text:
- 18.104.22.168 Researching Tax Law
- 126.96.36.199 Evaluating Evidence
- 220.127.116.11 Arriving at Conclusions
- 22.214.171.124 Proposing Adjustments to the Taxpayer and/or Representative
- 18.104.22.168 Burden of Proof Shifts to the Service
- Exhibit 4.10.7-1 Court of Appeals Jurisdictions
The Engineering Citator, Document 5262, contains annotations (short summaries of cases and rulings) and citations of precedents and published tax law developments pertinent to administering Internal Revenue Code provisions involving engineering matters.
Copies of the Citator and supplements are distributed to Service personnel most concerned with engineering issues.
A wide range of tax literature is available to Service personnel. Monthly publications such as The Journal of Taxation, Taxation for Accountants, and Taxation for Lawyers, published by Warren, Gorham & Lamont.
Numerous books presenting detailed analyses of tax laws and issues are available and provide excellent sources of information. One of the better known is Federal Income Taxation of Corporations and Shareholders by Bittker and Eustice, published by Warren, Gorham & Lamont, which has been cited by the Supreme Court.
A number of tax services are available from commercial publishers that provide explanations and annotations on a variety of tax issues. For example, CCH Incorporated's Standard Federal Tax Reporter, Bureau of National Affairs' Tax Management Portfolios , and Research Institute of America's American Federal Tax Reports.
There are numerous sources of information available through on-line research. IRS has electronic access to thousands of data bases. See IRM 18.104.22.168.15.1 for more detail.
Electronic tax research using computers, compact discs, and on-line tax services is also available. Information can be accessed quickly and all references to a given topic, obtained by searching, by specific words or word groups. Most of the documents discussed above are available from commercial vendors on compact disc or online.
Employees needing access to electronic research tools should consult with their manager and visit the SPDER web site http://spder.web.irs.gov/. This site provides information on available services, training, and password access information.
The Examination Specialization and Technical Guidance (ESTG) Program Office focuses on compliance on an industry segment basis, issue basis, or return type basis. ESTG analysts/technical advisors facilitate the development of examiners' expertise by providing guidance on issues specific to certain industries or return types and provide technical support to field examiners. They are responsible for preparing issue guidance and Audit Technique Guides(ATG) (also know as MSSP Guides) that provide auditing techniques, assist with issue identification and development, and tax law interpretation. Audit Technique Guides can be access from the SB\/SE home page by selecting Exam and then under the title "Industries" select Industry Specialization for the Technical Guidance home page or Audit Technique Guides to go directly to the ATGs. (http://sbse.web.irs.gov/Exam). This information was formerly housed on the IS Bulletin Board.
The Technical Advisor Program, under the operation of Large and Mid-Size Business Division (LMSB), has been established to:
Ensure uniform and consistent treatment of issues nationwide.
Provide for better identification, development and resolution of issues.
Provide a vehicle for coordination of technical issues for LMSB and other Operating Divisions.
Technical Advisors, each serving as a nationwide expert in a particular industry or issue area, ensure consistent treatment of all taxpayers within their specific industry or issue area. Visit the LMSB Intranet web site for a current listing of all Technical Advisors and the industry or issue areas they represent, and also to access information available for their industry or issue areas.
For more information about the Technical Advisor Program, see IRM 4.10.1.
Examiners gather facts to correctly determine a taxpayer's tax liability. This determination must be made on the basis of all available facts, including facts supporting the taxpayer's position. For this reason, examiners should determine all the facts supporting both sides of an issue.
Examiners should pursue an examination to a point where a reasonable determination of the correct tax liability can be made. In the daily application of this responsibility, examiners must deal with problems of evidence and its evaluation. The following discussion is presented as a series of definitions and explanations to assist examiners in determining the nature and sustaining value of various types of evidence.
Evidence is something which tends to prove a fact or point in question. Evidence is distinguished from proof, in that proof is the result or effect of evidence.
The Internal Revenue Code requires all taxpayers to keep adequate records. There are times, due to unusual circumstances, when records do not exist. In such cases, oral testimony may be the only evidence available. Therefore, oral statements made by taxpayers to examiners represent direct evidence which must be thoroughly considered. Although self-serving, uncontradicted statements which are not improbable or unreasonable should not be disregarded. The degree of reliability placed on a taxpayer's oral statements must be based on the credibility of the taxpayer and surrounding circumstantial evidence (IRM 18.104.22.168.10 below). The following general guidelines should also be considered:
Oral evidence should not be used in lieu of available documentary evidence.
If the issue involves specific recordkeeping required by law and regulations (e.g., IRC § 274), then oral evidence (testimony) alone cannot be substituted for necessary written documentation.
Oral testimony need not be accepted without further inquiry. If in doubt, attempts should be made to verify the facts from other sources of evidence.
In some instances a summary of a conversation or statement made by a taxpayer or witness should be prepared as documentation of the oral testimony and the taxpayer (or third party) should be requested to sign the document. It should always be signed by the examiner or examiners party to the interview. If the taxpayer or third party does not sign the documentation, then it is considered a report of the interview. This summary document should always contain:
Date, time and place of contact,
Name of the parties present, and
Description of what transpired.
Sometimes a more formal written statement is needed when documentation is not available and oral testimony will significantly affect the outcome of the case. In these cases examiners should assume that the case may eventually be resolved through litigation and should use formal written statements such as affidavits to record taxpayer or third party statements. An affidavit is an attested statement and has great validity when properly prepared and voluntarily given. Affidavits should be completed using Form 2311. Affidavits may be used:
When other documentary evidence is unavailable,
When the examiner wants the taxpayer's statements to become part of the case file,
To help accumulate complete and accurate information.
To record the testimony of a witness, and
To prevent a taxpayer from changing testimony.
If oral testimony is accepted or where oral testimony is not allowed, the workpapers should reflect a full development of the facts, oral statements, corroborating evidence and conclusions, including an explanation of the factors supporting the conclusion. "Per oral testimony" or "as reasonable" are insufficient unless the amounts are both de minimis and reasonable.
One of the basic rules of evidence is that witnesses (either taxpayers or third parties) can testify only about facts of which they have first hand knowledge. In other words, witnesses must be able to say the facts to which they testify are true.
Some issues are so difficult that the ordinary person needs assistance from someone more familiar with the subject to understand and resolve the matter at hand. An expert opinion is made by someone with the education and experience to qualify as an expert. Thus, expert testimony is needed.
An examiner is not compelled to accept expert testimony; expert testimony can be challenged.
Hearsay is what a witness says another person was heard to say. It is a secondary source of information and generally the reliability and trustworthiness of the evidence rests upon the veracity and reliability of a person giving testimony.
A common example of hearsay evidence is testimony of taxpayers' representatives. It should therefore be recorded in the workpapers by examiners. Hearsay often leads to primary sources of information.
A statement that is harmful to the person making the statement is considered an "admission against interest" . When an admission is made voluntarily and with deliberation, it represents substantial evidence that the fact admitted is probably true.
If someone tells a friend that they shoot par golf, the friend may be skeptical. But if they said that they have trouble breaking 100, the friend might be inclined to believe them because it would be more likely.
An opinion is a belief not based on absolute certainty, or a judgment or evaluation of what seems to be true. Opinions are statements of personal feelings.
An opinion is not conclusive evidence of a fact. But opinions may be the only evidence available. Before accepting an opinion as evidence, the examiner should solicit other documentary evidence.
Opinions emphasize connotative meaning, that is, how someone feels about something; how they value it.
Opinions cannot be proven or verified. The only criterion for testing an opinion is whether it is acceptable or not, believed or not believed.
There are three primary types of opinions:
Unqualified Opinion: An unqualified opinion is made by someone who is only guessing. The individual has neither the education or work experience to make an intelligent estimate.
Biased Opinion: A biased opinion is made by someone whose relationship with the taxpayer influences the opinion. Suspect bias when a valuation or opinion is rendered by a family member or someone receiving a substantial benefit from the taxpayer.
Expert Opinion: An expert opinion is made by someone with the education and experience to qualify as an expert, but biases, for example, family or employment relationships, should be considered. Any doubt about the validity of an expert's opinion should be resolved by seeking a second expert's opinion.
Observations are statements, judgements, or inferences of fact based on something observed. It is the act of recognizing and noting a fact or occurrence.
Documents are another form of evidence. Documentary evidence is generally regarded as having great probative (providing proof or evidence) value. Writings made contemporaneously with the happening of an event generally reflect the actual facts and show what was in the minds of the parties to the event.
While documentary evidence has great value, it should not be relied on to the exclusion of other facts. Facts can also be established by oral testimony and there will be occasions when courts will give greater weight to oral testimony than to conflicting documentary evidence.
Circumstantial evidence is evidence from which more than one logical conclusion can be reached. To be useful, both the credibility of the evidence and the reasonableness of the conclusion should be evaluated.
The best evidence rule requires that, when possible, original evidence be used. Therefore, examiners should always ask to the see original documents when there is reason to believe such documents are available.
Secondary evidence is used when original evidence is unavailable. Examples of acceptable secondary evidence are copies of original documents made by an examiner. In the absence of original documents, copies made by the examiner become the best evidence available.
The fact in dispute can, in some cases, be proved by showing other facts from which the fact can be inferred. In other words, as a matter of logic, an inference can be made from facts to decide a disputed fact.
An inference is a logical conclusion based on facts. Things beyond the range of what can be observed are inferences.
After all the facts have been gathered through taxpayer interviews; examination of the books, records and supporting documents; interviews with third parties; and, having researched questionable items, the examiner has all the information to be considered in resolving the issues. At this point the examiner will use his/her professional judgement in considering all the information to arrive at a conclusion.
Examiners are expected to arrive at a definite conclusion by a balanced and impartial evaluation of all of the evidence. Examiners are given the authority to recommend the proper disposition of all identified issues, as well as any issues raised by the taxpayer.
Once the examiner has reached a conclusion for an issue, the examiner should communicate their decision to the taxpayer and/or representative. Copies of the examiner's workpapers may be provided to the taxpayer and/or their representative. The examiner should attempt to resolve issues as the audit progresses.
Examiners will employ independent and objective judgment in reaching conclusions on issues being examined and in all aspects of their duties and will decide all matters on their merits, free from bias and conflicts of interest. Fairness will be demonstrated by:
Making decisions impartially and objectively based on consistent application of procedural and the applicable tax law,
Treating individuals equitably,
Being open-minded and willing to seek out and consider all relevant information, including opposing perspectives,
