text:
- 126.96.36.199 Introduction
- 220.127.116.11 Eligible Entities
- 220.127.116.11 Referrals to Insolvency
- 18.104.22.168 Field Insolvency Groups
- 22.214.171.124 Centralized Insolvency Operations
- 184.108.40.206 Automatic Stay
- 126.96.36.199 Opening a Chapter 7 Case
- 184.108.40.206 Proof of Claim - Asset Cases
- 220.127.116.11 Chapter 7 No Asset Process
- 22.214.171.124 Chapter 7 Asset Process
- 18.104.22.168 Commodity Broker Bankruptcies
- 188.8.131.52 Subordination of Federal Tax Lien
- 220.127.116.11 Sale of Property by the Trustee
- 220.127.116.11 Trust Fund Recovery Penalty
- 126.96.36.199 Bankruptcy Estate Income Taxes – Separate Taxable Entity
- 18.104.22.168 Postpetition Liabilities— Individuals
- 126.96.36.199 Conversion
- 188.8.131.52 Distribution
- Exhibit 5.9.6-1 Chapter 7 Trustee Turnover Procedures
Chapter 7 Liquidation. Liquidation under Chapter 7 of the Bankruptcy Code has traditionally been the most common form of relief sought by debtors. Chapter 7 is used primarily by individuals to free themselves of debt simply and inexpensively. Businesses wanting to liquidate and terminate their enterprises also file Chapter 7.
Chapter 7 provides relief to debtors regardless of the amount of the debts owed or whether a debtor is solvent or insolvent.
Debtors' assets are converted into cash for distribution among creditors. Individual debtors receive a discharge of all prepetition debts other than certain debts which are non-dischargeable under the Bankruptcy Code. (An individual's right to a discharge through the filing of a Chapter 7 petition is not absolute.)
While corporations and partnerships do not receive a discharge under Chapter 7, few, if any, assets remain from which to collect tax liabilities not paid by the bankruptcy estate.
A bankruptcy discharge does not extinguish a tax lien on property.
Parties. A Chapter 7 bankruptcy involves three major parties: the debtor, the trustee, and the creditors.
Voluntary/Involuntary. A case under Chapter 7 begins either by the filing of a voluntary petition by the debtor or by the filing of an involuntary petition by the creditors. (See IRM Exhibit 5.9.1-1), Glossary of Common Insolvency Terms.)
The Service's position is that the IRS will not initiate or join in a proceeding to request an involuntary bankruptcy for a taxpayer except in extraordinary circumstances, and then Insolvency must request the action through a referral to local Counsel.
Notice to IRS. Notice of a Chapter 7 bankruptcy filing must be given to the Service when the IRS is listed as a creditor in the debtor's schedules (Bankruptcy Rule 2002(f)).
Documents Filed. Bankruptcy Rule 1007 requires the Chapter 7 debtor to file supporting documents within a fixed time after filing the petition. Such filings include a mailing matrix, schedules, and a statement of financial affairs.
Trustee's Role. In general, a Chapter 7 liquidation is administered by a trustee who collects all of the debtor's assets, reduces the assets to cash, and distributes the funds to creditors in the priority set forth in 11 USC § 726. The Chapter 7 trustee is a private party who manages the bankruptcy estate on behalf of creditors. The trustee is accountable to the court for all actions taken on the case.
Trustee's Selection. The trustee is appointed by the United States Trustee's Office, an office of the United States Department of Justice. A Chapter 7 trustee can also be elected by creditors.
Trustee Responsibilities. The responsibility of collecting assets of the estate, which may include converting property to cash, avoiding unperfected liens, and setting aside preferential, fraudulent, and/or unauthorized transfers, falls to the trustee. If the business of the debtor is authorized to continue operating under 11 USC § 721, the trustee may, without notice or hearing, sell or lease property of the estate in the ordinary course of business. The trustee:
examines claims of creditors and objects to those claims when appropriate;
is charged with investigating the finances of the debtor;
files tax returns for the estate when required and pays taxes if due;
may object to a debtor's receiving a discharge if the debtor is uncooperative, found hiding assets, or is otherwise interfering with the effective administration of the case; and
must file a final report with the court and the United States Trustee at the conclusion of the case (any creditor, including the IRS, may object to this report).
Trustee Responsibilities under BAPCPA. In addition to the duties listed in paragraph (3) above, the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA) has given trustees the following duties for Chapter 7 cases filed on or after October 17, 2005.
