining in the second period.
Wedgewood finished with 23 saves for just his second loss in his last seven starts. Entering the night, he had a 1.32 goals-against average and a .942 save percentage in his last seven games.
At the other end, Kristers Gudlevskis made 16 saves for his 17th win of the season.
The Devils, who are 3-2-0-0 against the Crunch this season, went 1-3 on the power play and 2-2 on the penalty kill.
Next up, the Devils will try and close the gap between the Penguins with a 7:05 pm start at Mohegan Sun Arena. The game is available online or on mobile devices at ahllive.com. Additionally, the game can be heard on 104.5 "The Team" ESPN Radio.
Goaltenders: Scott Wedgewood, Keith Kinkaid
Defensemen: Brandon Burlon, Seth Helgeson, Raman Hrabarenka, Dan Kelly, Corbin McPherson, Alexander Urbom
Forwards: Reid Boucher, Mike Hoeffel, Cam Janssen, Stefan Matteau, Rod Pelley, Harri Pesonen, Mattias Tedenby, Scott Timmins, Joe Whitney, David Wohlberg, Darcy Zajac, Kelly Zajac


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The Sotheby's International Realty Canada Team of Niagara-on-the-Lake and the Niagara Peninsula is inspired by the stunning atmosphere of the Niagara Region, which is a fabulous blend of agriculture, history, culture, cuisine and quality of life that is unique in Canada.
The Niagara Collection is the premiere site for real estate inquiries throughout the Niagara Region.
Increasing Exposure for our Listings
In addition to our partnerships with the New York Times, International Herald-Tribune, Wall Street Journal and The Globe & Mail, we have secured two new extensive and exclusive campaigns this year with BBC, the world's largest broadcasting corporation, and The Daily Telegraph, the best-selling of all quality newspapers in the UK.
Both collaborations are the first of their kind for both the BBC and The Daily Telegraph, offering custom content that marries editorial and the listings that the Sotheby's International Realty LLC network represents. At the core of our collaboration with The Daily Telegraph is our participation in their new World's Best Places to Live online feature. We will have 200 pages of custom content built in conjunction with our network's locations, interactive maps will integrate all offices and we will have a dedicated microsite to house our program content. The interactive global maps provide users with a bird's eye view of our locations, creating a connection to all of our listings to the world.


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Don't just play games, make them! Games Creation is the ultimate experience.
Get a Certificate in European / International Computer Driving License.
Technology & Fun are at the core of everything we do at the Summer Tech Camp!
Learn how to use Photoshop to create professional images for both print & web.
Learn how to design, build and upload a website using Adobe Dreamweaver.
HTML, CSS & jQuery go hand-in-hand and are essential skills for web professionals.
Introduces Java as an implementation language for object-oriented applications.
Learn the skills to develop HTML5 web applications using Microsoft Visual Studio 2010.
Create awesome games with Unity games development tool.
With this course you will understand and master the basics of computer technology.
Choose between 3 courses and get an international CompTIA certificate.
Giving you the fundamentals to grow with SharePoint & Office 365.
An intensive program that awards candidates with a higher-level certification.
Computer Studies is an ideal foundation for further study in the ICT sector.
ECDL Core
Certificate of Achievement
ECDL Image Editing
Training Methodology
Official Courseware will be used
Hands-On exercises in class
Extra exercises to be studied after class
Course Outline
Photoshop course provide instructions on how to use Photoshop to create professional-looking images for both print and the Web. In this course, students will learn about image copyright, identify the components of the Photoshop environment, learn about the differences between raster and vector graphics, and learn how to use Adobe Bridge. Students will explore various methods of selecting image areas and will learn how to modify and manipulate selections. In addition, students will learn how to work with text, layers, and layer effects; how to adjust, retouch, and resize images; and how to prepare images for printing and the Web.


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16 Amazing Anti-Aging Beauty Tips
Tried and true beauty tips to keep your skin looking young and fresh.
Write Off Aging
Build a look-younger arsenal with these brow, lip, and eyeliner pencils:
Sormé Treatment Cosmetics Waterproof Eyebrow Pencil ($11, sorme.com for retail locations). Its slight shimmer enhances brows' natural glossiness. And it creates soft highlights, making brows appear fuller when hit by light.
Make Up For Ever Lip Line Perfector ($18, sephora.com). This clear anti-feathering tool works with any lip shade and any color of lipstick.
Physicians Formula Shimmer Strips Custom Eye Enhancing Eyeliner Trio ($11, drugstore.com). These soft-tipped liners won't tug at delicate eye skin, and each one comes with a sharpener built into its cap so you can keep your lines crisp and well-defined.
Stuart Tyson/Studio D


text: GUESS THE IDENTITY OF THE EX-SEXPOT. By hurricanevanessa on March 15, 2012 in Fashion, Laugh, Men His new girlfriend is called Ruth Wilson. She's an actor, and not that fussy about the way he dresses. Obviously. Who is he? There should be a Jude Law against such crimes of fashion. (And a law against bad writing, too. I know that.) Via Lainey Gossip Tweet