Voluntarily correcting mistakes and improprieties made by themselves or someone else in the Service and refusing to take unfair advantage of mistakes or ignorance of citizens, and
Employing open, equitable, and impartial processes for gathering and evaluating information necessary to decisions.
Examiners will use their professional judgment in evaluating all evidence to reach a conclusion. Examiners seldom have all of the information they would like to have to definitively resolve an issue. Examiners, therefore, must decide when they have enough, or substantially enough, information to make a proper determination for all issues under consideration. The sooner this point is reached, the more timely the case can be completed and the less burden will be placed on the taxpayer.
IRC section 274(d) specifies recordkeeping rules that are required in certain situations. Treasury Regulations 1.274–5(c)(2)(v) states that it is permissible to allow a deduction without complete documentation if the taxpayer can show he or she has "substantially complied" with the adequate recordkeeping requirements. The examiner will use his/her skill and judgement in developing the surrounding evidence when less than the required documentation is available, so that the taxpayer is treated fairly, but does not profit from failure to keep records.
To determine if the taxpayer has "substantially complied, " the following factors should be considered:
Number and type of expenditures involved,
Elements of documentation missing,
Reason(s) why deduction was not properly substantiated,
Availability of other information to substantiate the expenditure,
Materiality of unsubstantiated items, and
Relative tax significance of the items.
A determination of taxpayer credibility is most often required in connection with evaluating oral evidence presented by taxpayers (see IRM 220.127.116.11.2, Oral Testimony).
It is the responsibility of examiners to establish the taxpayer's or third party's credibility as part of the evaluation of oral evidence. Corroborative or contradictory details will have an important bearing on determining the reasonableness and probability of the statements.
If the statements of taxpayers, in the judgment of examiners, suggest some degree of unreliability, the decision to accept some, all or none of the oral statements as credible evidence should take this into account. However, unless taxpayers' statements are found to be wholly unreliable, they must be given some weight in the conclusion reached.
When deductions (such as exemptions for dependents) are based on a substantial number of small expenditures all of which cannot be substantiated by documentary evidence, examiner judgement will be used to reach a reasonable determination. This is provided there is basis for allowance under the law and regulations.
These instructions are not intended to relieve taxpayers of the burden of proof, nor to sanction their failure to comply with the recordkeeping requirements of the law and regulations. Rather, they are intended to give examiners flexibility in the evaluation of incomplete evidence that is often encountered in everyday administration of the tax laws.
Examiners will exercise sound judgment to make reasonable determinations. The examiner must be sure that there is a basis for each allowance. This involves consideration of the following elements, which will vary according to the nature of the items involved and the circumstances of the case:
Considering the extent to which detailed documentation is required,
Examining all existing records essential to adequate substantiation, and
Determining the weight to be accorded oral statements and explanations.
Close approximations of items, not fully supported by documentary proof, can frequently be established through reliable secondary sources and collateral evidence. For example, in questionable exemption cases, the fact that taxpayers cannot furnish documentary evidence in support of some of the amounts contributed need not be fatal to allowance of the exemption. Taxpayers may be able to demonstrate the total cost of support with reasonable certainty and satisfy examiners, for example, by third-party affidavits, that only nominal amounts were contributed by others.
Due consideration should be given to:
Reasonableness of the taxpayers' stated expenditures in relation to the taxpayers' reported income,
Reliability and accuracy of the taxpayers' records (determined by examining items on the return more readily lending themselves to detailed recordkeeping) , and
General credibility of the taxpayers' statements in the light of the entire record in the case.
The practice of disallowing amounts claimed because there is no documentary evidence available, which will establish the precise amounts beyond any reasonable doubt (even though it is clear that the taxpayer did incur some expense) ignores commonly recognized business practice, as well as the fact that proof may be established by credible oral testimony. However, an arbitrarily computed portion of deductions in this situation will not be allowed merely for the purpose of expediting the closing of the case.
For instance, if a taxpayer cannot precisely document amounts spent for expenses while away from home on business, examiners may establish that reasonable amounts were spent for such items if taxpayers can clearly establish the following:
Time: Dates of departure and return for each trip away from home, and number of days away from home,
Place: Destinations or locality of travel, for example, name of city or town,
Business Purpose: business reason for travel or nature of business benefit derived or expected to be derived, and
Proof that Expenditures were incurred: a reasonable showing, based upon secondary evidence, including oral testimony, that out-of-pocket expenses were paid.
The extent of the allowance in (7) above should be governed by the principles stated in (4), (5) and (6) above. Allowances should be consistent with an appraisal of the facts and conservative to ensure that taxpayers do not profit from failure to keep required records of all elements of travel expenses.
The Law Enforcement Manual (LEM) contains tolerances to be observed for deficiencies and various types of penalties. Consult the applicable section as needed.
The definition of "significant" or " material" depends on an examiner's evaluation of a return as a whole and the items that comprise the return. There are several factors, however, that examiners must consider when determining whether an item is significant. These factors include:
Comparative size of the item,
Absolute size of the item,
Inherent character of the item,
Evidence of intent to mislead,
Beneficial effect of the manner in which an item is reported, and
Relationship to/with other item(s) on a return.
Generally, automatic adjustments (obvious errors or omissions on the return) in excess of tolerances are to be considered significant items.
The impact on compliance within a segment of the population, sector of the economy, or similarly situated taxpayers will be considered when making a decision whether or not to raise an issue.
Once an examination has begun and a decision is made to limit the scope of an examination on account of collectibility, examiners will complete the examination at the earliest possible opportunity.
In making the determination, the following should be considered:
Are the taxpayers considering bankruptcy proceedings?
Are there net operating losses that could be utilized in the current year to absorb any potential tax liability resulting from an examination?
Are the taxpayer's bank accounts overdrawn?
Do the taxpayer's liabilities exceed the taxpayer's assets?
Are there collectibility indicators on the Charge-Out document?
Factors such as future earning power, age, assets, liabilities, education, profession or trade, and health.
The steps taken to determine whether to limit the scope of the examination are to be documented in the case file.
When an issue is examined and based on the findings, the examiner decides further issue development is not warranted, the examiner should use the Issue Lead Sheet to document what work has been performed, findings, and conclusions to support the examiner's determination to get out of the issue
For field examinations, if the examiner decides based on information developed during the examination that the examination of remaining issues as originally planned is no longer warranted, the examiner should use the Risk Analysis Workpaper to document the decision. The Risk Analysis Workpaper should be filed as a separate line item in Section 600.
For office examinations, if the examiner decides based on information developed during the examination that the examination of remaining issues as originally planned is no longer warranted, a risk analysis workpaper is not required, only a comment on the leadsheet or Form 4700 is needed.
The scope of the examination may be limited on an employment tax examination. However, examiners should avoid taking any action that would give the taxpayer a safe haven. As an alternative, examiners should limit the number of returns examined. This approach minimizes the potential tax liability, while avoiding the likelihood of giving the taxpayer a safe haven.
When permission has been given to limit the scope of the examination due to collectibility, the following adjustments should be included in the audit report:
Adjustments in the taxpayers' favor,
Automatic disallowances,
Statutory adjustments,
Other issues "developed," up to the point of limiting the scope of the examination.
Judgment should be exercised when identifying which issues are to be considered "developed." The following areas should be considered in making the decision:
The additional time required to complete the issue. Avoid raising an issue unless the audit work is substantially complete.
The potential for future non-compliance,
The extent of statutory authority. Avoid issues in which the statutory authorities are inconclusive unless there are overwhelming compliance considerations.
Once a determination to limit the scope has been made and approved, the determined tax liability will always be assessed.
In examinations conducted by examiners using field techniques, timing issues should be dealt with at the planning level. Generally, planning an examination to include short-term timing issues is not an effective use of resources. However, unplanned timing issues which are uncovered or arise as a correlative adjustment during an examination of non-timing issues should be made if cost effective to do so.
The pre-contact and/or examination plan should preclude the inclusion of timing issues, except those with long term, flagrant short term, indefinite, or permanent deferral features.
Coordinated Issues may be proposed by LMSB Technical Advisors to ensure that key issues within particular industry or issue areas are raised, developed and resolved on a consistent basis. The purpose of Coordinated Issues is to provide examiners with guidance on significant national issues that are not being resolved consistently. Coordinated issues establish uniform positions within industry or issue areas. Examiners cannot deviate from such positions without the concurrence of the responsible LMSB Industry/Issue Team. See IRM 22.214.171.124.1.8 for more information on Industry/Issue teams.
Visit the LMSB Intranet web site for a listing of coordinated issues.
For more information on Coordinated Issues, see IRM 4.40.3.
The term whipsaw refers to situations where the government is subjected to conflicting claims by taxpayers. A potential whipsaw situation exists whenever there is a transaction between two parties and correct reporting of the transaction may benefit one and adversely impact the other for tax purposes.
A potential whipsaw situation could be present in almost any transaction; however, experience has shown the following issues to generate the majority of whipsaw cases:
Goodwill vs. covenant not to compete,
Alimony vs. child support,
Allocation of purchase price,
Buyer vs. seller,
Sale vs. rental/royalty,
Employee vs. independent contractor,
Payments to widows (gift vs. taxable income),
Dependency exemptions for children of divorced parents,
Husband and wife filing separate returns,
Grantor, trust, and beneficiaries,
Parent and child,
Decedent and decedent's estate,
Taxpayers in which the Commissioner has invoked the provisions of IRC section 482, and
Parent and subsidiary corporations .
When whipsaw issues require ( i.e. material tax consequence), an examination of both parties, examiners will secure the name, address, and the tax identification number (TIN) of the related party. A transcript will be requested to determine the related party's examination status.
If a related party is under examination, then the examiner assigned to the case will be notified.
If the related party is not under examination, then the examiner will determine if they can examine the return or if a referral is needed. If a collateral examination is warranted, then Form 6229, Collateral Examination, will be prepared.
The primary objective of requiring support examinations of these returns is to assure consistent treatment of related taxpayers or taxpayers involved in the same transaction.
Communication with the taxpayer or representative on an on-going and continuous basis is a critical part of the examination process. Generally, the taxpayer should feel more involved in the audit process and will be better informed of the status of the examination. The examiner should discuss the progress of the audit and issues proposed with the taxpayer and/or representative at frequent intervals as the examination continues.