Presumption of Abuse. The US trustee is obligated, in the case of an individual who files Chapter 7 bankruptcy, to review all materials the debtor has filed and, not later than 10 days after the first meeting of creditors, file a statement with the court stating if a debtor's case is presumed to be an abuse of Chapter 7 under the means test described in paragraph (b) below. The court must supply a copy of that statement to all creditors within five days. Within 30 days of the US trustee's filing a statement that the presumption of abuse arises, (s)he must file a motion for conversion or dismissal or file a statement explaining why (s)he does not think filing such a motion is appropriate.
The debtor's attorney's signature on bankruptcy cases filed on or after October 17, 2005, constitutes certification the filing is well founded in fact, is warranted by existing law, and is not an abuse of the bankruptcy process. The court may assess civil penalties against the attorney if it finds the attorney was negligent in his investigation into the circumstances of the bankruptcy. (See Rule 9011, Federal Rules of Bankruptcy Procedure.)
Means Testing. The US trustee (or bankruptcy administrator, if any) must apply a means test to individuals who file Chapter 7 bankruptcies and owe primarily consumer debt to determine whether their cases are presumed to be an abuse of the Chapter 7 process. The standards for this means test are based in part on the IRS national and local expense standards used in resolving delinquent tax accounts. If the debtor fails to meet the means test, the court, the US trustee, or in certain cases any party in interest can move for dismissal or conversion. This IRM will not go into detail on the mechanics of the process. 11 USC § 707(b)(2) provides a comprehensive explanation of means testing.
Property of the Estate. A Chapter 7 debtor's right to a refund (where the refund statute has not expired) is considered property of the bankruptcy estate to the extent the refund is attributable to prepetition events. As such they are subject to turnover to the Chapter 7 trustee even though the debtor may be in full tax compliance.
If a debtor files a Chapter 7 petition on October 12, the amount of his refund attributable to January 1 through October 11 is property of the bankruptcy estate.
Turnover Procedures. The IRS and the Executive Office of the US Trustees (EOUST) have agreed to the following conditions for the Service's turning over taxpayers' income tax refunds which are considered wholly or partially property of the Chapter 7 bankruptcy estate.
The trustee must request the turnover of refunds in writing for specific taxpayers. The trustee may use a form prepared by the IRS or may request the turnover on official letterhead.
The US Trustee's office will encourage trustees not to submit long rosters of their debtor inventories and to refrain from requesting small dollar refunds; however, the Service will not refuse to accept rosters or small dollar requests.
Insolvency will honor trustees' requests for turnover for 180 days from receiving the turnover request or for 180 days after the due date of a return (including extensions), whichever is later. If no return is received within these 180 day periods, the turnover request will not be honored.
If a trustee submits a turnover request on February 12, 2006, for a 2005 tax year refund, Insolvency will turnover any refund available up to and through April 13, 2007, assuming the debtor has an approved extension to file his 2005 return no later than October 15, 2006.
If a trustee submits a turnover request on February 12, 2006, for a 2004 tax year refund, Insolvency will turnover any refund available up to and through August 11, 2006 (180 days after the request is made).
Insolvency will not compute prepetition and postpetition refund allocations, nor amounts due the debtor as opposed to a non-debtor spouse in the case of a jointly filed return. Those calculations will be completed by the trustee. The trustee is responsible for refunding monies for postpetition allocations and to non-debtor spouses if applicable.
As soon as the turnover notice is received, Insolvency will input the appropriate bankruptcy freeze code and closing code on related accounts to hold the refund. If no account is found on IDRS, the Insolvency caseworker will create a dummy module with the appropriate freeze (TC 520 cc 81) to hold credits.
When no accounts are on IDRS and the bankruptcy is a joint filing, dummy accounts must be established for both husband and wife in the event the spouses file separately for the refund period.
IRM 220.127.116.11, Unassessed Liability/No Open Modules, provides instructions for establishing dummy modules.
Trustee requests for refund turnover received after the refund has been remitted to the debtor or before a pending refund can be intercepted will not be honored.
The turnover agreement procedures do not limit either the Service's right of setoff or domestic support agencies' rights of setoff.
Turnover Processing Steps. Exhibit 5.9.6-2 provides specific guidance for processing Chapter 7 trustee turnovers.