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Expression of the betaine aldehyde dehydrogenase gene in barley in response to osmotic stress and abscisic acid
- Manabu Ishitani,
- Toshihide Nakamura,
- Seung Youn Han,
- Tetsuko Takabe
- … show all 4 hide
Rent the article at a discount
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Get AccessAbstract
When subjected to salt stress or drought, some vascular plants such as barley respond with an increased accumulation of the osmoprotectant glycine betaine (betaine), being the last step of betaine synthesis catalyzed by betaine aldehyde dehydrogenase (BADH). We report here cloning and characterization of BADH cDNA from barley, a monocot, and the expression pattern of a BADH transcript. An open reading frame of 1515 bp encoded a protein which showed high homology to BADH enzymes present in other plants (spinach and sugar-beet) and in Escherichia coli. Transgenic tobacco plants harboring the clone expressed high levels of both BADH protein and its enzymatic activity. Northern blot analyses indicated that BADH mRNA levels increased almost 8-fold and 2-fold, respectively, in leaves and roots of barley plants grown in high-salt conditions, and that these levels decreased upon release of the stress, whereas they did not decrease under continuous salt stress. BADH transcripts also accumulate in response to water stress or drought, indicating a common response of the plant to osmotic changes that affect its water status. The addition of abscisic acid (ABA) to plants during growth also increased the levels of BADH transcripts dramatically, although the response was delayed when compared to that found for salt-stressed plants. Removal of plant roots before transferring the plants to high-salt conditions reduced only slightly the accumulation of BADH transcripts in the leaves.
- Amzallag GN, Lerner HR, Poljakoff-Mayber A: Interaction between mineral nutrients, cytokinin and gibberellic acid during growth of Sorghum at high NaCl salinity. J Exp Bot 43: 81–87 (1992).
- An G, Ebert PR, Mitra A, Ha SB: Binary vectors. In: Gelvin SB, Schilperoort RA (eds) Plant Molecular Biology Manual A3, pp. 1–19, Kluwer Academic Publishers, Dordrecht (1989).
- Arakawa K, Takabe T, Sugiyama T, Akazawa T: Purification of betaine-aldehyde dehydrogenase from spinach leaves and preparation of its antibody, J Biochem 101: 1485–1488 (1987).
- Arakawa K, Katayama M, Takabe T: Levels of betaine and betaine aldehyde dehydrogenase activity in the green leaves, and etiolated leaves and roots of barley. Plant Cell Physiol 31: 797–803 (1992).
- Arakawa K, Mizuno K, Kishitani S, Takabe T: Immunological studies of betaine aldehyde dehydrogenase in barley. Plant Cell Physiol 33: 833–840 (1992).
- Bano A, Dorffling K, Bettin D, Hahn H: Abscisic acid and cytokinins as possible root-to-shoot in xylem sap of rice plants in drying soil. Aust J Plant Physiol 20: 109–115 (1993).
- Boyd LA, Adam L, Pelcher LE, Mchughen A, Hirji R, Selvaraj G: Characterization of an Escherichia coli gene encoding betaine aldehyde dehydrogenase (BADH): structural similarity to mammalian ALDHs and a plant BADH. Gene 103: 45–52 (1991).
- Brouquisse R, Weigel P, Rhodes D, Yocum CF, Hanson AD: Evidence for a ferredoxin-dependent choline monooxygenase from spinach chloroplast stroma. Plant Physiol 90: 322–329 (1989).
- Creelman RA, Mason HS, Bensen RJ, Boyer JS, Mullet J: Water deficit and abscisic acid cause differental inhibition of shoot versus root growth in soybean seedings. Analysis of growth, sugar accumulation, and gene expression. Plant Physiol 92: 205–214 (1990).
- Davies WJ, Zhang J: Root signals and the regulation of growth and development of plants in drying soil. Annu Rev Plant Physiol Plant Mol Biol 42: 55–76 (1991).
- Dellaporta SL, Wood J, Hicks JB: A plant DNA minipreparation: Version II. Plant Mol Biol Rep 1: 19–21 (1983).
- Green PJ: Control of mRNA stability in higher plants. Plant Physiol 102: 1965–1070 (1983).
- Guiltinan MJ, Mactotte WR, Quatrano RS: A plant leucine zipper protein that recognizes an abscisic acid response element. Science 250: 267–271 (1990).
- Hanson AD, Hitz WD: Metabolic responses of mesophytes to plant water deficits. Annu Rev Plant Physiol 33: 163–203 (1982).
- Hanson AD, May AM, Grmet R, Bode J, Jamieson GC, Rhodes D: Betaine synthesis in chenopods: localization in chloroplasts. Proc Natl Acad Sci USA 82: 3678–3682 (1985).
- Hong B, Barg R, Ho TD: Developmental and organ-specific expression of an ABA- and stress-induced protein in barley. Plant Mol Biol 18: 663–674 (1992).
- Ishitani M, Arakawa K, Mizuno K, Takabe T: Betaine aldehyde dehydrogenase in the Gramineae: levels in leaves of both betaine-accumulating and nonaccumulating cereal plants. Plant Cell Physiol 34: 493–495 (1993).
- Kurkela S, Franck M: Cloning and characterization of a cold- and ABA-inducible Arabidopsis gene. Plant Mol Biol 15: 137–144 (1990).
- Lang V, Palva ET: The expression of a rab-related gene, rab 18, is induced by abscisic acid during the cold acclimation process of Arabidopsis thaliana (L.) Heynth. Plant Mol Biol 20: 951–962 (1992).
- Mattanovich D, Ruker F, Machado AC, Laimar M, Regner F, Steinkellner H, Himmler G, Katinger H: Efficient transformation of Agrobacterium spp. by electroporation. Nucl Acids Res 17: 6747 (1989).
- McCue KF, Hanson AD: Drought and salt tolerance: towards understanding and application. Trends Biotechnol 8: 358–362 (1990).
- McCue KF, Hanson AD: Salt-inducible betaine aldehyde dehydrogenase from sugar beet: cDNA cloning and expression. Plant Mol Biol 18: 1–11 (1992).
- McCue KF, Hanson AD: Effects of soil salinity on the expression of betaine aldehyde dehydrogenase in leaves: investigation of hydraulic, ionic and biochemical signals. Aust J Plant Physiol 19: 555–564 (1993).
- Morgan JM: Osmoregulation and water stress in higher plants. Annu Rev Plant Physiol 35: 299–319 (1984).
- Raschke K: Stomatal action. Annu Rev Plant Physiol 26: 309–340 (1975).
- Rhodes D, Hanson AD: Quaternary ammonium and tertiary sulfonium compounds in higher plants. Annu Rev Plant Physiol 44: 357–384 (1993).
- Sambrook J, Fritsch EF, Maniatis T: Molecular Cloning: A Laboratory Mannual, Cold Spring Harbor Laboratory, Cold Spring Harbor, NY (1900).
- Sanger F, Nicklen S, Coulson AR: DNA sequencing with chain-terminating inhibitors. Proc Natl Acad Aci USA 74: 5463–5467 (1977).
- Skriver K, Mundy J: Gene expression in response to abscisic acid and osmotic stress. Plant Cell 2: 503–512 (1990).
- Thomas JC, McElwain EF, Bohnert HJ: Convergent induction of osmotic stress-responses: abscisic acid, cytokinin, and the effect of NaCl. Plant Physiol 100: 416–423 (1992).
- Tardiu F, Davies WJ: Integration of hydraulic and chemical signalling in the control of stomatal conductance and water status of droughted plants. Plant Cell Environ 16: 341–349 (1993).
- Vernon DM, Ostrem JA, Bohnert HJ: Stress perception and response in a facultative halophyte: the regulation of salinity-induced genes in Mesembryanthemum crystallinum. Plant Cell Environ 16: 437–444 (1993).
- Weigel P, Weretilnyk EA, Hanson AD: Betaine aldehyde oxidation by spinach chloroplast. Plant Physiol 82: 753–759 (1986).
- Weigel P, Lerma C, Hanson AD: Choline oxidation by intact spinach chloroplasts. Plant Physiol 86: 54–60 (1988).
- Weretilnyk EA, Hanson AD: Molecular cloning of a plant betaine-aldehyde dehydrogenase, an enzyme implicated in adaption to salinity and drought. Proc Natl Acad Sci USA 87: 2745–2749 (1990).
- Weretilnyk EA, Hanson AD: Betaine aldehyde dehydrogenase from spinach leaves: purification, in vitro translation of the mRNA, and regulation by salinity. Arch Biochem Biophys 271: 56–63 (1989).
- Winter K, Gademann R: Daily changes in CO2 and water vapour exchange, chlorophyll fluorescence, and leaf water relations in the halophyte Mesembryanthemum crystallinum during the induction of Crassulacean acid metabolism in response to high salinity. Plant Physiol 95: 768–776 (1991).
- Zeevaart JAD, Creelman RA: Metabolism and physiology of abscisic acid. Annu Rev Plant Physiol Plant Mol Biol 39: 439–473 (1988).
- Title
- Expression of the betaine aldehyde dehydrogenase gene in barley in response to osmotic stress and abscisic acid
- Journal
Plant Molecular Biology
Volume 27, Issue 2 , pp 307-315
- Cover Date
- 1995-01-01
- Print ISSN
- 0167-4412
- Online ISSN
- 1573-5028
- Publisher
- Kluwer Academic Publishers
- Additional Links
- Topics
- Keywords
- glycine betaine
- betaine aldehyde dehydrogenase
- osmotic stress
- gene expression
- plant hormone
- abscisic acid
- Industry Sectors
- Authors
- Manabu Ishitani (1)
- Toshihide Nakamura (1)
- Seung Youn Han (1)
- Tetsuko Takabe (1)
- Author Affiliations
- 1. BioScience Center, Nagoya University, Chikusa, 464-01, Nagoya, Japan


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So let's run down the checklist: Rockin' metal soundtrack? Check. Buckets of violence? Check. Overwrought mythology? Check. Bitchin' Hot Rod with flame exhaust? Check. Demon wings? Check. Sexy metal babes? Check. All in a video game format? Very check.
Wait a second, this game wasn't designed by Tim Schafer at all. No, it was designed by the collective fantasies of every teenage boy who's ever lived ... Schafer's just the tool they'll use to see their vision writ large.


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This Election is Every Bit about Barack Obama - Oct 20, 2014Democrats Are Loyal to the Bitter End - Sep 15, 2014The Democratic Fallacy of Justifiable Dishonesty - Jul 07, 2014Why Democrats are Terrified of the Select Committee - May 19, 2014Liberal Intolerance at Rutgers - May 05, 2014Disenchanted Democrats Have a Dilemma - Mar 31, 2014A Direct Answer for Kathy Lemaster - Feb 24, 2014He Has a Pen and He Knows How to Use It - Feb 10, 2014The Imperial Presidency, 2014 - Feb 03, 2014Where Will the Gay Agenda Take Us? - Dec 30, 2013Americans Get a Taste of Socialized Medicine - Dec 02, 2013When Is a Lie Not a Lie? - Nov 11, 2013Obamacare – A White Elephant, Not a Sacred Cow - Oct 21, 2013We Have Assad Right Where He Wants Us - Sep 16, 2013A Reluctant Warrior without a Plan - Sep 09, 2013The Disgrace of the Agitators, Exploiters, and Dupes - Jul 29, 2013Let's Just Strike the Impeachment Clause - Jul 22, 2013
Peter Lemiska has spent more than 28 years in government service. He is a former Senior Special Agent of the U.S. Secret Service and an Air Force veteran. His political commentaries have been widely published on line and in print.
Send the author an Email at firstname.lastname@example.com