In office examinations, the examiner can discuss issues as they are concluded during a scheduled appointment or at the conclusion of the appointment. Whenever possible, the examiner should prepare an audit report at the conclusion of the appointment and discuss audit issues with the taxpayer and/or representative in a face to face meeting versus just mailing the report later.
In field examination, the examiner should discuss issues as they are concluded. This allows the resolution process to begin as the examination continues. Each issue is discussed as it is completed and resolved so that at the conclusion of field work the status of each issue is known. The examiner can then take the appropriate steps to close the case.
This section focuses on techniques for conducting closing conferences, presenting examination findings, explaining proposed adjustments, and soliciting agreements. Each situation is unique and techniques vary widely, but there are basic procedures which should always be followed. See IRM 4.10.8 for report writing requirements.
Generally, substantive issues should be proposed and discussed with taxpayer and/or his representative in a face to face meeting. In some circumstances, a telephone conference or call may suffice, but this would be the exception.
Generally, a report will not be mailed to the taxpayer prior to discussing findings and proposed issues with the taxpayer and/or his representative. Exceptions to this rule would be for the following:
no-show/ no-response appointments,
uncooperative taxpayers, or
when additional records are provided for the examiner to consider.
A revised report may be mailed to the taxpayer rather than presented in a face to face meeting.
To facilitate discussion at closing conferences, the examiner may provide the taxpayer with a listing and brief description of items to be discussed.
The examiner should choose the order in which issues will be presented at the closing conference. The order can be modified during the conference. While there is no "right" order or order which is best for all occasions, it is generally easier to resolve factual issues or issues involving an established application of law. These issues should be discussed first. Less certain issues should be discussed last.
Closing conferences vary in the degree of formality, but generally the following areas are covered:
The examiner discusses his findings with the taxpayer and/or representative.
The examiner should be prepared to converse knowledgeably and explain proposed adjustments and provide the taxpayer with copies of relevant court cases, lead sheets and workpapers showing computations.
The examiner provides the taxpayer and/or representative with the authority for his findings (law, argument and conclusion).
The examiner receives information from the taxpayer and/or representative and addresses any taxpayers concerns. It is very important that the examiner listen to the taxpayer and gets a clear understanding from all persons present that there are no pertinent facts other than those of which the examiner is aware. This can be done in a positive manner by stating, "This is my understanding . . .," and then detailing the facts as the examiner understands them. "Are we all in agreement on this? Are there any other material facts or circumstances of any consequence? "
The examiner solicits an agreement from the taxpayer.
When a joint return is being examined and only one spouse is present at the interview, a copy of the examination report must be mailed to the other spouse. If the taxpayers are represented by a power of attorney and he signs the audit report, copies of the audit report will be sent separately to each spouse.
On agreed cases, the examiner solicits payment of tax, interest and penalties.
(1) If taxpayer indicates an inability to pay the tax due at closing, alternative payment methods should be discussed. An installment agreement should be offered if the taxpayer meet the requirements. Form 9465, Installment Agreement Request, can be used to solicit a payment agreement.
(2) If the taxpayer and/or representative agree with the findings, but do not wish to pay the deficiency immediately, explain that a statement for the deficiency plus interest will be mailed. Their cancelled check will be their receipt. Secure appropriate waivers and close the case. -
On unagreed cases, the examiner will
(1) Offer the taxpayer a managerial conference.
(2) Determine if the case is wholly or partially agreed.
(3) Solicit the taxpayer(s)' position on unagreed issues.
(4) Advise the taxpayer of the appellate process and his Appeal Rights.
This section provides additional information for the processing of office examination cases. See IRM 220.127.116.11.1 for general information.
If the taxpayer says he has additional information to consider at the end of the initial meeting, this should not delay the issuance of a report. The taxpayer should be informed that the report will be revised or voided if adequate additional information is provided. The general rule is to issue a report at the conclusion of the initial appointment. The additional information the taxpayer wants considered can be mailed or faxed in for consideration. The examiner and taxpayer should agree on a mutually acceptable date (generally 15 days) for submission of additional information to be considered.
If the examiner do not issue a report at the conclusion of the initial appointment, the examiner and the taxpayer should agree on a mutually acceptable date (generally 15 days) for submission of additional information needed. The examiners will advise the taxpayer that if the additional information is not received, or is inadequate, an examination report will be issued based on the information currently available.
A focused IDR, using Form 4564, Information Document Request, should be issued to request additional information..
The examiner should explain to taxpayer that they are entitle to a managerial conference if they do not agree with the examination findings. The examiner should advise that a managerial conference is optional and has no impact on the taxpayer's right to request an appeals hearing.
When the communication process between the examiner and the taxpayer is working well, the examiner will know at the end of field work which issues are agreed and which are unagreed.
If the desired level of communication and cooperation is not achieved, once the examination is completed, examiners will explain the basis of the proposed adjustments to taxpayer and/or his representative. The examiner should solicit agreement to the issues and attempt to secure agreement to the proposed tax liability. Examiners should be prepared to cite the law, regulations, rulings, and court decisions on which their conclusions are based and provide the taxpayer with copies of workpapers explaining the proposed adjustments.
Over assessment and no-change cases are generally not controversial and, in most instances, there is no need to hold a formal closing conference.
For agreed cases a closing conference is generally not required as the issues were probably discussed and resolved throughout the audit. However, in some instances, a formal closing conference will be needed. The examiner should discuss the revenue agent's report with the taxpayer and/or representative to ensure that all questions are answered and that payment arrangements are made.
For unagreed cases a closing conference will generally be held.
Taxpayers who disagree with any of the proposed adjustments will be informed of their right to discuss the proposal with the examiner's group manager. Taxpayers will also be informed of formal appeal rights, as well as the right to pay any deficiency and file a claim for refund.
Examiners are required to inform all taxpayers about the Fast Track Mediation (FTM) program. All examiners must offer taxpayers the opportunity to use FTM on all unagreed cases that meet the criteria as described in Publication 3605. FTM is designed to expedite the resolution of disputes with taxpayers. A key feature of this program is the recognition of taxpayers as customers who are entitled to have their disputes handled as expeditiously as possible. FTM involves an appeals or settlement officer who has been trained in mediation techniques acting as a mediator between the taxpayer and Compliance.
At the completion of a disputed examination/collection determination, the examiner/revenue officer or manager will inform the taxpayer of the opportunity to request FTM to resolve the case.
Both the Service and the taxpayer must complete and sign a simple agreement, Agreement to Mediate Form, to use mediation. All necessary documents are accessible on the official FTM website at: http://appeals.web.irs.gov/ftm/.
An appeals or settlement officer is assigned to work as a mediator between the taxpayer and Compliance. The case is not transferred to Appeals.
FTM is generally available for all non-docketed cases and collection source work over which SB\/SE has jurisdiction except for campus cases. Cases worked at the campuses are generally not eligible for FTM due to the lack of a manager's closing conference. The following is a list of issues/cases currently excluded from FTM:
An issue designated for litigation;
Issues for which there is an absence of legal precedence and/or conflicts between circuit courts of appeal;
Issues included in the IRS' Compliance Coordinated Issue Program and Appeals Coordinated Issue Program (ACI). ISP issues are listed on the Appeals web site. (See IRM 126.96.36.199.1 and IRM 220.127.116.11.2)
Competent Authority cases;
Campus penalty appeal cases;
Campus (streamlined) offer-in-compromise cases;
Collection Appeals Program cases;
Automated Collection Site cases;
Frivolous issues, such as, but not limited to those identified in Rev. Proc. 2002-2, 2002-2 C.B. 82;
No show/no response cases (due to a lack of cooperation by the taxpayer and/or representative).
If agreement can be reached on one or more, but not all issues or years, taxpayers should be encouraged to enter into a partial agreement by executing a waiver such as Form 870, covering the agreed issues or years.
In attempting to reach agreement, Examination personnel have the authority and responsibility to reach a definite conclusion based on a balanced and impartial evaluation of all the evidence (refer to IRM 220.127.116.11 above, Arriving At Conclusions). This authority does not extend to consideration of the hazards of litigation.
If a taxpayer requests a written record of what has been agreed to at the time a partial agreement is entered into, an appropriate letter or statement may be furnished covering such agreed issues or years.
When agreement is reached on the last of the disputed issues, examiners should review all questioned items and confirm that taxpayers and/or representatives are in complete agreement.
Calculate the deficiency or overassessment. Unless the tax computation is very complicated, it may be completed immediately and a report prepared. If everyone is in agreement, there is no reason for delay in execution of the waiver.
Examiners will solicit payment of the tax due including accrued interest and applicable penalties.
If taxpayers indicate an inability to pay the tax due at closing or within 120 days of the first notice, alternative payment methods should be discussed. An installment agreement should be offered if the taxpayers meet requirements.
If the taxpayer and/or representative do not wish to pay the deficiency immediately, explain that a statement for the deficiency plus interest will be mailed. Their cancelled check will be their receipt. Secure appropriate waivers and close the case.
In the examination of large, complex tax returns, numerous issues will likely be proposed. Adjustments need to be fully developed before they are presented to taxpayers for review. If adjustments are not adequately developed, the review process may take longer. Records should be maintained of proposed adjustments and every effort taken to secure taxpayers' responses in a timely manner.
Form 5701 may be used to present proposed adjustments to taxpayers. Form 5701 is a three part form designed to provide written record of proposed adjustments. It is distributed as follows:
Part I is kept by the taxpayers.
Part II is returned by the taxpayers with their response to the issue.
Part III is maintained by the examiners.
Use of Form 5701 is not mandatory. Any method which provides a record of what was presented to taxpayers may be used.
The issuance of Form 5701 is recorded on the Issue Control Sheet, Form 5700. Form 5700 is a log which provides a record of outstanding Forms 5701, along with their current status.
Preparation of Form 5701 must be tailored to the peculiarities of the issue, the taxpayer, and the expected agreed or unagreed status of the proposed adjustment. Form 5701 may serve as a cover sheet for a Form 886A, Explanation of Items. This facilitates incorporation of an explanation of the issue into the Revenue Agent's Report.
The suggested format for preparation of an issue proposal is as follows:
Government's Position,
Taxpayer's Position, and
The Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) changed examination and administrative procedures for partnership examinations. The Sub-Chapter 5 Revision Act of 1982 made similar revisions to S corporations. Under the 1982 Acts, examinations, appeals, and judicial proceedings are, in general, conducted at the entity level. Closing conferences and issue proposals relating to TEFRA entities must by law follow rigid guidelines. Refer to the Tax Shelter/TEFRA Handbook for a complete discussion of TEFRA examinations and procedures.
Payment for agreed deficiency cases should be solicited and secured at the closing conference whenever possible. Taxpayers should be informed of the following benefits of making a current payment:
It decreases future interest that is compounded daily,
The interest and the failure to pay penalty will begin to accrue if the tax is not paid within 10 days from the date of the first notice,