Invalid Turnover Requests. An invalid turnover request will not be honored. A request is invalid when:
the request is incomplete and does not include necessary information; such as, the case number or the tax period for which the refund is being requested, or
the trustee is requesting a refund on a postpetition tax period (unless the postpetition turnover is due to a settlement between the Service and the Chapter 7 Trustee.
Refund Turnover Requests for Discharged Cases. If a taxpayer files a return for a prepetition period after a discharge has been granted and a refund credit is generated, the automatic stay is no longer in effect. That credit may be offset against any existing federal tax debt owed by the taxpayer. If a trustee has requested a turnover of that refund credit, Insolvency should first offset the credit against the current tax liabilities, and any remaining credit should be manually refunded to the trustee.
FMS will offset any appropriate amounts from the refund turnover through the Treasury Offset Program before the manual refund goes to the trustee. No bypass indicator (BPI) code should be used on Form 5792, Request for IDRS Generated Refund (IGR).. (See IRM 18.104.22.168.3,Offsets to Other Agencies.)
Reopening a Closed Case. A MyEureka report must be run weekly to identify discharged cases that have been closed on AIS for which a trustee turnover request continues to be in effect. The report will select closed cases with a TTEE RFND or MIRRORING in the classification field on the AIS Taxpayer Screen.
When ADS systemically inputs TC 971 ac 100 on an account to begin MFT 31 processing, "MIRRORING" automatically generates in the classification field overriding any other condition code that might be present in that field.
The caseworker must take the following actions for cases listed on the MyEureka report:-
Access the case on AIS and remove the "On AIS" date.
Change MIRRORING to TTEE RFND in the classification field for cases that are being mirrored.
Ensure IDRS has an open TC 520 cc 81 on all related SSNs to freeze future refunds.
If necessary, update the 180 day follow-up date on the AIS letter screen to reflect an accurate turnover hold period.
A trustee's request for turnover of a prepetition refund does not affect the requirement that closing actions be initiated within 30 days of receipt of notice of discharge or dismissal or change the timeframe for release of liens in IRM 18.104.22.168, Release of Liens, and Interim Guidance Memo, Insolvency Monitoring of Lien Releases, SBSE 05-1209-071 (12/16/09).
Actions on Discharged Cases after the Turnover. Caseworkers must take the following actions on cases where discharge actions have been completed, and the trustee turnover request for all periods has been addressed.
Remove the TTEE RFND from the case classification field.
Reverse the TC 520 freeze codes manually on all related SSNs. TC 522 must be input on non-debtor spouse accounts.
Document the AIS history: "Removed TTEE RFND from case classification field since the refund was issued."
Re-input a closed on AIS date using the current date.
These procedures must also be followed when Chapter 7 cases are closed by Field Insolvency specialists and advisors.
Petitioners. Any person, with the exception of governmental units, railroads, insurance companies, banks and other financial institutions, can file a Chapter 7 petition. Eligible entities include the following:
Only individuals may receive a discharge.
Referrals to Insolvency. Non-Insolvency IRS employees must send a referral on Chapter 7 cases to the Centralized Insolvency Operation (CIO) as soon as they learn a bankruptcy has been filed (same day notification, if possible). CIO phone numbers for internal referrals can be found on SERP. The referral to Insolvency may be phoned or faxed to a CIO liaison. Or a written inquiry referral can be sent by overnight courier to the CIO at 2970 Market St. (Mail Stop - Q30.133), Philadelphia, PA 19104 - 5016. The outside of the envelope containing written referrals must be marked "expedite."
Assignments. Up-front clerical work on all Chapter 7 cases is performed by CIO tax examiners.
Chapter 7 Asset Cases. Field Insolvency groups work all Chapter 7 Asset cases by perfecting automated proofs of claim, preparing manual proofs of claim that cannot be processed through APOC, resolving complex issues such as adversaries and Exempt, Abandoned, and Excluded Property (EAEP) investigations and monitoring the case for distribution or discharge.
Individual Cases. Individual cases can be transferred by Field Insolvency to the CIO for closure after the discharge has been received and the "RI" has been entered on the taxpayer screen, all complex issues have been resolved and no distribution is anticipated or there is no NFTL that requires the case to remain open for distribution. See IRM 18.104.22.168, Chapter 7 Discharge Actions for additional information.Note:
If the case has "no liability" and must remain open to comply with a trustee turnover order, the case can be transferred to the CIO prior to the issuance of the discharge and input of the "RI" on the taxpayer screen.