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ZAWAWI CUP(L), Jägersro 2009 [01:32]
ZAWAWI CUP(L) 2009 (1200m dt). Jockey Fredrik Johansson and Tertio Bloom makes a nice recovery after a bad start and wins. Tertio Bloom is trained by Fredrik Reuterskiöld. ... Jockey Fredrik Johansson Tertio Bloom ZAWAWI CUP horse racing galopp Jägersro häst
Tags: Jockey, Fredrik, Johansson, Tertio, Bloom, ZAWAWI, CUP, horse, racing, galopp, Jägersro, häst
Virtuoso breaks his maiden at Bangalore Summer 2009 [01:12]
Virtuoso (Local Talent-Allocate) gets his just dues as he wins at Bangalore Summer season for trainer Arjun Mangalorkar and jockey Imran Chisty. ... turf 2009 競馬赛马hippisme cavallo race caballo India Horse Racing Turf Keiba Filly Bangalore Indian colt
Tags: turf, 2009, 競馬, 赛马, hippisme, cavallo, race, caballo, India, Horse, Racing, Keiba, Filly, Bangalore, Indian, colt
Fastest time Pole Bending win [00:39]
My first win pole bending win. 27.42 i think it was. At the Bar Diamond S rodeo in Yrissari New Mexico ... AQHA new mexico horse barrels racing fastest time pole bending poles grey quarter cowgirl cowgurlll rodeo
Tags: AQHA, new, mexico, horse, barrels, racing, fastest, time, pole, bending, poles, grey, quarter, cowgirl, cowgurlll, rodeo
1993 Spinster Stakes - Paseana [03:49]
of seven starts this year, earned $205902 to bring her winnings to $754122 this year. The 6-year-old mare has won $2403303. Wilderness Song, the 1991 Spinster winner and unbeaten in three races at Keeneland, was only a length and a half behind Paseana at the half-mile pole, but faded going into the far turn and ran eighth. Fowda, who won last year's Spinster, didn't handle the off track and finished last. ... keeneland horse racing paseana sid jenny craig ron mcanally chris mccarron dave johnson ...
Tags: keeneland, horse, racing, paseana, sid, jenny, craig, ron, mcanally, chris, mccarron, dave, johnson
1994 Hollywood Turf Handicap - Grand Flotilla [02:35]
rode Grand Flotilla, a 14-1 shot, to victory and a payoff of $30.60 for $2 to win. He was timed in 1:591/5 for a mile and one-quarter on firm turf. Grand Flotilla, a 7-year-old son of Caro, was fourth on the final turn but found room along the rail when thepacesetter, Blues Traveller, drifted out. Grand Flotilla caught Bien Bien with a furlong left, then drew off in the final 150 yards. ... hollywood park horse racing gary stevens bienbien grand flotilla arcangues trevor denman chris mccarron ...
Tags: hollywood, park, horse, racing, gary, stevens, bienbien, grand, flotilla, arcangues, trevor, denman, chris, mccarron
1... 1123 | 1124 | 1125 | 1126 | 1127 | 1128 | 1129 | 1130 | 1131 | 1132 | 1133 ...1157


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Press Release
25th January 2009
Hemel Hempstead Canoe Club Meets Essex Man
Chelmsford was the location for the fourth Essex Winter Series Race. John Bennet competed in the Veteran's category and Slasher Preston (aka Snapper) and Jurassic Petersen attempted to repeat the win they achieved in the previous race at Sudbury. Chelmsford is nintey minutes drive away but it is worth the trip. Chelmsford Canoe Club is new and right next to the river Chelm just outside of the town. Consequently the canadian canoe course was chiefly through the town centre and followed a letter "v" shape whilst the longer eight mile kayak course was a "there and back" route.
The race start was directly outside the club and the canadian canoes set off first. As there was to be a steep turn soon after the start it was important to get corner first and be able to control the race. However the first stroke from Slasher's right arm was sufficient to snap the carbon fibre paddle shaft into two pieces.
This was the first time this had happened to him and a number of choice words were heard. The immediate problem was getting to the bank without capsizing as the marathon canoe is a tippy affair and only by breast stroking the water did the pair get to the bank without swimming.
A kind member of Chelmsford canoe club then ran off to the storage shed and found another paddle which Slasher grabbed with thanks and returned to the boat. Only then did he spot it was over a foot longer than he needed and another discussion (with a few more choice words) followed. Then the crew paddled back to the bank to allow Slasher to run the two hundred metres back to the car to collect the spare paddle. Whilst this extra running is going on Jurassic manages to turn the boat around and once the two are reunited they join the race about eight hundred metres behind the other boats.
The course took the pair underneath five bridges before the first turn and the concrete sides of the river bank reflect the waves to provide a difficult paddling surface. To add to this the river was in spate and the higher river lowered the clearance between the bridges and the river surface. On more than one occasion many crews had to bend double to get underneath without banging their heads. Finally the Chelm takes a number of twists and turns as it goes through the town and these were tough to steer around in a boat designed for straight line sprints with no rudder.
Despite these challenges Jurassic and Slasher worked very hard to try to catch up the other two boats. By the first turn they saw the other crews returning from the turn and knew that there was a chance of catching them and by halfway they managed to catch the Mr Harding and Master Harding crew from Leighon Buzzard. A quick sprint enabled them to pass them and set their sights on the leading crew Mr Surrage and Mr Brett. These two were a little more difficult to catch but eventually they drew level with one turn to go. Jurassic and Slasher then overtook to win the race by two and a half minutes in a time of 46 minutes and 28 seconds, both shattered but elated.
John Bennet did the extra miles required of the senior kayak racers where the expected winner was Mark Adams. John came in a few minutes later in a time of one hour and ten minutes, an excellent effort on a wet day with a fast flowing river. See Races page
Next race is the Essex Winter series is at Barking & Dagenham on 8th February and a number of Hemel members will be attending to get some race practise before the Waterside Series races and the Devises to Westminster race at Easter.
(One wonders how it might be that the paddle that Jurassic used for a long period without incident lasted only one stroke in Slashers hands - perhaps he just pulls harder)
Slasher Preston


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Given all the Oscar buzz Lee Daniels' "Precious" has gotten in recent weeks, it was no surprise the Cinema Society's Thursday night screening of the film, cohosted by Tommy Hilfiger, scored an A-list turnout. Kyra Sedgwick, Terrence Howard, Iman, Mamie Gummer, Sandra Bernhard, Agyness Deyn, Donna Karan and Paula Patton were among the revelers who showed up to catch the film (based on the novel "Push" by Sapphire) and mingle at Crosby Street Hotel for the after-party.
But despite all the star power in the room, the surprise entrance of one guest — General Colin Powell — still turned attendees' heads. "We came because we were invited," explained the politician, who had his daughter and assistant in tow. "It's not very often that an old guy like me gets to come to a young people's party like this in the SoHo area." (Powell explained he was wearing a "monkey suit" because he had come straight from a black tie dinner for the National Urban League.)
Competing with Powell for the spotlight was Gabourey Sidibe, the star of the movie, who had selected a glittery number by Torrid for the occasion. "I bought it two days ago and figured tonight would be a good excuse to wear it," explained the actress. "There are not a lot of places I can wear a sequin ball gown shirt."
Presumably, Sedgwick approved. "You look so beautiful," she cooed when Sidibe arrived at the step-and-repeat.
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Thanks Hobgoblin and Cornet Nev - will go for the medical professional and see what happens
Type: Posts; User: Sop_Or_Bass?; Keyword(s):
Thanks Hobgoblin and Cornet Nev - will go for the medical professional and see what happens
My wife is considering stopping playing as when she plays the facial muscles are weakening inside her cheeks and on one is now splitting and hurting. This has built up over years losing more and...
Result of Section C - 4th Section
1. Ebbw Valley Brass
The band are also keen to hear from kit players as our existing player is leaving to go to college shortly.
The Band of the Gloucestershire Constabulary currently need a BBb Bass player to complete the ranks for the summer season.
We rehearse in Cheltenham on Thursday evenings, are non-contesting, and...
Rehearsals for the National Brass Band Finals in September 2012 - The Pavillion, Cheltenham. Just 4 miles from the Racecourse and just off J11, M5. Please contact Val Brown; see...
Following our first Area contest for 5 years last weekend, Lydney Town Band are looking for a euphonium player and a front-row cornet player to complete their ranks.
The band are looking at...
Thanks Deano: I've been passed the following details:
The closing date is Friday 30th March, send an email to Dave Evans SEWBBA secretary and he will send you an entry form in the post....
Have struggled to find any details on this contest on the net. If we were interested in registering (may be too late) or coming along to listen; where do we get the details?
Following our first Area contest for 5 years last weekend, Lydney Town Band are looking for a front row cornet to complete their ranks.
The band are looking at entering a couple of contests this...
Can anyone recommend a top Euphonium teacher within c. 50 miles or so of Cheltenham?
Looking for someone to teach my son who is currently studying grade 8 and needs to take his playing to the next...
Lydney looking forward to their return to the Areas
Good luck to all the Gloucestershire bands this weekend - see you at the bar :-)
Here is something that bugs me.
Now I know that we all try to be lovely and helpful here in tMP land. I know that as I recevied some superb help yesterday with a query I had.
However it really...
Stuart Haigh is looking for a band, but only if it has a new Yamaha Neo available :-) http://www.themouthpiece.com/vb/showthread.php?46743-BBb-Player-looking-for-band
Probably the first note :clap:
A pet hate of mine is not being allowed to applaud a musical performance as part of a more traditional church service...
I remember such a service when the vicar had started requesting that the...
Really proud of Rory - well done. Great rendition of Grandfather's Clock; esp. for a 12 year old :clap:
To me it's the cost of a BBb Bass - I can only play it if a band can lend me one!
Love playing BBb & love playing Sop too (a man of extremes) - both offer their challenges :-)
The list of entrants is on the new WEBBA site http://www.webba.org.uk/results2012.html
These vacancies for the Regional Finals have now been filled and we have a complete band :-)
PolySteel Youth Band are really looking forward to the concert - it's going to be a fantastic night :-)
If you are looking at quintet carols, the look at Big Shiny Brass/Matt Kingston's site. His set is £20 for 40 carols and instantly downloadable. Used them in a quintet last week and will be printing...
Difficult I know - how about 500/1?
We should be taking the Training Band for a couple of contests (Cross Keys and GBBA) but our first run out will be the West of England (eeek!)
Hi Paddy
Lydney Town Band are in the process of re-registering so are expecting to be in the 4th Section :cool:


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Washington Week
Episode #4046
The program on the week's top political events featured a panel conversation on the Bush administration's public statement on its energy and conservation policies and whether its proposal to drill for oil in Alaska is at odds with its mission to conserve the environment; Sen. John McCain's cooperative move with Sen. Joe Lieberman to support gun control in Congress; and the early dialogue on possible candidates--especially Democrats--for the 2004 presidency. [26 minutes]
This episode has not aired in the past few months on Iowa Public Television.
Webcast Extra: Obama's Governing Woes and...
On the Webcast Extra: Christi Parsons fills us in on why the Obama administration does not run as well as the Obama... 09:34
Webcast Extra: 2014 Midterms and Obama's Secret...
On the Webcast Extra, Doyle McManus discusses the role the tea party will play in the 2014 midterm election. Karen... 10:34
HealthCare.gov Troubles, GOP Intra-Party Battle...
Full Program: We analyze the continuing problems with the HealthCare.gov website; Republicans are in a "recovery" mode to reunite... 24:51
Webcast Extra: Inside the Bush-Cheney White...
On the Webcast Extra: New York Times Chief White House Correspondent Peter Baker joins Gwen at the roundtable to... 07:50
Post-Shutdown Washington: Political Divides &...
Full Program: President Barack Obama signed a law to end the government shutdown and extend the U.S. debt limit into 2014. We... 24:50
- Watch more video from this program »
Series Description: WASHINGTON WEEK, PBS' longest-running public affairs series, features Washington's top journalists analyzing the week's top news stories and their effect on the lives of all Americans. Gwen Ifill hosts.
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List your Wildwood, NJ rental with Cabrera Vacation Rentals
Wildwood, NJ vacation Rental Listings (Weekly and Nightly Rentals)
At Cabrera Realty, you will find that our vacation rental management program is both beneficial and hassle-free. You can enjoy the privileges of owning a shore home while having your investment maintained. Our trusted management services for Wildwood, NJ rentals will give you peace of mind in your decision to rent.
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text:
The goal of the Accelerated Bridges Program is to accelerate $3 billion of future investment capacity within the fiscal constraints of the Commonwealth's debt affordability policy to fund at least 250 structurally-deficient bridge rehabilitation and prevention projects over the next eight years, create thousands of jobs, improve the safety and condition of our bridge inventory. As part of the Program, the Administration has established participation goals for minority and women contractors and for women and minorities as part of the contractor labor force.
This information is provided by the Executive Office of Administration & Finance.


text:
Ramada Ligonier
Description provided by Ramada Ligonier
This award-winning Ramada is situated in the heart of charming Ligonier, a designated national historic district, in the beautiful Laurel Highlands of Southwestern Pennsylvania. This Ramada Ligonier hotel provides free wireless high speed Internet access in all meeting and guest rooms, outdoor heated swimming pool, fitness center, and free USA Today. The Ramada Ligonier offers The Bistro an excellent Restaurant and Lounge inside the hotel for your convenience. Also a free hot breakfast buffet if offered for your pleasure. Luxury suites and beautifully appointed guest rooms offer new upscale beds, upscale linens, and spa inspired bath amenities. This Ligonier hotel offers meeting and banquet facilities for groups large and small. Professional onsite meeting coordinators are available to assist with all details. Guests of this Ramada Ligonier hotel may walk to over 60 shops, restaurants and antique stores. Historic Fort Ligonier, the Southern Alleghenies Museum, and Idlewild Soak Zone Park are within 1 Mile. No Pets Permitted. ADA certified service animals are welcome.
List of Amenities for Ramada Ligonier
· Accessible facilities · Accessible parking · Adjoining rooms · Adjoining rooms · Air conditioning · Air conditioning · Alarm clock · Banquet facilities · Bus parking · Business center · Closets in room · Coffee/Tea maker · Coin operated laundry · Complimentary in-room coffee or tea · Conference facilities · Cribs · DVD/video rental · Desk with lamp · Elevators · Exercise gym · Exterior corridors · Family/oversized room · Free local calls · Free newspaper · Free newspaper · Heated pool · High speed internet access · High speed internet connection · Hot breakfast · Ice machine · Interior corridors · Ironing board · Ironing board · Kennels · Meeting rooms · Microwave · Non-smoking rooms (generic) · Outdoor parking · Parking · Recreational vehicle parking · Remote control television · Restaurant · Rollaway bed · Room service - limited hours · Safe · Security · Vending machines · Wheel chair access |
Restaurant Information
The Tavern Ernis Place Golden Wok The Bistro Carol and Daves Roadhouse The Kitchen on Main Du Soleil - Brasserie Ginos Pizza Fox Pizza Diamond Cafe The Furnace The Road Toad The Hollow Tavern Colonial Inn Ligonier Tavern Vallozzis Restaurant First Wok Chinese Rest Pizza Hut Subway Dennys McDonalds Burger KingMeeting Facility
Meeting Room Banquet Room Meeting RoomArea Attractions
Steelers Traing CampSt Vincent College
Frank Lloyd Wrights Kentuck
Laurel Valley Golf Club
Rolling Rock Club
Idlewild Park SoakZone
Frank Lloyd Wright Fallingw
Flight 93 National Memorial
Seven Springs Mtn Resort
Ligonier Highland Games
Fort Ligonier Days Festival
Jennerstown Mtn. Playhouse
Compass Inn and Museum
St Vincent Summer Theatre
Falling Water
Georgian Place Outlet Center
Hidden Valley Ski Resort
Johnstown Flood Museum
Johnstown Incline
Mountain Playhouse
Ohiopyle State Park Rafting
Seven Springs Ski Resort
Westmoreland Museum of Art
Westmoreland County Fairgrounds
Champion Lakes Golf
Duncan House by Frank Lloyd Wright
Bethlen Communities
Bethlen Home
Fred Rogers Center
Latrobe Speciality Metals
Linnrun State Park
Wine Tasting
Winter Sports
Museum Gallery
Water Park
Driving Range
Movie Theater
Champion Lakes Golf Club
Horseback Riding
Sporting Clays Hunting Preserve
Mountain Biking - Seasonal
Donegal Highlands GolfCourse
Glengoney Golf Course
Downhill Skiing
Alpine Skiing
Cross Country Skiing
Exercise Fitness Center
Amusement Park
Nature Preserves
Sightseeing Tours
White Water Rafting
Miniature Golf
Greyhound bus
TAXI Ligonier Valley Limo
Altoona Blair County Arprt
Cambria County Airport
Greater Pittsburgh Arprt
DuBois Regnl Airport
Enterprise Rent A Car
Arnold Palmer Regnl Arprt
Latrboe Airport
Veterans Cab
Valley Limo Service
Red Carpet Limousine
Budget Car Rental
Hertz Car Rental
Spirit Airlines
Miscellaneous Information provided by Ramada Ligonier
· American Dollars is the native currency.
· Check in time is 4:00 PM
· Check out time is 11:00 AM
· Opened in 1965
· 72 rooms.
· 0 suites.
· 3 floors.