Any personal interest will not be tax deductible.
If taxpayers state they cannot pay, ability to pay should be determined. The interview should include the following dialogue:
The total amount you owe, which includes tax, interest, and penalties, is $. Are you going to pay by check, money order, or cash? (If a taxpayer desires to make payment by cash, assistance will be requested, through the group manager, for Collection assistance in the acceptance of the payment.)
Given that full payment cannot be made today, what is the maximum amount that you can pay today?
Can you make full payment upon receipt of the first notice?
Do you have any assets which you can easily liquidate?
Can relatives or friends lend you the funds?
If taxpayers indicate that they will not be able to full pay at the conclusion of the examination or upon receipt of first notice, examiners have the additional responsibility to discuss installment agreement provisions.
If taxpayers state a willingness to pay, but do not meet the installment agreement criteria, examiners, through their group manager, will involve Collection.
Case files must be documented to reflect the taxpayers' responses and actions taken to verify the taxpayers' statements, if appropriate.
IRC section 7491 provides that the burden of proof in a court proceeding will shift from the taxpayer to the Service effective for court cases arising out of examinations started after July 22, 1998 in the following areas:
Income, estate, gift, and generation skipping taxes, if the taxpayer meets certain requirements described below.
Cases where any item of income is based solely on statistical information from unrelated taxpayers.
Shift burden of production only with respect to penalties.
The term examination includes an audit, the matching of amounts from information returns (IRP), and the review of a claim for refund prior to the issuance of the refund.
Congress reasoned that individual and business taxpayers were at a disadvantage in court against the IRS, and that there was fundamental unfairness in the process. With the burden of proof on the taxpayer, there was a presumption of "guilt, until proven innocent." Congress believed that if a taxpayer is generally law abiding, then the Service should prove that the position taken by the taxpayer is wrong.
IRC section 7491 applies specifically to income, estate, gift, and generation-skipping transfer taxes. For this purpose. self-employment taxes are treated as income taxes. It should be noted that the Director, Compliance (Examination) has determined the policy of Examination is that the general burden of proof provisions should apply to all Examination determinations of Federal tax liability. The proper identification, development, proposal and resolution of as many issues as possible is a good examination practice.
IRC section 7491(a)(1) shifts the burden of proof in a court proceeding from the taxpayer to the Service if the taxpayer produces credible evidence regarding the factual issues relevant to determining tax liability and also satisfies the criteria below.
The new legislation provides the criteria for shifting the burden of proof to the Service. For the shift to apply, the taxpayer has the burden of proving the following:
Met all substantiation requirements of the Code and regulations;
Maintained all records required by the Code and regulations;
Cooperated with any reasonable request for information, documents, and witnesses by the Service;
Exhausted all its administrative remedies, including appeal rights; and,
Met certain net worth qualifications but only if the taxpayer is a partnership, corporation, or trust. Special rules apply to Qualified Revocable Trusts (see Section 7491(a) of the Internal Revenue Code). There is no net worth qualification for individuals (an estate is considered an individual).
IRC section 6201(d) became effective in 1996 and applies without regard to IRC section 7491. If the taxpayer meets the conditions of IRC section 6201(d), the Service has the burden of producing information to support income items reported on the information return.
IRC section 6201(d) requires that the Service produce " reasonable and probative information" in any court proceeding regarding a deficiency based on an information return if: (1) the taxpayer raises a reasonable dispute and (2) the taxpayer has fully cooperated with the Service. Full cooperation includes timely compliance with requests for information, including access to witnesses and documents within the control of the taxpayer. If the taxpayer does not raise a "reasonable dispute" , the Service will not be required to produce any information beyond the information return.
The examiner should take the following actions when a taxpayer disputes receipt of income reported on an information return (IRP), or disputes the accuracy of the information return:
Contact the third party payer and request verification of the accuracy of the information document;
Document the examiner's activity record to show the date the letter was sent;
Retain a copy of the letter and third party payer's response in the case file;
If the third party payer does not respond to the verification letter, or responds that the records no longer exist, the adjustment may need to be conceded if the Service cannot obtain reasonable and probative information from another source.
It should be noted that relatively few audits result in litigation, the outcome of tax litigation rarely turns on who has the burden of proof, and those cases where the taxpayer refuses to provide documents and refuses to cooperate are not affected at all by IRC section 7491(a). However, this does not mean examiners should not follow sound audit practices.
Even before the burden of proof provisions were enacted in 1998, the Service sought to make sure that its technical positions were well thought out, the facts were appropriately developed, audit conclusions were well supported, and the case file was well documented.
If the examination ultimately reaches litigation, and it becomes necessary to determine whether examiner requests for information were made and were reasonable, the determination will depend upon the facts and circumstances of each case as documented in the case file.
The use of Form 9984, Examining Officer's Activity Report, or the RGS equivalent, is required for:
Uniform case file documentation of examination activities,
Examination Quality Measurement System (EQMS) case reviews,
The possibility of having to respond to a taxpayer's claims for interest abatement under IRC section 6404(e), and
Determining whether taxpayers fully cooperated with reasonable requests for information.
Examiners and any person (Group Manager, Group Secretary, Appointment Clerk, Audit Accounting Aid, Tax Examiner, Reviewers, etc.) are required to document each action taken on the case using the Form 9984 (or RGS equivalent). Documentation of activity begins on the date the taxpayer is notified in writing of the commencement of an examination. Actions after assessment (i.e., audit reconsiderations, collection referrals, etc.) must also be documented on Form 9984.
The following information will be accurately documented on Form 9984 for each action taken on a case:
Date of the activity,
Location of the activity,
Contact code,
Time charged, and
Remarks and/or actions taken.
In the Remarks, Notes, Actions Taken section of Form 9984 it is very important to record all activity, as well as inactivity (i.e., details, training, extended leave, etc.), including but not limited to:
All contacts with the taxpayer and/or representative, whether in writing or by telephone,
Appointments, conferences, meetings, etc. with the taxpayer and/or representative, group manager, or other persons,
Research conducted,
Report preparation and issue resolution,
Date the case is closed to the manager, as well as the date the case is closed from the group to Case Processing, and
Any other activity that assists in bringing the examination to a resolution.
Examiners should utilize workpapers and audit reports to support audit adjustments and document the extent of taxpayer cooperation. This includes making complete copies of documents submitted by the taxpayer in appropriate cases.
These workpapers/reports should be used to:
Explore and document all requirements of the law with respect to the treatment of an item for tax purposes;
Fully describe all documents reviewed or inspected that support audit conclusions and proposed tax adjustments; and,
Fully describe the audit steps taken and analysis which supports audit conclusions.
IRC section 7491(b) places the burden of proof on the Service in any court proceeding when the Service reconstructs any item of the taxpayer's income using solely statistical information. See IRM 126.96.36.199.1.3 for more detailed discussion on the use of Bureau of Labor Statistical (BLS) data.
The use of BLS or Consumer Price Index (CPI) information is still appropriate in some situations. If the Service has some direct or indirect evidence that links the taxpayer to unreported income generating activities, the burden of proof does not shift to the Service under this specific burden of proof. When this supplemental evidence is present, then the general burden of proof rule applies.
The Nonfiler manual, which contains specific audit procedures for the Nonfiler Examination Program, has not been changed in any way by the new Burden of Proof legislation. That section of the IRM discusses what an examiner should do when examining a taxpayer who procrastinates or is an uncooperative nonfiler.
Remember that if an examiner determines that a taxpayer has unreported income, the use of statistical data must be supported by supplemental information that links the taxpayer to an income producing activity.
When using statistical information provided by either BLS or CPI, an examiner must develop supplemental information to support the finding of unreported income. Such evidence could include proof of assets owned, verification of personal living expenses, and verification of the likely source of income.
Most importantly, the examiner should develop direct or indirect evidence that links the taxpayer to income generating activities. Some audits steps which would support such a determination could include:
Checking for business listings in the local phone book;
Contacting any known employers;
Identifying any non-taxable sources of income;
Securing copies of financial statements from lending institutions who have made loans to the taxpayer;
IRC section 7491(c) states that the Service now has the burden of production in a court proceeding when the issue is a penalty, an addition to tax, or an additional amount imposed by the Internal Revenue Code. In any court proceeding, the IRS must first present evidence that imposition of the amount is appropriate. Only then must the taxpayer assume the burden of persuasion to raise appropriate defenses, such as reasonable cause, to the imposition of the penalty. IRC section 7491(c) applies only to individuals.
The following definitions are related to the burden of proof requirements for assessment of penalties:
Penalties include all penalties assessed under this title. An example is IRC section 6662 that imposes the accuracy related penalty.
Addition to Tax is any amount computed by reference to the amount of tax. An example is the addition to tax imposed by IRC section 6654 for failure by an individual to pay estimated income tax.
Additional Amount refers to an amount that can be assessed by the Service that is not an addition to tax or penalty. An example is the amount imposed under IRC section 6673 for the sanctions and costs awarded by a court when a taxpayer's position is frivolous.
(Note: That the definition of additional amounts under IRC section 7491(c) does not include excise taxes imposed by chapters 42 and 43 of the Internal Revenue Code nor does it include interest under IRC section 6601.)
The Service must first present evidence that a penalty, addition to tax, or additional amount is appropriately applied to the taxpayer. It is then the taxpayer's responsibility to present evidence of reasonable cause, substantial authority, or other similar defense in showing that the amount should not be asserted.
For example, if a delinquency penalty is asserted under IRC section 6651, the Service would meet its burden of production by showing that the filing date was after the due date for the tax return, and that there was no evidence the taxpayer filed for an extension.
Examiners should treat a penalty issue as any other issue by including the following information in the case file:
The facts surrounding the issue
Applicable law
Application of the facts to the law
Audit conclusion
Taxpayer's Position
Examiners should consult IRM 4.10.6, and IRM 20.1, Penalties, for additional information when developing penalty issues.
First | Second | Third |
Maine | Connecticut | Delaware |
Massachusetts | New York | New Jersey |
New Hampshire | Vermont | Pennsylvania |
Rhode Island | Virgin Islands | |
Puerto Rico | ||
Fourth | Fifth | Sixth |
Maryland | Canal Zone | Kentucky |
North Carolina | Louisiana | Michigan |
South Carolina | Mississippi | Ohio |
Virginia | Texas | Tennessee |
West Virginia | ||
Seventh | Eighth | Ninth |
Illinois | Arkansas | Alaska |
Indiana | Iowa | Arizona |
Wisconsin | Minnesota | California |
Missouri | Hawaii | |
Nebraska | Idaho | |
North Dakota | Montana | |
South Dakota | Nevada | |
Oregon | ||
Washington | ||
Guam | ||
Tenth | Eleventh | District of Columbia |
Colorado | Alabama | Washington, D.C. |
Kansas | Florida | |
New Mexico | Georgia | |
Oklahoma | ||
Utah | Federal * | |
Wyoming | ||
U.S. Claims Court | ||
* The Court of Appeals for the Federal Circuit was created to hear decisions appealed from the U.S. Court of Federal Claims. |