Business Cases. A business case can be transferred from Field Insolvency to the CIO for closing actions (including resolution of credit balances, input of the TC 530 cc 07, and/or closure on AIS) after the following conditions have been met:
the proof of claim has been prepared and acknowledged,
any potential trust fund recovery penalty (TFRP) has been addressed,
aspects of the initial case review have been completed as required in IRM 188.8.131.52(13), Initial Review of Business Chapter 7 Asset Cases; and,
the Field Insolvency Manager has approved closure of the case.
Chapter 7 No Asset Cases. Complex cases, such as those with adversary proceedings, and large dollar cases requiring a review for collection potential from EAEP, are worked by Field Insolvency. Once the complex issue has been resolved, or it has been determined that all EAEP issues have been addressed and there is no collection potential from EAEP, the case is reassigned back to the CIO for closure.
Prior to transfer of the case back to the CIO, Field Insolvency must include a "SUMMARY HISTORY" to assist the CIO in closing the case. See IRM 126.96.36.199(6), Classification PDSC.
If a Field caseworker wants a closure delayed on a Chapter 7 No Asset or Chapter 7 Asset case, (s)he must open an OI screen on AIS. (See IRM 184.108.40.206(5),Preventing Premature Closures and IRM 220.127.116.11(6), Use of the OI Screen).
Complex Issues. Cases identified to have complex issues and assigned to the CIO should be transferred to Field Insolvency to resolve the issues. (See IRM 18.104.22.168(3), Complex Issues.) Once the complex issues have been addressed and resolved, generally the cases should be transferred back to the appropriate CIO unit.
Assignments. The CIO loads all Chapter 7 cases, runs IIP and works the subsequent reports, posts payments received outside of bankruptcy when those payments are received at the CIO address, and closes all Chapter 7 cases , except those assigned to Field Insolvency due to excluded, exempt, or abandoned property issues. The CIO is responsible for reassigning "large dollar Chapter 7 No Asset" individual cases to Field Insolvency for EAEP investigations when the outstanding liability exceeds the amount established by the Insolvency Area Managers and the Director, AIQ, and the CIO Operations Manager. Complex issues as defined in IRM 184.108.40.206(3), Complex Issues, may be transferred to Field Insolvency for resolution.
The Automatic Stay. IRM 220.127.116.11 ,Automatic Stay, provides an overall explanation of the issues involved in the imposition of the automatic stay, and IRM 188.8.131.52,Serial Filers, provides a discussion of the BAPCPA provisions affecting the operation of the automatic stay when an individual has filed one or more bankruptcies, which have been dismissed, prior to filing the current bankruptcy. Unless the stay terminates 30 days after the bankruptcy petition was filed or does not go into effect at all because of a debtor's serial bankruptcy filings, the stay arises at the time the petition is filed and remains until the case is closed by the court or dismissed. In the case of an individual who has filed a bankruptcy petition, the stay remains until the time a dismissal is ordered or a discharge is granted or denied. The stay against property of a Chapter 7 estate continues until such property is no longer property of the estate (i.e., the property is being administered by the trustee). (See IRM 18.104.22.168, The Effect of Bankruptcy on Collection.)
Limited Bankruptcy Timeframes. In the majority of Chapter 7 individual cases, the court grants a discharge shortly after the meeting of creditors has been held and the period of time has expired for creditors to file complaints objecting to the debtor's discharge. The period of time from petition to discharge is usually 90 to 120 days. Thus, the stay period, if allowed, and the period of the statute suspension for collection (plus six months) on any non-discharged tax in Chapter 7 cases are generally short.
Preventing Stay Violations. An account in a bankruptcy commenced before October 17, 2005, or an account in a bankruptcy commenced on or after October 17, 2005, and for which no order is issued to limit or eliminate the automatic stay must remain under freeze codes (TC 520s). The Service must exercise due diligence to conform with the provisions of the Bankruptcy Code to avoid violating the automatic stay. IRM 184.108.40.206,Serial Filers, details actions to take when the court orders variations to the automatic stay.
Payments Received for Dischargeable Tax. When a payment is received from a debtor after a bankruptcy petition is filed, and the debtor directs it be applied toward a dischargeable tax liability, the payment generally cannot be retained by the Service. In most circumstances that will mean returning the uncashed check to the debtor. If a payment by check is received prior to the bankruptcy petition's being filed, the check may be cashed after a bankruptcy petition date without violating the automatic stay.