text:
Morrisville 19, Faith Christian 3
Faith Christian 211 000 0 - 03 3 0
KISSIMMEE, Fla. — Cliff Lee faced major league hitters for the first time since July 31, when his season ended with an elbow injury.
Israeli Prime Minister Benjamin Netanyahu gave a raucous speech to a joint session of Congress on Tuesday that Vice President Joe Biden and mo…
In my four years in Harrisburg, I developed a specific regimen for mental hygiene: no mind-altering substances before 1 p.m.
Evesham's all-Republican council intends to exercise its legal right to give the silent treatment to members of the public deemed cage rattler…
The second annual Camden Comic Con will be making a scene from 10 a.m. to 5 p.m. Saturday at Rutgers-Camden.
Posted: Friday, April 4, 2014 11:35 pm | Updated: 11:39 pm, Fri Apr 4, 2014.
Friday's softball result: Morrisville wins 19-3
Morrisville 19, Faith Christian 3
Faith Christian 211 000 0 - 03 3 0
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DOYLESTOWN OPEN HOUSE 2/15, 1 TO 4 4240 MARIE CIRCLE Beautiful Landis Greene home with spectacular upgrades! 4 BR, 2.5 bths, fantastic lot. Simply Gorgeous! $499,000 Directions: 61
WARRINGTON OPEN SUN., 2/15, 1 TO 3 2878 HIGHLAND AVE. 4 BR, 2 BA Cape on 1.56 acres. Recent upgrades. C/A, public sewer. Deck, FP, wood floors. Bright & sunny. $279,000. M
DOYLESTOWN BOROUGH OPEN TODAY FEB 15TH, 1-3 PM 465 LINDEN AVE. Uniquely renovated 4 BR, 2 ½ bath Beauty! Open kitchen, dining room, family room. Private master suite & libr
Hatboro. 2BR in town, 2nd flr, bus & train, walk to shops, new kitchen & wall to wall carpets. No pets. $950, avail immediately. 215-675-1627
Doylestown Boro-Rental OPEN TODAY FEB. 22ND, 1-3 PM 4 Barns Court. in Barnes CourtWonderful location! Great Condo! 2 BR, 2 ½ BAs, entrance hall, LR, DR & powder room on 1st
NEW BRITAIN TWP. OPEN TODAY 1-3 PM 105 STOCKTON COURT - SYLVERSMYTHE 4 Bed. 2 ½ Bath Colonial. Finished Lower level perfect for entertaining. 2 Car Garage, fenced backyard backing
DOYLESTOWN OPEN HOUSE 3/1, 1 TO 4 5011 ANN DAVIS DR. Patriots Ridge End Unit 3 BR, 2.5 BA, Move in! $242,000 Dir: 313 to Sawmill Rd to Left on Patriots Ridge to Left on Louise St.
CHALFONT $130/Week. All utilities included. Partly furnished, no pets. NO SMOKING. 215-822-1142
WARRINGTON OPEN SUN., 3/1, 1 - 3 569 MOCKINGBIRD WAY 3 bdrm, 2 ½ bath townhome, finished walkout basement backs to woods, gas fireplace, add'l breakfast room, fresh paint, new flo
DOYLESTOWN AREA Exceptionally Maintained Luxury Apartments 1, 2 BR Garden Style Private Entrance Renovated Kitchens Washer/Dryer in Each Apt. Pool, Playground, Tennis Cats Welcom
WARMINSTER Duplex. 1st floor large 2 BR apt. Off street parking. No pets. $950+ utilities. 215-355-5523.
DOYLESTOWN BOROUGH OPEN TODAY SUN., 3/1, 1-3 PM 125 WEST OAKLAND AVE. Beautiful single, updated kitchen with Carrara marble & Subway tile. Hardwood floors, 2 zoned central
NEW HOPE AREA 1 BR guest house. Furnished. $1500/mo. Call 215-870-2013
Hatboro. 2BR in town, 2nd flr, bus & train, walk to shops, new kitchen & wall to wall carpets. No pets. $950, avail immediately. 215-675-1627
Doylestown Commons 2 BR, washer/ dryer, A/C, lots of closets, no pets. $1150/mo, avail now. 267-992-5126
DOYLESTOWN AREA Exceptionally Maintained Luxury Apartments 1, 2 BR Garden Style Private Entrance Renovated Kitchens Washer/Dryer in Each Apt. Pool, Playground, Tennis Cats Welcom
WILLOW GROVE 1 BR from $1065+ 2 BR from $1200+ Private entrance, washer, dryer, patio or balcony. ** Free Month ** WILLOW RUN APTS. 215-375-7867 westovercompanies.com
Affordable and Adorable Homes Valley View Danboro / Sunnyside UMH Properties 215-766-0351 www.umh.com
WILLOW GROVE 1 BR from $1100+ 2 BR from $1258+ Private entrance, washer, dryer, patio or balcony. ** Free Month ** WILLOW RUN APTS. 215-375-7867 westovercompanies.com
Hatboro Refirbushed 2BR 1BA Duplex appliances, bsmt, near transportation, Avail. Now $895+utilities. No pets. 215-443-0599
DOYLESTOWN BOROUGH BARNES COURT *Wonderful location! Great Condo! *3 BR, 2 ½ Bths, Entrance Hall, LR w/Fireplace, * DR, & Powder Rm on 1st floor. HDWD floors, * Stone Pati
Doylestown Boro 1 BR, 2nd floor, w/ loft. Includes heat! $975. No dogs. Call 215-348-7837 or 267-261-6032
BUCKINGHAM TWP./FURLONG 3 BR, 2½ BA. Gorgeous 9 year old townhouse with finished bsmt, washer, dryer, garage, graniite & hardwoods. Rent includes clubhouse, pool, exercise
Doylestown 3 BR, 2½ BA, 2263 sq.ft. Spacious Summer Hill townhouse w/partially finished bsmt, freshly painted, open floor plan & large deck. No pets. $2,290+. 267-885-4300
DOYLESTOWN BOROUGH OPEN TODAY 1/18, 1-3 PM8 EASTHILL DR. Beautiful Ranch home completely RENOVATED! New plumbing, electric, kitchen, baths & hardwood. New siding, landscapi
WARWICK TOWNSHIP OPEN TODAY 1/18, 1-3 PM 2114 REDBUD LANE Beautiful 3 BED Townhome in BRIDGE VALLEY AT FURLONG! Spectacular New Gourmet Kitchen- A Chef's Delight. end unit, Cul-de-
CHALFONT $130/Week. All utilities included. Partly furnished, no pets. NON SMOKING 215-822-1142
DOYLESTOWN AREA 1 BR, washer/ dryer, heat/hot water & trash included, no pets or smoking. Available Jan 31st$760/mo. 215-768-5699
Doylestown Victorian lg efficiency. All utilities, parking, laundry & porch. No Pets/Smoking $835/mo. 215-345-0755
Warrington 2BR, 2 full BA, handicap accessible, 1st floor, over 55 Forest Ridge, $1400 mo. Call 215-816-2211
DOYLESTOWN BOROUGH O PEN TODAY, 1/11, 1- 3PM 616 NORTH STREET Log Cabin & Office built in 1926 with later additions. Handsome MERCER TILES on each of the 4 Fireplaces. Mas
Upper Black Eddy, Bridgeton Twp. Open Today, 1/11, 1- 3PM 1489 River Road *Stunning contemporary on beautiful 1 acre overlooking The River with breathtaking views. *Walls of windo
Baliwick Condo w/ Loft Total of 1582 sq.ft. Call 215-968-4224 Ask for Ken for more details
Willow Grove 3 BR, single car driveway. $1650 per month. 1st, last security. 267-644-6448, leave message
DOYLESTOWN BOROUGH *Much Sought after Doylestown Boro rental. *3 BR, 2 ½ BA home combing the old w/the modern aesthetics *1st floor master w/private porch *2 car garage, studio/wo
Jamison 1st Flr, 2 BR, Washer/Dryer, No Smoking. Small pets OK. Avail 2/1/15 $1200/mo. 215-343-3248
Doylestown Boro. 3BR, 1½BA, FR w/ FP, Office, Laundry Room, Patio, Gar. Gas Heat, A/C. Short walk to town or shopping center. No Pets/ Smoking. $1600/mo +utilities. Avail. 2/1. Cal
Horsham Duplex. Bottom floor. 3 BR. Dishwasher. Bsmt. $1150+ utilities. Avail now. 215-443-7800
Horsham 2 BR. Washer, dryer, C/A, dishwasher,fridge, $1125 + electric. Avail now. Call 215-443-7800
Carpentry Tile Masonry Additions Garages Roofing Siding Over 40 Years. PA041425 Leeland Builders, 267-474-8623
Skilled & Experienced Handyman Painting, Electrical, Plumbing, Carpentry & More! Free Estimates. Licensed & Insured Call Tom: 215-356-2767 www.1travelntool
Affordable Craftsmanship Carpenter / Handyman / Paint All Types Home Repair & Remodeling Windows & Doors, Over 35 Years Call Gary 215-343-1720
Affordable: Transfer Switches Generator Installation VIP Electric Call 267-566-9506
Affordable Craftsmanship Carpenter / Handyman / Paint All Types Home Repair & Remodeling Licensed & Insured, Over 35 Years Call Gary 215-343-1720
Affordable Craftsmanship Carpenter / Handyman / Paint All Types Home Repair & Remodeling Licensed & Insured, Over 35 Years Call Gary 215-343-1720
John Cooke CPA, MBA, CGMA Tax Return Preparation Individuals & Small Businesses 215-630-9083 firstname.lastname@example.com
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text:
Lawyer Atticus Finch defends the real mockingbird of Harper Lee's classic, Puliter Prize-winning novel--a black man charged with the rape of a white woman. Through the eyes of Atticus's children, Scout and Jem Finch, Harper Lee explores with rich humor and unanswering honesty the irrationality of adult attitudes toward race and class in the Deep South of the 1930's.
"synopsis" may belong to another edition of this title.
"When he was nearly thirteen, my brother Jem got his arm badly broken at the elbow.... When enough years had gone by to enable us to look back on them, we sometimes discussed the events leading to his accident. I maintain that the Ewells started it all, but Jem, who was four years my senior, said it started long before that. He said it began the summer Dill came to us, when Dill first gave us the idea of making Boo Radley come out."
Set in the small Southern town of Maycomb, Alabama, during the Depression, To Kill a Mockingbird follows three years in the life of 8-year-old Scout Finch, her brother, Jem, and their father, Atticus--three years punctuated by the arrest and eventual trial of a young black man accused of raping a white woman. Though her story explores big themes, Harper Lee chooses to tell it through the eyes of a child. The result is a tough and tender novel of race, class, justice, and the pain of growing up.
Like the slow-moving occupants of her fictional town, Lee takes her time getting to the heart of her tale; we first meet the Finches the summer before Scout's first year at school. She, her brother, and Dill Harris, a boy who spends the summers with his aunt in Maycomb, while away the hours reenacting scenes from Dracula and plotting ways to get a peek at the town bogeyman, Boo Radley. At first the circumstances surrounding the alleged rape of Mayella Ewell, the daughter of a drunk and violent white farmer, barely penetrate the children's consciousness. Then Atticus is called on to defend the accused, Tom Robinson, and soon Scout and Jem find themselves caught up in events beyond their understanding. During the trial, the town exhibits its ugly side, but Lee offers plenty of counterbalance as well--in the struggle of an elderly woman to overcome her morphine habit before she dies; in the heroism of Atticus Finch, standing up for what he knows is right; and finally in Scout's hard-won understanding that most people are essentially kind "when you really see them." By turns funny, wise, and heartbreaking, To Kill a Mockingbird is one classic that continues to speak to new generations, and deserves to be reread often. --Alix Wilber
From the Publisher:Featuring a new introduction by the author, this specially packaged, popularly priced hardcover edition of an American classic (with more than 30 million copies sold) celebrates the 35th anniversary of its original publication.
"About this title" may belong to another edition of this title.
Book Description HarperLargePrint Classics. Paperback. Book Condition: New. Bookseller Inventory # DADAX0060933275
More Information About This Seller | Ask Bookseller a Question
Book Description HarperLargePrint Classics. Paperback. Book Condition: New. Bookseller Inventory # P110060933275
More Information About This Seller | Ask Bookseller a Question