text:
SDP Financial Aid
Financial Aid
Financial assistance is available for the SDP. Students are eligible to receive Federal (Pell Grant, Stafford Loans) and State (Summer Development Grant) Aid to assist with covering the cost of tuition, room and board, and books for the SDP. Students must:
• Complete an Application for Admission to the University;
• Submit the Free Application for Federal Student Aid (FAFSA)for the current year (i.e. 2012 - 2013) at www.fafsa.gov
• Complete and submit the MVSU Summer School Application to the Office of Student Financial Aid, and;
• Complete the Summer Developmental Grant Application nolater than the first Monday in June to meet eligibility at www.ihl.state.us/financialaid/default.asp to the Mississippi Office of State Financial Aid. The application and additional information about the Summer Developmental grant can also be found at www.mississippi.edu/riseup.

subset: commoncrawl


text:
Limabain had already bagged some of his candy when I took the picture, but had it all organized by category and type. "Look Mom, 10 packs of whoppers, 8 baby ruths, 12 skittles"...and on and on.
Who knows, he might just grown up to be a bean, er...bain, counter!
linked at SITS


text:
Who, What, Why: Why don't more countries use plastic banknotes?
The Bank of Canada began circulating $100 polymer banknotes this week in an effort to combat counterfeiting and reduce costs. So why don't more countries use plastic cash?
On the face of it, plastic banknotes have many advantages.
They last a long time, and they don't get dirty so quickly - a great advantage in countries with hot climates, and sweaty pockets.
"The tropical climate is a challenging environment for banknotes, especially because of high humidity and high temperatures," says polymer researcher Stane Straus.
"This causes paper notes to absorb moisture, thus becoming dirty and limp quickly. Polymer notes, on the other hand, do not absorb moisture.
The answer
- Polymer notes last more than twice as long as paper notes, and cost less to produce over their lifetime, but they also have some disadvantages
- They used to be harder to counterfeit than paper notes, though paper notes have now caught up
- Disadvantages include being unfoldable and more slippery
- Central bankers are conservative and risk averse - and are waiting to see whether their counterparts in other countries embrace plastic first
"You could say that polymer notes beat paper notes in terms of cleanliness and durability in all climates, but this particular advantage of polymer notes stands out even more in tropical climates."
Canada had security, cost and also the environment in mind when it took the decision to go plastic.
When counterfeiting hit a peak in the country from 2001 to 2004, blame was put on the $10 and $5 bills printed in 2001 and 2002, which were deemed to have too few security features.
By this stage, the polymer technology first introduced in Australia in 1988 was already well established, and security features such as transparent windows and microprinted watermarks looked like a solution to Canada's problem.
Canada claims its $100 bill is the world's most advanced banknote, including a hologram within the transparent window. It also shows a circle of numbers that match the value of the denomination when held up to a light.
A $50 polymer denomination will follow in March and a $20 bill in late 2012. By the end of 2013, new $10 and $5 bills will have been introduced, and all Canadian money will be printed on polymer.
RecyclingThe new notes, says Bank of Canada senior analyst Julie Girard, will last 2.5 times longer than paper bills. The lifespan of a $20 bill - Canada's most widely circulated denomination - should be at least seven years.
Countries that are purely polymer
- Australia
- Brunei
- Papua New Guinea
- New Zealand
- Romania
- Vietnam
That will save production costs because fewer bills will need to made - and the plastic is also recyclable at the end of its lifetime.
"It's possible that someone could be sitting on a lawn chair some day whose parts are made of currency," Girard says.
Stane Straus also sings the praises of polymer, from an environmental point of view, compared with traditional "paper" banknotes.
Many of these are actually made of cotton - US paper bills are 75% cotton - which, he points out, takes large amounts of pesticides and water to produce.
So why don't more countries cash in on this technology?
Today, 23 countries use polymer banknotes, but only six have converted all denominations into plastic.
A history of plastic notes
- Haiti and Cost Rica were the first to trial polymer banknotes in the 1980s, using American technology - but the ink smudged
- A plastic note was introduced in the Isle of Man in 1983, using British technology, but withdrawn in 1988 - again because of problems with the ink
- Australia, the first country to go purely plastic, is now the world's sole polymer banknote producer
Tom Hockenhull, curator of the Modern Money exhibition at the British Museum, says one reason is that the security gap between paper and plastic notes is closing.
It is now possible to make "hybrid notes" - paper notes with a transparent polymer window - he points out.
"Paper is much more secure than it used to be and the new [British] £50 note, for example, has features that are extremely hard to counterfeit," he adds.
Meanwhile counterfeiters are making progress with polymer. "Polymer is very hard to counterfeit, but it hasn't stopped people trying: good imitations do appear from time to time," Mr Hockenhull says.
RiskWHO, WHAT, WHY?
A part of BBC News Magazine, Who, What, Why? aims to answer questions behind the headlines
He also points to some notable disadvantages of polymer banknotes:
- They are harder to fold
- They are more slippery, which makes them harder to count by hand
- Some less developed countries may not have the facilities to recycle them - and when they burn they pollute the air
In addition, polymer notes cost more to produce in the short-term, which could be a drawback for developing countries. The payback from their extra durability only comes over time.
Another factor could the conservatism of central bankers.
"Central banks are very conservative institutions," Stane Straus says. "People making the decision to convert to polymer - partially or fully - are taking a personal risk.
"Many central banks are simply waiting until others convert and then they will follow."