A debtor may voluntarily pay a discharged tax. (See 11 USC § 524(f).) Therefore, if a debtor knowingly and voluntarily pays a discharged tax after the discharge is granted, the Service may retain it.
Payments Applied to Dischargeable Tax. If a voluntary postpetition payment has posted to a dischargeable tax period and no non-dischargeable periods exist, the payment generally must be refunded. But see 11 USC § 524(f). The Service must initiate the refund process within two business days of identification of receipt of the payment. To refund a payment Insolvency must complete and expedite a Form 5792, using established manual refund procedures. (See IRM 220.127.116.11, Manual Refunds.)
Unless evidence exists the debtor knows (s)he is not obligated to pay the discharged liability (such as a letter from the debtor stating as much), Insolvency will assume the payment has been made in error, and a refund will be issued. If an Insolvency caseworker is unsure if the refund should be sent to the trustee or to the debtor, guidance from Counsel should be sought.
Payments to Non-dischargeable Periods. If a voluntary postpetition payment has posted to a dischargeable tax period and a non-dischargeable period exists, the payment should be transferred from the dischargeable module to the non-dischargeable period.
Debtors, aware of penalties and interest that will accrue on non-dischargeable taxes, may make periodic payments outside of a bankruptcy on those periods to lessen their tax burden after the close of bankruptcy.
Prior Installment Agreements. IRM 184.108.40.206,Installment Agreements and Bankruptcy, and IRM 18.104.22.168.2,Postpetition Payments and Credits, explain how to address voluntary payments received during the pendency of a Chapter 7 bankruptcy.
Asset/No Asset. Upon receipt of a Chapter 7 case by Centralized Insolvency, each case is categorized as either an "asset" or a "no asset" case. Some bankruptcy courts simplify the asset/no asset determination considering all Chapter 7 petitions as "no asset" until the court issues a notice of possible dividend and sets a bar date. Other courts issue separate notices identifying the cases as either "asset" or "no asset."
The CIO must load all new cases on AIS and run IIP processes C and D within five workdays of receipt. (See IRM 126.96.36.199,Insolvency Interface Program.)
No Asset Case. The IRS and other creditors do not receive payments (or dividends) from the bankruptcy estate in a no asset case. For IRS purposes a no asset case is defined as any case:
where the trustee determines "no dividend" will be paid
in which assets of the debtor are less than allowed exemptions and costs of administration
involving a partnership or corporation where the costs of administration exceed the value of the assets
Since tax liabilities on unfiled returns are not dischargeable in Chapter 7 No Asset cases and no proof of claim is filed, the Service will not expend resources on procuring unfiled returns through the bankruptcy process on those cases.
Large Dollar Chapter 7 No Asset Case Reassignment. Large dollar Chapter 7 No Asset individual cases are reassigned by the CIO to Field Insolvency to address EAEP "up-front" instead of when a discharge is received. To reassign the cases, the tax examiner takes the following actions:
identifies all individual bankruptcy cases with liabilities greater than the amount pre-determined by the Insolvency Area Managers and the Director, AIQ, and the CIO Operations Manager,
uses the Chapter 7N Large Dollar Assignments Tool to reassign the case from the CIO to Field Insolvency. The tool can be located by accessing the Intranet and selecting the "Who/Where" tab on "SERP" and choosing "Chapter 7N Large Dollar Assignments." The tool can also be accessed at http://serp.enterprise.irs.gov/databases/who-where.dr/cio_assignment.htm.
the tax examiner then enters the 4 or 5 digit court key in the box "Enter Court Key" and presses the "Submit" button,
the name of and SEID of a designated field employee will appear. The CIO employee then manually assigns the case to the designated field employee by entering the SEID of the employee in the "Employee Field" on the "Taxpayer Screen" on AIS and clicking "Save" to complete the reassignment.
If the field determines that there are no collection issues to be pursued, a "SUMMARY HISTORY" is entered and the case is reassigned to the CIO.
Stay Research Required. No asset cases filed prior to October 17, 2005, require limited or no follow-up. To prevent violations of the automatic stay on those cases, TC 520 with the applicable closing code is input when the IRS is listed as a creditor. Follow-up on specifically identified cases filed on or after October 17, 2005, is required to check for possible stay variations resulting from serial filings. IRM 22.214.171.124,Serial Filers, and Exhibit 5.9.5-4, Steps for Processing Serial Filer Cases, provide procedures for caseworkers to address serial filers in all chapters, including Chapter 7 cases. The Service does not file a proof of claim in a no asset case. If the case converts to an asset case at a later date, a claim may be filed.