text:
Spring Mountain Free Trappers like to shoot
Mar 22, 2015
Spring Mountain Free Trappers hold a black powder rifle and pistol shoot, along with knife and hawk competitions, once or twice a month.
These are at the Blue Tree Primitive Campground on Lee Canyon Road or in Lovell Canyon during the summer and at various locations during the winter, and are for folks of all ages.
For more information go here.
Submit your community event to Jay Bartos.
Subscribe to an RSS feed of upcoming events.
Return to list of events.


text:
Booking Class | V
Reservations | Reservations are required for all sectors.
Purchase & Ticketing | Ticketing must be completed within 24 hours after reservations are made.
Outbound Travel Period | 24th December 2014 - 27th December 2014 and 11th January 2015 - 15th Febuary 2015 and 23rd Febuary - 14th June 2015.
Blackout | None
Minimum Stay | None
Maximum Stay | 1 Month
Applicable Airline | Operated by Delta Air Lines
Stopover | Not permitted
Changes | HK$1,500 per transaction
Refunds | Not permitted
*Additional taxes/fees/restrictions/baggage charges may apply.
Destination |
Fares* from |
Seattle |
Enjoy an additional 5% discount when purchasing online, click here for more details. |
Terms & Conditions
Baggage Charges:
For travel between United States/Canada/PR/U.S. Virgin Islands /South America (except Brazil) and Asia (except Cambodia, Indonesia, Malaysia, the Philippines and Vietnam), 100 USD fee for second checked bag. Contact a Delta agent or see Excess Baggage for details.


text: Glad you could stop by. For those of you familiar with the old site you're probably wondering what the hell happened with all the blog and YouTube posts. Never fear, they are safely tucked away into the back corner of the room, and I might pull a few out and dust them off from time to time. Until then we're starting fresh, and I'll update the other websites as time permits. Some of the sites, however, will either go away or see very little interaction. I just don't have the time to cross-post and update everything. In the meantime you can still find me on Twitter @KD_Rush and my Twitch channel here.


text:
2000 block of E. Prairie -- St. Louis, MO
ST. LOUIS, Mo. (KMOV.com) -- Police are searching for four suspects after a teenager was shot in the leg in north St. Louis on Friday night.
The shooting happened in the 2000 block of East Prairie Ave. around 11:15 p.m.
Authorities say the 18-year-old victim was attacked by four unknown suspects, one of whom was armed with a pistol. The armed suspect struck the victim in the head, according to police, and a struggle ensued.
The suspect reportedly fell to the ground, then fired several shots at the victim as he fled. The victim suffered a graze wound to his upper thigh, and was taken to the hospital in stable condition.
A police investigation into the attack is ongoing.