text:
The Organs
The Aeolian-Skinner, Opus 1438
The primary organ used for weekly worship at St. Luke's is the 69-rank Aeolian-Skinner.
Aeolian-Skinner Organ, Opus 1438, was built by the Aeolian-Skinner Organ Company, Inc. of Boston, Massachusetts, in 1965 for installation in Caruth Auditorium of the Owen Fine Arts Center at Southern Methodist University. A gift to the university from C.S. and Bernice Hamilton of Dallas, for twenty-seven years, the instrument at SMU served as one of the outstanding teaching and concert organs in the South. The organ was re-installed at St. Luke's in 1992 by Range Organ Company of Dallas.
Under the instruction of Dr. Robert T. Anderson, many of North Texas' finest organists became accomplished artists at the console. International concert organists who performed on Opus 1438 at SMU were Robert T. Anderson, Marie-Claire Alain, Guy Bovet, Maurice Duruflé, Marie-Madeleine Duruflé-Chevalier, Anton Heiller, André Marchal, Luigi Ferdinando Tagliavini, and Gillian Weir.
In consultation with Dr. Anderson, the organ's original specification was determined by Roy Perry of the Aeolian-Skinner staff and the pipe scales and tonal concept were developed by Joseph S. Whiteford, Chairman of the Board of Aeolian-Skinner. The finishing of the organ was by Donald Gillett, Head Finisher, and Roy Perry. The SMU installation was by J.C. Williams of New Orleans.
The organ consists of four divisions (Great, Swell, Positiv and Pedal) comprising 69 ranks and 51 independent stops. The design of the organ incorporates several features necessary to the rendition of the vast literature of the instrument. The organ follows basically the North German ideals of the late-17th and early-18th centuries. A "plenum" is achieved within the structure of the three manual divisions and pedal. The ideal of complete choruses on all manuals and pedal is often neglected in contemporary organ building. Certain "Romantic" voices are incorporated in the Swell Organ to increase the versatility of the instrument.
Since the action of the organ is electro-pneumatic, the console can be placed apart from the instrument, giving the performer a better perspective. The console is constructed of teak, rosewood and ebony. One of the most notable visual features is the Swell Division, placed in an exquisite enclosure of warm, rich teak wood.
The William Longmore, Opus 2
For services held in the All Saints Chapel, St. Luke's also has the 9-rank, 2 manual tracker by William Longmore. More information about William Longmore and this instrument can be found here.
Other Instruments
St. Luke's is blessed to have many other instruments to worship God. The children's area uses many rhythm and Orff style instruments. Pianos are located in the chapel, rehearsal hall, children's choir room, and the sanctuary, which holds the 7'6″ Yamaha Grand. The church also uses three octaves of Malmark handbells and five octaves of Malmark Choirchimes.


text:
BOSTON--NOVEMBER 12, 2012 -- This morning, 4-star winter getaways in Puerto Rico -- including three nights at the upscale Rio Mar Beach Resort & Spa, a Wyndham Grand Resort, and roundtrip airfare from Boston -- were reduced to $499 per person, including tax.
This package knocks an additional $100 off already-reduced prices and saves more than $450 on the regular cost of purchasing airfare and hotel stay separately.
Travel is available for select departures Jan. 6 - May 28.
This CheapCaribbean.com deal also includes 25% off golf, tennis, spa, water sports, tours and cabana rentals.
The sale ends Friday, Nov. 16.
About Rio Mar Beach Resort: Three miles north of the El Yunque rainforest, this oceanfront resort features two championship golf courses, a spa, a 13-court tennis center, two pools -- including one with a water slide -- and seven restaurants.


text:
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New Haven Lawyer Seeks To Sue State Over Newtown Shooting
by Christine Stuart | Dec 28, 2012 4:33 pm
(25) Comments | Commenting has been closed | E-mail the Author
Attorney Irv Pinsky's 6-year-old client heard the "cursing, screaming, and shooting" over the intercom Dec. 14 when a gunman entered Sandy Hook Elementary School and killed her friends.
"You're having a wonderful life and then the next thing you know your friends are all getting killed and you're in danger," Pinsky (pictured) said Friday.
That's why he's filed a $100 million claim Thursday on behalf of his client, Jill Doe, with state Claims Commissioner J. Paul Vance, Jr.
"You're not allowed to sue the state until you receive permission," Pinsky explained Friday. That's why he's filing the claim with the claims commissioner and not a court.
The claim says that state Board of Education, Connecticut Department of Education, and state Education Commissioner failed to take the appropriate steps to protect minor children from "foreseeable harm."
The state failed to determine "whether the Newtown Board of Education had provided a safe school setting at said school." The claim goes onto say that Sandy Hook Elementary and the Newtown Board of Education failed to "formulate and implement an effective student safety emergency response plan and protocol."
"As a consequence, the claimant-minor child has sustained emotional and psychological trauma and injury, the nature and extent of which are yet to be determined," the claim says.
Post a Comment
posted by: Kevin on December 28, 2012 5:35pm
While most of my colleagues and many of my friends are attorneys, this suit reminds of why many people hate lawyers.
posted by: tkerresma on December 28, 2012 6:10pm
This is the most horrific thing I have heard yet. I dont think there is a person that wasnt affect by this situation, especially those directly. Who wouldnt have some post dramatic syndrome after this, but to sue? Unless you put gates and alarms around any school, there was no way to stop this person, or even see it coming. Those teachers did exactly what needed to be done and by the children hearing any of it, was the only way to let the school know what was happening and giving the teachers time to prepare, and make those children as safe as they could.This is horrible.
posted by: donnacap on December 28, 2012 7:05pm
Really? "The claim says that state Board of Education, Connecticut Department of Education, and state Education Commissioner failed to take the appropriate steps to protect minor children from "foreseeable harm." And how would they have know? I'm sorry, this attorney is looking for his 15 mins of fame. If you feel harm was foreseeable then why leave your house or send your children to school. This country is to quite to sue and to place blame all in the name of making money.
posted by: HhE on December 28, 2012 7:07pm
This is despicable. The town of Newtown was in bad financial straits before this terrible tragedy, now this?
posted by: Walt on December 28, 2012 8:12pm
Has Pinsky been actually hired by someone on this case, or is he just fishing for a possible big class action bonanza?
Nothing here indicates he is working pro bono., which is OK I guess, but not deserving any big kudos
posted by: RCguy on December 29, 2012 3:19am
Quote on the Register Comment section:
"Such suits may get the politicans' attention, not something easy to do, and be a spur to much-needed security reforms."
—Bob Thomas, Retired.
posted by: lrnoff on December 29, 2012 9:15am
What a bunch of crap. I hope Irv Pinsky has a hard time sleeping at night.
posted by: momfromnewhaven on December 29, 2012 9:18am
I worry that lawsuits like this will only encourage those who think it is OK to arm teachers
posted by: Nhv.Org on December 29, 2012 10:46am
Classic Pinsky. What's next?
posted by: Mary Faulkner on December 29, 2012 10:58am
"Much-needed security reforms"? I am not sure what security measures a school COULD take to stop someone with an assault rifle ready to kill small children. The armed guards didn't stop the 15 deaths at Columbine. Perhaps an armed guard at every classroom door? Or for each student? We had trouble paying for librarians and paraprofessionals here in New Haven and the suggestion is to hire armed guards and put MORE guns into the system? How about properly funding gun safety research? How about mental health initiatives that help families help their mentally ill family members? How about sensible gun regulations? How about a culture shift that puts my right to not be shot by a gun before your right to own one? And lets stop talking about "good guys" and "bad guys". It is not an "us" against "them" scenario. We are ALL in this together. It is time for a major change in America and more guns is not the answer.
posted by: writewrong on December 29, 2012 12:00pm
Very disappointed in his actions…You just lost a fan!
posted by: swatty on December 29, 2012 1:31pm
Get Ready Pinsky! I'm going to sue YOU for stained emotional and psychological trauma after reading this sick story!
posted by: bwamba on December 29, 2012 2:07pm
I'm sure suing the school board will help. This man should have his license to practice revoked by the bar. What a despicable, selfish act.
posted by: V on December 29, 2012 2:52pm
Implicit in this lawsuit is that armed guards should be at every school, and yet LaPierre was lambasted for proposing that.
Fairly insulting to the taxpayers of CT in so many ways.
posted by: HhE on December 29, 2012 7:32pm
I think swatty's suit has considerably more merit than Pinsky's. Can we make it a class action?
I have friends who used to live in Newtown. They tell me the town was already strapped before this happened. I think they said that the town self insures itself, if so, his talk of insurance investigators tampering with evidence is just a red herring. Oh, for English Rule.
posted by: ramonesfan on December 29, 2012 9:33pm
Seems like a very entrepreneurial fellow. Some people can spot a money making opportunity in any situation. Winning the lawsuit would mean he gets to keep $33 million. If he ever gets tired of lawyering, he can go to work for Goldman Sachs, where they steal their money more honestly.
posted by: gibsonsdad on December 29, 2012 10:48pm
I haven't read anything about what safety policies were in place at Sandy Hook. Where I teach, we have extensive safety policies, including an 'active shooter' policy. I'm sure it isn't fail proof, but it is better than no policy. If this school/district had no such policy, they are surely negligent.
posted by: Brutus2011 on December 30, 2012 10:38am
I agree with the post by "RCguy:"
And I am so disappointed with the apparent lack of understanding by so many as to why we need to be asking questions (and not just about security)of those who administer public education in our state.
This nascent legal action is taking aim at the top state education administrators and wanting them to answer questions about how and why they do things they are given the public trust to do. Once this starts, the information asymmetry perpetrated upon the public by those who are charged with putting their public duty before their personal gain will become more and more visible.
But we first must ask questions of those we have elected, and appointed, to be in government.
It is the duty of every citizen in this republic.
And if we don't ask, and we become complacent, we will find ourselves in the kind of mess our state and nation are in now.
What kind of mess?
On the national level, we have the "fiscal cliff." On the state level, we now have a huge budget deficit." On the local level, we have a career politician who has become "king" of one of our most venerable cities (New Haven).
And how does this relate to the unthinkable tragedy of Sandy Hook?
___________________________________ (you fill in the blank.
posted by: David S Baker on December 30, 2012 11:19am
Wow this guy really strikes me as an attention starved, social parasite, opportunist. What are the odds he will use his winnings (aka your tax dollars) to undo the great oversights he spots in our educational facility security policies?
Jacques Verges was at least under the delusion he was doing something important.
HhE, good find.
posted by: dgeorge on December 30, 2012 3:55pm
I Have read the articles, and seen the news, and yet I still find this to be unbelievable. Just the fact that he took the suit is despicable, but the fact that the parents used their child to file the suit so their name wouldn'tbe published is outright disgusting. I'm sure the child didn't pick up the phone book and look up his number. Instead of mourning with the rest of the world, these "PARENTS" are trying to benefit from a bad situation and are just making it more painful for everyone else. Glad i'm not an attorney, or to put it in a nice way, Glad i'm not in the business where my clients can hide behind a child, or even have to.
posted by: Long Time NH Resident on December 31, 2012 10:21am
I too know many attorneys and Irving too, but this is a bit much. Not sure the angle being played here, seems like a lose lose for all. Even if he/his client wins, doesn't that money come from the taxpayers of the State. I think we've all suffered enough.
I was out of town for a few days and when u mention ur from CT people are like oh wow….. our reputation is damaged enough without trying to get paid for it.
Can't the healing be allowed to begin without dragging this thing through Court ( if the Commissioner approves)for the next 5-10 years.
I would rather see every citizen of CT donate $5 to a general fund and let all the victims split it.
posted by: cedarhillresident! on December 31, 2012 11:08am
Irv is a savvy business man. It may not be the van with the 1800 Lawyer in blinking lights on elm but it is free advertising.
Luv ya Irv but in my heart I have to say this is wrong. (but hey what do I know) It seems no different than the person in cali using the little boy that died to make money or the other women that use Newtown to make money. Maybe I am not seeing the whole picture