CC 84 and Corporate Chapter 7 Cases. IIP is programmed to input closing code 84 on all Chapter 7 cases with an 1120 filing requirement. This closing code cannot be changed. Closing code 84:
allows an assigned revenue officer to complete TFRP investigations and assessment determinations;
permits an assigned revenue officer to close the case as currently not collectible;
alerts ACS or field Collection not to take collection actions without first contacting Insolvency;
does not suspend the CSED;
does not move the account to Status 72; and
does not prevent collection actions.
ACS and CC 84. An account assigned to ACS may display a TC 520 cc 84. The CIO must access ACS when the case is identified on the IIP "stat 22 notice" and ensure any outstanding levies are released and any liens filed after the TC 520 date are withdrawn. After necessary actions are taken by the CIO, including determining if an OI is appropriate for a TFRP investigation, the case should be moved to the queue to delete it from ACS inventory. If ACS identifies a bankruptcy closing code 84 before Insolvency makes contact, ACS should put a 45 day hold on the account to allow sufficient time for the CIO to take necessary actions.
Consolidated Filings. Under consolidated group regulations, each member of the group is severally liable for the income taxes of the group for each year it was a member. However, the Service makes only one assessment which is in the name of the parent of the group. The procedures in IRM 18.104.22.168,Consolidated Chapter 11 Filings, should be followed before a parent's Chapter 7 account is closed as currently not collectable so the group's liability can be collected from other members if possible.
Conversion of Corporate Chapter 11 to Chapter 7. When corporate Chapter 11 cases convert to Chapter 7 proceedings, TFRP determinations may already be underway or completed. If a TFRP investigation has not been requested on the case, the actions in the IF/THEN chart in IRM 220.127.116.11(4) should be followed. Barring local practice to the contrary, the TC 520 freeze code used for the Chapter 11 bankruptcy may remain on the account when it is converted to Chapter 7.
Conversion of Individual Chapter 11, 12, and 13 Cases to Chapter 7. Two types of postpetition, pre-conversion taxes must be considered in a converted case of an individual. (See 11 USC § 348(d).)
Taxes that were entitled to be paid as administrative expenses of the pre-conversion case remain administrative expenses in the Chapter 7 case. (Typically only Chapter 11 estates owe administrative expense taxes.)
Taxes owed by the debtor for postpetition, pre-conversion periods are considered for all purposes as claims that arose on the day before the bankruptcy petition was filed; that is, they are considered prepetition, priority tax claims that are nondischargeable. Usually a debtor who is an individual incurs income tax liability for earnings for tax years ending during the time (s)he is in Chapter 11, 12, or 13 bankruptcy. Under 11 U.S.C. § 1115 and the separate taxable entity rule of IRC 1398, income taxes on earnings during a Chapter 11 case may be taxable to the estate and considered administrative expenses of the pre-conversion case.
Initial Review of Individual 7 Asset Cases. When an individual debtor who files Chapter 7 bankruptcy has non-exempt assets, those assets can be available for satisfying the claims of creditors. Asset cases require complete processing, and appropriate research must be conducted by Insolvency caseworkers.
Timeframes. When a Chapter 7 Asset case is assigned to a specialist or advisor prior to the 341, the initial case analysis should be completed at least 5 calendar days prior to the 341. If the case is received within 5 days of the 341 or after the 341, the initial case analysis must be completed at least 30 calendar days prior to the earlier of the last date to object to discharge or the bar date for the Service to file a proof of claim. Certain elements of this review may be required sooner; for example, to resolve stay violations or to respond to pending motions or defensive litigation. APOC flags should be worked within 5 workdays of APOC identifying the flagged condition. See IRM 126.96.36.199.7, APOC Flag Condition Time - Frame Requirements.
Aspects of the Review. Aspects of the initial case review include but are not limited to:
Stay Review. Cases filed on or after October 17, 2005, should be reviewed for dismissals of previous bankruptcies within one year of the current bankruptcy. For cases filed on or after October 17, 2005, the caseworker assigned to the 7 Asset case must check for possible stay variations resulting from serial filings. IRM 18.104.22.168, Serial Filers, and Exhibit 5.9.5-4, Steps for Processing Serial Filer Cases, provide procedures for working stay variations.