text:
Stoke City bid for Tottenham Hotspurs' Crouch Palacios
Stoke City have made a final offer to Tottenham for striker Peter Crouch and midfielder Wilson Palacios.The Potters have been in talks with Spurs for several weeks. Chairman Peter Coates told BBC Radio Stoke: "We've made our last bid, the ball is in their court. We shall not be negotiating from where we are. "The last conversation I had with Spurs, we had not agreed anything. We'll see what happens, but we haven't got any further." Crouch, 30, began his career at Spurs as a trainee, and re.... read more
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text:
New Rules Prevent Duplicated Losses
IRS Responds to Consolidated Return Defeat in Rite Aid
By Nick Morrow
Generally, the loss disallowance rules, which the Treasury Department issued in 1991, serve to disallow losses on the sale of subsidiary stock by a corporate group that files a consolidated return. The aim of these regulations was twofold. First, the regulations were intended to prevent corporate taxpayers from avoiding the recognition of corporate income tax on distributions of appreciated property. Thus, the intent was to thwart transactions that had been devised to use the consolidated return rules to circumvent the portion of the Tax Reform Act of 1986 that repealed the so-called General Utilities doctrine [General Utilities Co. and Operating Co. v. Helvering, 296 U.S. 200 (1935)]. (The "Son of Mirror" technique could be used to allow a consolidated group to circumvent the repeal of General Utilities. Typically, such a transaction enabled corporate taxpayers to dispose of unwanted assets in an acquisition without recognizing taxable gain or loss.)
The second aim of the loss disallowance rules was to prevent taxpayers from using the consolidated return rules to generate duplicated losses. Duplicated losses occur when the corporate taxpayer uses the consolidated return rules to achieve two tax deductions from a single economic loss.
Example 1: Basic example. In Year 1, P forms S with a capital contribution of $500, and in return receives all of the S stock. S purchases an asset for $500; the asset subsequently declines in value to $300 (assume, for simplicity, that no depreciation is allowed or allowable on the asset). In Year 2, P sells the S stock to an unrelated third party for $300 and recognizes a $200 loss ($300 realized on the sale, less P's $500 basis). Subsequently, S sells the asset for $300 and also recognizes a $200 loss ($300 realized on the sale, less the $500 basis that S held). Other sections of the IRC, such as section 382, could apply to affect the ability of S to use the loss on the sale of its asset. Often these impediments to use the loss could be overcome with planning.
The Treasury Department and the IRS consider it unreasonable for a tax benefit to be obtained twice when in fact only one economic loss has occurred. The loss disallowance rules of Treasury Regulations section 1.1502-20 took care of this perceived abuse by disallowing losses on sales of subsidiary stock. In Example 1, the loss disallowance rules of section 1.1502-20 as issued in 1991 would have disallowed the loss of $200 that P would have realized on its sale of S stock. Only a single tax benefit—the loss on the asset sale by S—would be allowed, because economically only one loss had occurred.
Some tax planners have devised other creative transactions to generate duplicated losses and to keep them within the same consolidated group. Note that in Example 1, S achieves the tax benefit of the loss on the asset sale after it has left the P group. Thus, different owners benefit from the duplicated loss: P benefits from the loss on the sale of S stock (absent application of the loss disallowance rule), and S benefits on the sale of the asset only after it has been sold by P to new owners. Taxpayer P could undertake certain tax planning steps to keep both the tax benefit of the loss on the sale of S stock and the loss on the sale of the asset within the P consolidated group, and thereby obtain two tax benefits from a single economic loss.
Such creative transactions might involve selling high-basis common or preferred stock in S for a tax loss while P retains ownership of sufficient common stock in S such that the subsidiary remains a member of the P consolidated group. On the subsequent sale of the loss asset by S, the P group again receives a tax benefit, duplicating the loss recognized previously on the sale of stock. Ultimately, the temporary regulations section 1.1502-35T that the IRS adopted in 2003 (replacing certain facets of the loss disallowance rules of 1.1502-20) aims to prevent the duplication of losses if the tax benefits are enjoyed by the same consolidated group. Losses generated by sales of the stock of a member of a consolidated group, such as the one described in Example 1, would not be disallowed under the temporary regulations of 2003, because the tax benefits of the stock sale and the loss asset are achieved by two different, unrelated taxpayers.
Rite Aid
In 1984, Rite Aid purchased sufficient stock in a subsidiary, Penn Encore, for it to be included in Rite Aid's consolidated tax filing. In 1994, Rite Aid sold its entire interest in Penn Encore to an unrelated third party, CMI Holding Corporation. Rite Aid realized a loss of approximately $22 million on the sale (net proceeds of $16.5 million, less adjusted basis in CMI shares of approximately $38.5 million). Rite Aid claimed the $22 million loss on its consolidated income tax return. The IRS disallowed the $22 million loss, citing the loss disallowance rules of Treasury Regulations section 1.1502-20. Those rules generally serve to disallow the loss on the sale of the subsidiary stock to the extent that the adjusted basis of the subsidiary's assets exceeds the fair market value immediately preceding the sale. In the instant case, Penn Encore's adjusted basis in its assets exceeded the fair market value immediately preceding the sale of the Penn Encore stock by Rite Aid by approximately $28 million. Because the $22 million loss realized by Rite Aid was less than this amount, the IRS cited section 1.1502-20 to disallow the entire $22 million amount.
Rite Aid disagreed with the IRS' assessment. After losing its claim for refund on summary judgment in the U.S. Claims Court, Rite Aid appealed its case, ultimately to the Federal Circuit Court, which agreed with the taxpayer that the loss on the sale of Encore should not be disallowed on account of duplicated losses, holding that the duplicated loss factor of regulation 1.1502-20 was an invalid use of regulatory authority:
The purpose of section 1502 is to give the Secretary authority to identify and correct instances of tax avoidance created by the filing of consolidated returns. … Therefore, in the absence of a problem created from the filing of consolidated returns, the Secretary is without authority to change the application of other tax code provisions to a group of affiliated corporations filing a consolidated return. …
In our view, there is no requirement that a taxpayer acquiesce in a regulation promulgated outside the authority delegated by Congress. The "bitter with the sweet" does not include the invalid. The loss realized on the sale of a former subsidiary's assets after the consolidated group sells the subsidiary's stock is not a problem resulting from the filing of consolidated income tax returns. The scenario also arises where a corporate shareholder sells the stock of a non-consolidated subsidiary.
Because the Federal Circuit Court did not view the loss on the sale as created by the filing of a consolidated return, the operation of the loss disallowance regulation as it applied to Rite Aid was invalid.
IRS Response to Rite Aid
The IRS disagreed with the decision in Rite Aid, but stated (Notice 2002-11 IRB 2002-7, 526) that "in the interests of sound tax administration" it would not continue to litigate the validity of the loss disallowance regulations. The IRS further stated its view that the court decision invalidated only the duplicated loss element of the loss disallowance rules under Treasury Regulations section 1.1502-20, not other factors, such as the aim of the regulation to prevent circumvention of the General Utilities doctrine. In March 2002, the Treasury Department issued Temporary Regulations section 1.337(d)-2T, which was designed to prospectively supercede Treasury Regulations section 1.1502-20 and provide guidance on the application of loss disallowance on sales of stock of members of a consolidated group. More specifically, Temporary Regulations section 1.337(d)-2T applies to sales of stock for periods after March 6, 2002. Transition rules in the regulations allow for certain elections to be made [see Treasury Regulations section 1.1502-20T(i)] to permit the continued application of 1.1502-20T if a sale of subsidiary stock is made on or after March 7, 2002, pursuant to a binding written contract in effect before March 7, 2002. Generally, these rules address only two of the factors originally considered in the section 1.1502-20 regulations and do not address the "duplicated loss" factor that was invalidated in Rite Aid. The rules of section 1.1502-20 were constructed to disallow loss on the disposition of a subsidiary by a consolidated group to the extent of extraordinary gain disposition, positive investment adjustments, and duplicated loss. Temporary Regulations section 1.337(d)-2T addresses disallowance of losses attributable to built-in gains (i.e., attributable to extraordinary gain disposition and positive investment adjustments), but does not address the duplicated loss factor.
The Treasury Department proposed section 1.1502-35 in October 2002 in order to address the transactions originally covered by the duplicated loss factor of the section 1.1502-20 rules. This was adopted as a Temporary Regulation on March 11, 2003. The regulation reflects the principles advocated by the IRS in Notice 2002-18 and address the broad concept argued by the government. Notice 2002-18 was issued on March 7, 2002, simultaneous with the issuance of Temporary Regulations section 1.337(d)-2T, as public evidence of the government's intention to address in future regulations the duplicated loss factor that was invalidated by the Rite Aid decision. The notice stated the Treasury Department's intent to "prevent a consolidated group from obtaining a tax benefit from both the utilization of a loss from the disposition of stock (or another asset that reflects the basis of stock) and the utilization of a loss or deduction with respect to another asset that reflects the same economic loss."
Targeted Transactions