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After some serious thought and consideration, I went ahead and picked up a 4runner. I wanted the limited one in an 04 or an 06, but when it came down to it, this Sr5 was running well, looked good, and below market value--I couldn't pass it up.
So I replaced a 06 Tacoma Double Cab Off Off Road TRD with 200k miles.
I liked that truck, but the cats were bad (p420 and p430), the A/C had a leak, needed a windsheild and it had 200k miles...
I decided on the 4runner since it was comporable in reliablity and so forth. I have a little 6x8 trailer I can strap up behind the 4runner if I need to haul something. Also the 7k towing capacity is a hair better...I tow cars in the 3-4k with a 2wheel dolly but am considering a full on trailer.
So, here is what I ended up with:
04 SR5 v8 with tow package.
102k miles
everything works except the parking break (think it needs adjustment)
seems pretty well maintained except the Tbelt hasn't been changed.
It had crappy tires so I swapped them from the taco before I sold it--the ones on there were take-off's from a 2013 tacoma Sport with like new tread and exact same rim. So far no TPMS light, but I have th techStream software if it comes on...
My plans are mostly to keep it stock, a nicer stereo with blue tooth is probably in order. I need to get the TBelt done. I'll be using it as my DD unless I notice gas killing me, in which case I may go shopping for a DD.
Here are a few pics:, I haven't had a chance to clean it up yet. Bought it a couple days ago.
And here is what I gave up....


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Fine Arts Guild Production "Talking With" Opens This Weekend
Talking With" a series of women's monologues by Jane Martin will be performed on Friday and Saturday, May 9, 10, 16, & 17 at Park Village Playhouse at 7:30 p.m.
The show is presented by the Fine Arts Guild of the Rockies and is directed by Kerry Aiken and Diane Penn with help from Hancel McCord. Stage Manager of the show is C.J. Jensen.
With razor sharp wit and meaningful perplexity, eleven women share their experience with life, love and mortality. Always speaking from their soul, some of the cast members include a baton twirler, a fundamentalist snake-handler, an ex-rodeo rider, and an actress willing to go to any length for the job. Sometimes humorous, sometimes startling, sometimes heartwarming, these gripping narratives tell each woman's story in a very personal and revealing style.
"Talking With" consists of monologues by women who have learned to cope with change, loss, lack of love and aging in their own unique, unconventional ways. Some face reality squarely and find ways of compensating, while others retreat into fantasy or ritual. Beneath their odd and sometimes bizarre behaviors, we catch glimpses of ordinary people whose needs and emotions are not very different from our own, who share in our common humanity.
Take note, this is not just "women's theater," Talking With is a collection of observations on life from a woman's perspective. Men and women alike will find these extraordinary monologues fascinating. The show is recommended for high school age and up.
Talking With cast in order of appearance:
15 Minutes: Linda Moak-An actress describes her experience on stage as a lacerating exposure of her inner self, and ponders turning the tables on the audience.
Scraps: Lynn McManamon-A homemaker copes with her boredom and feeling of insignificance by escaping into the fantasy world of Oz.
Clear Glass Marbles: Shelley Drake- A woman gives an emotional account of how her mother dealt with her impending death.
Audition: LaShelle Lyman- An actress resorts to bizarre behavior to get a part she wants desperately.
Rodeo: Carmen Middleton-A young woman who grew up riding broncos in the ring laments the commercialization and loss of community in the rodeo.
Twirler: Samantha Holt- A young girl's enthusiasm for baton twirling becomes an obsession involving a bizarre and dangerous religious ritual.
Lamps: Linda Tucker- An elderly woman describes the gradual loss of people in her life and the growing importance of certain objects that have meaning for her, especially the lamps she gradually extinguishes.
Handler: Nadine Streib-A Southern woman recounts her family's religious practice of handling snakes, its tragic consequences, and her own experience as a snake handler.
Dragons: Sandra Vilar-A woman in labor believes she is giving birth to a dragon.
French Fries: Ellie Williams-A destitute old woman dreams of being allowed to live at McDonald's.
Marks: Cynthia Elkins-A woman who narrowly escaped an attack is "marked," and her life is changed in a surprising way.
Says Director Kerry Aiken, "It's been great working with the eleven women who bring to life the stories in Talking With. The characters have wildly different backgrounds, temperaments, ideas, voices and quirks. The women are characterized by their dress, speech, tone of voice, dialect, delivery and manner. We've been working on those things throughout the rehearsal period. Hancel McCord presented a great actor's workshop the first week of rehearsals."
She continued, "The characters are fascinating and present stories that will leave the audience talking and wanting to know more about the women they've met. When watching the play you will be laughing one minute, and choking back tears the next. There is a comic element but there are also pangs of sadness and desperation in the stories."
After the Friday, May 9th show, there will be a reception honoring Ned Linegar. Ned and his late wife Margaret, were the founders of the Fine Arts Guild of the Rockies. Ned recently published a book on the Fine Arts Guild titled, "The Beginning Of A Dream." Copies will be on hand at the reception.
Tickets for the show are on sale at Macdonald Book Shop (970) 586-3450. Advance tickets are $12 for adults, $6 for kids, at the door, tickets will cost $14 for adults, $8 for kids. See next week's paper for more on the show.
-Estes Park, Colorado News


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Final Four
UConn Upsets Michigan St 60-54, Back To Final Four
Shabazz Napier scored 17 of his 25 points in the second half, and UConn beat Michigan State 60-54 to return to the Final Four a year after the Huskies were barred from the NCAA tournament.
Wisconsin Beats Arizona 64-63 In OT In West Region
Frank Kaminsky had 28 points and 11 rebounds for Wisconsin, rallying the Badgers to a 64-63 overtime victory against Arizona to advance to the Final Four.
Florida 1st To Final Four, Beating Dayton 62-52
Scottie Wilbekin scored 14 of his 23 points in the first half as Florida became the first team to advance to the Final Four with a 62-52 win over the 11th-seeded Dayton Flyers.
Five Things: Cards Find A Way And Reserves Shine For Wolverines
Tonight, the No. 1 overall seed takes on a team once ranked No. 1 and now playing its best basketball. On one side is Louisville, the favorite when the field was announced, trying to keep the national championship trophy in the state of Kentucky.
Five Things: Motivated Cardinals Prevail And Wichita State Stays Alive
Even with limited drama—none of the regional finals were particularly thrilling—the NCAA Tournament is a wonderful thing, the perfect blend of fairness and unpredictability.