Discharge Limitations. IRM 188.8.131.52(7), Discharge Limitations, and Exhibit 5.9.5-3, Allowable Elapsed Time between Bankruptcy Filings, provide instructions for reviewing accounts for allowable elapsed time between discharge and subsequent bankruptcy filings.
Discharge Prior to Conversion. When the case was converted from a Chapter 7 No Asset case, and the discharge was entered prior to the conversion to a Chapter 7 Asset case, the specialist or advisor should determine if there were liabilities that were abated that must be manually added to the proof of claim. See IRM 188.8.131.52(2), Manual Proof of Claim Review,IRM 184.108.40.206.3(5), Reopened Chapter 7 Cases, and IRM 184.108.40.206.7(5)(p), Discharged, Dismissed, or Closed Date on AIS Flag, for additional instructions that must be followed when working these cases.
PACER should be reviewed to see if the discharge was revoked in the case. If so, remove the discharge date from the "Taxpayer Screen" and update the AIS history with the date the discharge was revoked. A TC 520 must be reinput to IDRS as the revocation of the discharge reimposed the automatic stay.Caution:
Unless the Court entered an order revoking the discharge, do not remove the discharge date from the "Taxpayer Screen." The debtor has already received a discharge in the current case. The discharge date will not change.
PACER Review, A review of PACER should be conducted to determine if the trustee filed a report of potential assets when he/she requested that the Court set a bar date in the case. Frequently, these reports will indicate the date that the trustee will file an interim report with the Court on the status of the liquidation of the assets, monies on hand, and when a distribution is anticipated. A follow-up should be scheduled for 30 days after the projected date of the interim report. If the report has been filed, the report may clarify the total assets and liabilities by claim classification, when a distribution may be forthcoming, and the potential for the Service receiving a distribution in the case.
If no date for the interim report has been documented in PACER, or if the trustee did not file a report of potential assets when the Court established the bar date, a follow-up should be scheduled for 30 days after the bar date to contact the trustee to discuss the prospects for distributions in the case and when a distribution can be anticipated. In these instances, the follow-up must be through telephone contact with the trustee or issuance of Letter 984, Request for Payment from Trustee.Note:
See IRM 22.214.171.124(4), Asset Discharge for Individual Debtor, for additional information.
Unfiled Returns. BAPCPA provides for conversion or dismissal in the case of unfiled returns. IRM 188.8.131.52,Unfiled Prepetition Returns, explains how the Service advises trustees of unfiled returns for Chapter 7 Asset cases and all other cases for which a proof of claim is prepared.
Lien Refile Determinations. A lien refile review must be conducted during initial case review if a secured claim will be filed by the Service or the Service has identified exempt, abandoned or excluded property that may be used to satisfy the taxpayer's liabilities after the discharge has been granted. IRM 126.96.36.199.2, Addressing Lien Issues and IRM 220.127.116.11, Chapter 7 Discharge Actions, provide more information on lien refiling.
Documentation. IRM 22.214.171.124,AIS Documentation, provides guidance on required AIS documentation.
Initial Review of Business Chapter 7 Asset Cases. With the exception of reviewing for adequate protection, the initial review for Chapter 11 BMF cases outlined in IRM 220.127.116.11,Initial Case Review for Chapter 11, should be followed for BMF Chapter 7 Asset cases. Insolvency specialists or advisors must conduct an initial case review at least 5 calendar days prior to the scheduled 341 meeting date. If the case is assigned to the caseworker less than 5 calendar days prior to the 341 date (or after the 341 date), the initial case review should be completed within 30 calendar days of the assignment. Elements of this review may be required sooner, for example, to resolve stay violations or to respond to pending motions or defensive litigation. All actions taken and findings in the review must be documented in the AIS history. APOC flags should be worked within 5 workdays of APOC identifying the flagged condition. See IRM 184.108.40.206.7, APOC Flag Condition Time-Frame Requirements, for additional guidance.
Initial Review of Large Dollar Chapter 7 No Asset Individual Cases. Individual large dollar Chapter 7 No Asset cases are reassigned from the CIO to Field Insolvency early in the case to determine if there is any collection potential from EAEP. This is done early in the case instead of after the discharge to facilitate unnecessary transfers between the CIO and Field Insolvency employees during case closing.