The regulations are intended to address at least two types of transactions that may allow a consolidated group to obtain more than one tax benefit from a single economic loss. One type covers situations where a consolidated group absorbs an "inside" loss (e.g., a loss inherent in an asset: the basis of the asset exceeds its fair market value) on the sale of an asset owned by a subsidiary, and a second tax loss on the sale of the subsidiary's stock. The regulations also target transactions whereby a tax loss is generated on the sale of shares of a subsidiary and the group subsequently recognizes a loss on the sale of the asset of the subsidiary. Generally, the regulations apply when a consolidated group disposes of shares in a subsidiary or deconsolidates, and when the basis of such shares exceeds their value at the time of disposition or deconsolidation.
A basis redetermination rule [section 1.1502-35T(b)] and a loss suspension rule [section 1.1502-35T(c)] are the two primary regulatory mechanisms used to prevent duplicated losses. The regulations also specify a basis reduction rule [section 1.1502-35T (f)] and anti-avoidance rules [section 1.1502-35T (g)] that are intended to capture situations not covered by the two primary rules.
Basis Redetermination
The basis redetermination rule requires that the basis of subsidiary stock held by members of a consolidated group be redetermined immediately before a disposition or deconsolidation of a share of such subsidiary member stock if the basis of such stock exceeds its value. The regulations provide different rules for redetermining the basis in the subsidiary stock depending upon whether the subsidiary remains a member of the consolidated group after the stock is disposed of.
If the subsidiary remains a member of the consolidated group after the disposition of the shares, the rules [section 1.1502-35T(b)(1)] require that all members of the group aggregate all their bases in the subsidiary member. Such a basis is first allocated to any preferred shares up to their fair market value and then to all of the outstanding shares of common stock in proportion to their value on the date of the disposition.
Alternatively, if the subsidiary does not remain a member of the group after the disposition or deconsolidation, the rules require reallocation of a certain amount of the basis in the stock to the other remaining members of the group. The amount of reallocated basis is linked to the basis in the disposed shares to the extent that the basis in such shares has been determined by reference to the built-in loss asset. The amount of basis is reallocated such that the loss on disposition is reduced to zero. Such an amount of reallocated basis may be reduced (allowing some or all of the loss to be recognized on disposition) depending upon the extent that certain basis adjustments had previously been made under the consolidated return rules. The operation of the basis redetermination rules in cases where the subsidiary does not remain a member of the group following disposition or deconsolidation is complex and beyond the scope of this article.
Example 2: Basis redetermination. In Year 1, P forms S and contributes $500 to the subsidiary in return for 500 shares of common stock. In Year 2, P contributes an asset with a basis of $100 and a fair market value of $20 to S in exchange for 20 shares of preferred stock. Neither capital contribution is subject to tax under IRC section 351. In Year 3, P sells the preferred stock to an unrelated third party for $20, and later S sells its asset for $20.
Absent section 1.1502-35T, P would recognize an $80 loss on the sale of the preferred stock. In addition, the P group would again recognize an $80 loss on the sale of the asset by S in Year 3, thereby obtaining two tax benefits from a single economic loss. Section 1.1502-35T(b) applies to the sale of the S preferred shares, however, because the basis in the preferred shares exceeds their value.
The regulations require that the basis in the preferred shares be redetermined immediately prior to the sale of the S preferred shares. P's aggregate basis in the common stock and preferred stock of S is $600 (Year 1 initial capital contribution of $500 and Year 2 capital contribution of an asset with a basis of $100). The $600 of basis is reallocated first to the preferred shares, then to the common shares in proportion to their value on the date of the sale by P of the preferred shares to the unrelated third party. In this example, the preferred shares have a value of $20, and the regulations call for the basis to be adjusted down to this level. The remaining $580 of basis is allocated to the common shares ($600 of original aggregate basis, less $20 allocated to the preferred).
The operation of the regulation results in no loss on the sale of S preferred shares by P [$20 amount realized less $20 basis in the preferred shares as computed under 1.1502-35T(b)]. The loss on the sale of the asset by S in Year 3 would not be affected by the regulations, and would be included in the P group Year 3 consolidated tax return.
Loss Suspension Rule
The loss suspension rule [section 1.1502-35T(c)] prevents duplication of an economic loss by disallowing a loss on the disposition of subsidiary stock if the underlying economic loss (e.g., the ownership of an asset by the subsidiary with a built-in loss) could later be reflected on the return of the consolidated group. Thus, the loss suspension rules apply only where the subsidiary remains a member of the group after the stock is disposed of by the parent.
The amount of the loss that is suspended cannot exceed the duplicated loss. Generally, the duplicated loss is the extent to which the basis of the assets in the subsidiary exceeds the value of the subsidiary stock (i.e., the amount by which built-in loss assets are reflected in the stock price).
The regulations reduce the tax deductibility of suspended losses to the extent that the subsidiary member's deductions and losses are taken into account in computing the taxable income of the consolidated group. (The regulations presume that all deductions and losses of the subsidiary are first attributable to duplicated losses, but this section of the temporary regulations also permits this presumption to be rebutted. The regulations do not specify a specific method for rebuttal, but some form of tracing would be required.) The suspended losses are allowed to be used by the group in the year the subsidiary member leaves the consolidated group, to the extent such losses are otherwise allowed under applicable provisions of the IRC.
Example 3: Loss suspension rule. In Year 1, P forms S by making a capital contribution of $500 and receiving 500 shares of S common stock. S uses the $500 to purchase a building. In Year 2, the building decreases in value to $100 (assume, for simplicity, no operating expenses or depreciation are incurred). In Year 2, P also sells 100 shares of S stock to an unrelated third party for $20. S is still a member of the group following the sale of the S shares, because P still owns 80% of the stock of S. At the time of sale, the duplicated loss as computed under section 1.1502-35T (d)(4) is $400. That is, the duplicated loss is the excess of the adjusted basis of the S assets, $500 (the building) over the $100 value of the S stock (the value of the S stock is equivalent to the underlying value of the building owned by S). The portion of this duplicated loss attributable to the shares sold is $80 (20% of the shares sold, multiplied by the duplicated loss element of $400).
Prior to the application of the loss suspension rule, P's loss on the sale of the 100 S shares is $80 ($20 realized, less $100 basis). Because the $80 duplicated loss element attributable to the shares sold equals the $80 loss on the sale of the stock, the full extent of such loss on the sale of the S shares is suspended.
Example 4: Reduction of suspended loss. Assume the same facts as Example 3, except that in Year 3, S sells the building for $100, recognizing a loss of $400. Under Treasury Regulations section 1.1502-35T(c)(4), the $80 suspended loss would be zero because the underlying built-in loss of $400 is used to offset the income of the P group.
Example 5: Allowance of suspended loss. Assume the same facts as Example 3, except that in Year 3, P sells an additional 100 shares of S stock to an unrelated third party for $20 and recognizes an additional $80 loss. Because P's ownership percentage in S has dropped below 80%, P and S can no longer file as a consolidated group. Therefore, under Treasury Regulations section 1.1502-35T(c)(5), the $80 suspended loss incurred by P in Year 2 can be used to offset the taxable income of the P group.
Basis Reduction and Anti-Avoidance Rules
The Treasury Department and, IRS have adopted basis reduction and anti-avoidance rules to prevent the use of duplicated losses in situations not dealt with under the basis redetermination or loss suspension rules. In general, the basis reduction rule applies when, following the disposition of the stock, the subsidiary ceases to exist or is worthless. The anti-avoidance rules address situations where the Treasury Department and the IRS are concerned that taxpayers could circumvent the duplicated loss rules by, for example, making transfers of built-in loss property to a partnership or other corporation, or by "re-importing" losses to the subsidiary group member.
Exception to the Duplicated Loss Rules
Generally, the basis redetermination rules do not apply if the consolidated group disposes of all of its stock of the subsidiary member within a single taxable year. Because the loss suspension rules do not apply if the subsidiary does not remain a member of the consolidated group following the sale of the shares, the two primary mechanisms proposed by the Treasury Department and IRS will not apply to the vast majority of transactions undertaken by taxpayers. In its own summary of the regulations as originally proposed, the Treasury Department went so far as to say that "the IRS and the Treasury do not expect that the basis redetermination and loss suspension rules will apply frequently."
The regulations would not serve to prevent the taxpayer in Rite Aid from deducting its loss on the sale of subsidiary stock, because in Rite Aid all of the subsidiary stock was disposed of (at a loss) within a single taxable year. Thus, the temporary regulations have been crafted to prevent the enjoyment of duplicated losses by a single consolidated group, but not to run afoul of the adverse decision handed down in Rite Aid.
November 2004 Issue
Enlarge Cover
New Duties Reflect a New Role
IRS Responds to Rite Aid
Valuing Operating Assets
Teaching Fraud Detection
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