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Tavo Hellmund, managing partner of Full Throttle Productions LP, revealed Red McCombs as the primary investor for the Formula 1 United States Grand Prix racing project. McCombs, a business and sports legend, is committing financial resources, experience and the business relationships of McCombs Partners to complement Hellmund and his extensive motorsports background.
Hellmund and McCombs Partners have been working on potential site development as well as event and facility infrastructure. The end result will present one of the worlds most prestigious sporting events and the first ever purpose-built Formula One facility in the United States.
Hellmund, an Austin native, event promoter and former race car driver, has had a lifetime affinity for Formula One racing and has spent the last three years working to deliver the return of Formula One racing to the U.S. with his hometown of Austin as the events backdrop.
This project has been a tremendous undertaking, stated Hellmund. But for at least the next decade, Texas will host a global sporting event on an annual basis in a new world-class multipurpose facility. Knowing that our hard work is being rewarded and that my dream is becoming a reality is extremely gratifying.
It is a great honour to have Red McCombs and McCombs Partners as our primary investor and partner. Reds success in business and the professional sports arena is legendary. Working together as a team and under Reds direction, we will ensure that this project will make all Texans very proud and will benefit our great State.
Bringing Formula One back to the United States represents the opportunity of a lifetime and one that any city in the world would want, stated McCombs. The size and scope of an F1 event is comparable to hosting a Super Bowl and will bring substantial economic benefit to Austin, San Antonio and the entire State of Texas.
We know Tavo has a clear vision for developing Formula One into a major event with year-round opportunities. Over the past few years, he has built a solid business foundation and has assembled a great team - one we are proud to be part of. We are ready to roll-up our sleeves and work alongside Tavo to make this project a huge success.
McCombs, a Texas business and sports icon, is the former owner of the NFL's Minnesota Vikings and the NBA's San Antonio Spurs and Denver Nuggets. In addition, McCombs is the co-founder of Clear Channel Communications and has owned nearly 400 businesses in his career, including McCombs Automotive Group and McCombs Energy. McCombs Partners serves as the investment management division of McCombs Enterprises, the family office of Red McCombs.
In addition to McCombs Partners, Hellmunds team includes Prophet Capital Management, an Austin based private investment company founded in 1995, and MotoGP World Champion Kevin Schwantz.
Hellmund also launched the events official website: www.formula1unitedstates.com, a site dedicated to the local, state, national and global communities interested in the Formula 1 United States Grand Prix. The sites objective is to provide racing and non-racing fans alike a view into the global sporting event where 'technology meets glamour'. Site content will include information on the event visionary and investment group, FAQs, the host city of Austin, event news, Formula One racing information and Formula1.coms onboard lap driving experience. Fans will have the opportunity to register to receive additional information including updates on event ticket packages. The site will be continually updated with the latest news and developments for the Formula 1 United States Grand Prix project and respective racing industries.
Formula One racing is ranked among the top three most prestigious sporting events in the world along with the Olympics and Soccers FIFA World Cup. Formula One is considered the most technologically advanced sporting event in the world. It has a massive worldwide following, attracting more than 520 million viewers in 187 countries - making it the most-watched annual sport in the world. This project will place Austin and the state of Texas on the global stage. Its economic impact to the community is estimated to be approximately US$300 million on an annual basis, according to the Office of the Texas Comptroller.
Austin, Texas is located at the epicentre of a surrounding population of nearly 20 million people and provides 130 daily departing international flights within 180 miles. Austin also offers easy access from each U.S. coast, as well as from Canada, Europe, Mexico, Central and South America.
The track will be located on a 900-acre site in southeast Austin along the SH 130 corridor near FM 812. The majority of land involved in the project is formerly known as the Wandering Creek property. The sites natural topography is expected to provide an excellent canvas for the world class facility.
For more information, visit www.formula1unitedstates.com.


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Pink Floyd Tribute - PIGS - Royals after-party
add to outlook add to google calendar remind me
It's another Victoria Royals after-party with Canada's Most Authentic Pink Floyd Tribute - PIGS
PIGS on Facebook: https://www.facebook.com/canadianpinkfloyd
PIGS on the web: http://www.canadianpinkfloyd.com/
PIGS in local media: http://bit.ly/Zn5oQb
Tickets on sale in early 2013. Ticket outlet details to follow...
Formed in 2008 in Victoria, British Columbia, Pigs have been amazing audiences ever since with their dynamic re-creation of one of the world's favourite rock groups.
Pigs' claim to fame is their authenticity, which means looking, sounding and feeling like the real Pink Floyd in their hey-day: the '70s. Audiences can expect long, pyschedelic jams to such songs as 'Shine on You Crazy Diamond' and 'Set the Controls for the Heart of the Sun' as well as impassioned performances of emotional material like 'Comfortably Numb' and 'Us and Them'.
Audiences lose themselves in the band's lights and visuals, which give the music an otherworldly feel. Pigs has seven members and include a backup singer and saxophone in most performances.
With the passing of Richard Wright in 2008, fans of Pink Floyd lost hope of ever again seeing their favourite band re-united. Pigs offers the next best thing: an authentic look back into the breathtaking past of one of the world's most timeless bands.
Cost: |
Adult: $12 advance At the Door: $15 at door |
Category: |
Concerts | Music Pop | Rock |
Location: |
Soprano's Karaoke & Sports Bar
730 Caledonia, Victoria |
This event is for Adults, Seniors, Singles, Student / College | |
More Info: |
Jim Emery firstname.lastname@example.com 382-5853 |
Views: | 630 |


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Hi All
I finally purchased my first ever Ford
Basically I got a few problems at the moment.
There is a knocking noise coming from the front left wheel area.
I took it to the garage and they said it was the Top Mount, so i changed that. Noise went for about 6 hours but then came back!
So I took it back and they said the Drop Link was worn, So they changed that and now its still there!
So now they said they think its the wrong spring on the car? Does this sound correct?
There is definitely something wrong with that side of the car because the tracking is out and its wearing that wheel quite fast!
Thanks for all support


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Quantum Global Campus is located at Roorkee, the Mecca of higher education in India in the picturesque state of Uttarakhand. Roorkee is a quiet, scenic town located along the Ganga canal. Given its long history of higher education, it offers a rich pool of highly qualified faculty.
While the Institution encourages its students in the path of academic excellence, great emphasis is also laid on soft skills, English language classes, co-curricular and extra-curricular activities. As such, every Quantum student shall have the opportunity to excel in his or her chosen field.
Quantum has been ranked the Top Engineering college in Roorkee, DehraDun, UP & Uttarakhand by various magazines and research agencies. Quantum School of Technology has been ranked in the top 2 Engineering colleges in Uttarakhand by IMRB Research Agency. Quantum School of Business has been ranked the No. 1 MBA College in Uttarakhand and No. 29 in North India by the prestigious The Week Magazine.
Take a 360 Degree Campus virtual tour to get a real insight into campus facilites and infrastructure.
Quantum has consistently been ranked as the Top Educational Institution in North India. Click to find out more..
Quantum has consistently recorded the best placements in North India for its students.
Registrations to both Engineering and Management Programs for the year 2015 are on at Quantum. You can do it online at our website. Alternatively, you can visit the campus or any of our admissions offices nearest to you and register yourself.
National Stock Exchange (NSE) has conducted online test for NCFM Certifications at Quantum Global Campus, Roorkee on Tuesday dated 25 Nov 2014.It is important to note that NSE conducts online test centres) out of which onecentre is located at Dehradun which covers whole Uttarakhand Region.
Quantum Global Campus is the first and the only institute in whole Uttarakhand region which has had tie-up withNSE to conduct its online test for NCFM Certifications besides its own NSE-IT centre situated at Dehradun
Read moreCongratulations to all the 31 students selected in Maintec (HCL) Technologies.
Read moreCongratulation to all the 12 Students Selected in Pune based Qualitas Global. A Game Development & Testing Organization.
Read moreThe much awaited literary fest of Quantum Global Campus, Roorkee, finally unveiled its competitive multiple events under the grand finale of "Literary Fest-2014", spread all over the premises with lots of enthusiasts. The 'Kavi Sammelan' in Quantum Global Campus, Roorkee aims to revive the magic of contemporary poetry by bringing the best poets of the country on its stage. The Chairman Shri Ajay Goyal Ji, felicitated all the invited Poets, Guests and other Dignitaries. He said that words of a poet have an enormous power, and when they come from great poets like Prof. Krishna Kumar from Birmingham, UK, Dr. Budhinath Mishra, Shri Ram Kishore Tiwari , Sh. Dev Mani Pandey, Sh. Surendra Sukumar, Dr. Madhu Shukla and Sh. Salim Shivalvi from all walks of the country, the magnitude and resplendence of these words, tend to achieve enormous heights".
Read moreAt QUANTUM, life is an exciting tale of learning, progression and celebration.
Check the latest Placement News and Updates about companies visiting the campus.


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Is your child struggling with unhealthy weight?
Are you sick of the 'Pester Power' your child employs
to obtain a Junkfood fix?
Well watch out Ronald McDonald… there's a
New Health Hero in Town!
Superfood Spike and the Fart of Junkfood Jimmy is the first book which allows parents to tackle the subject of unhealthy weight and junkfood advertising head on.
It provides lots of laughs for kids while giving parents the tools to raise awareness about junkfood and superfood in a fun and engaging way.
"The Superfood Spike children's book is a great story that I'm sure children will love. In today's world where children are so often seen as fair game by sophisticated marketers of junk food, it's refreshing to find a book that uses humour to teach children (and adults) about the impact of advertising and poor food choices"
– Dr Rosemary Stanton OAM, nutritionist