Timeframes. When a case is assigned to Field Insolvency prior to the 341 Meeting of Creditors, an initial case analysis should be completed at least 5 calendar days prior to the scheduled 341 meeting date. This allows the specialist or advisor ample time to plan on attending the 341 meeting to question the debtor if there are issues that need clarification. If the case is assigned to the caseworker less than 5 calendar days prior to the 341 date (or after the 341 date), the initial case review should be completed within 30 calendar days of the assignment unless the last day to object to discharge is imminent. In either case, the review should be at least 30 days prior to the last date to object to the discharge should a referral to Area Counsel become necessary.
Aspects of the Review. At minimum, the specialist or advisor must determine the following when conducting the initial case analysis:
Are there any outstanding liabilities that are potentially dischargeable? If not, the case can be reassigned back to the CIO without proceeding further.
Is attendance at the 341 to question the debtor warranted in the case?
What are the issues to be addressed at the 341 meeting of creditors?
Are there violations of the stay to be addressed?
If the debtor is a serial filer, is the automatic stay in the current case impacted by the filing of previous bankruptcy petitions?
Is there a NFTL present that requires refiling? If so, determine the lien refile date and schedule a follow-up in sufficient time to refile the NFTL prior to expiration.
Is there any excluded property, such as ERISAs, that are subject to collection due to the statutory lien after the discharge?
Did the debtor list excluded property erroneously as "exempt" property? If so, the debtor should be asked to remove the property from Schedule B - Personal Property in the bankruptcy schedules.
There are many tools available to the specialist or advisor to assist in completion of the initial case analysis. These tools include, but are not limited to, IDRS, PACER (for the Statement of Financial Affairs and Bankruptcy Schedules), locator services, such as: Accurint, the revenue officer case history on ICS, the ACS history on AMS, examination files, local court house on line records, and on line real estate property valuations. The facts and circumstances in the case should determine the extent of the research conducted.
Case History Documentation. All aspects of the review must be documented in the AIS history. Prior to reassigning the case back to the CIO, all cases must have a "SUMMARY HISTORY" . See IRM 126.96.36.199, AIS Documentation.Note:
See IRM 5.9.17, Closing a Bankruptcy Case, for guidance on closing procedures for EAEP cases.
Notice Given if Dividends Likely. The court may initially conclude no assets exist in a case but later determine a dividend payment is possible. At that time the court will issue a notice for the filing of claims. A creditor, including the IRS, must file a proof of claim in a Chapter 7 Asset case to share in the distribution of the estate. The procedures for filing claims in Chapter 7 are set forth in Bankruptcy Rules 3001 and 3002.
Unassessed Claim. To protect the government's interests, the IRS can file an unassessed (estimated) claim when the exact amount of a debtor's liability is unknown (e.g., unfiled returns, TFRP under investigation, pending audit). However, the claim must have a factual basis. The government should be in a position to show the court the liability is reasonable. (See IRM 188.8.131.52.1,Unassessed Claims.)
Monitoring. If Insolvency files an unassessed claim based on a pending assessment, it must monitor the case for the receipt of more information from either the debtor or the IRS function proposing the assessment. After all pending actions are completed, Insolvency may amend or withdraw the claim, or file a $0 claim if appropriate. (See IRM 126.96.36.199.1(11), Liability Not Pursued.)
Claim Filed on Behalf of Creditor. If a creditor (IRS) does not file a proof of claim, the debtor or the trustee may file a claim on behalf of the creditor. The Service generally then files a corrected claim or an amendment with the court showing accurate tax figures based on the IRS tax database.
Objections to Claims. The duty to object to any duplicative, overstated, previously paid, or otherwise questionable proof of claim falls to the trustee. Objections to a claim may also be made by other parties, including the debtor.
Bar Date. Information on Chapter 7 bar dates and late filed claims can be found in IRM 184.108.40.206, Bar Dates and IRM 126.96.36.199.1, Late Filed Claims.
Chapter 7 No Asset Process under BAPCPA. Following are the steps typically involved in a Chapter 7 No Asset bankruptcy filed on or after October 17, 2005. Their order of occurrence may vary from court to court.
The debtor attends credit counseling briefing within 180 days prior to filing a petition.
The petition is filed.
The debtor files Form 22A, Statement of Current Monthly Income and Means-Test Calculation, with the petition or within 15 days thereafter.
The debtor's attorney certifies the client's filing is not abusive (Bankruptcy Rule 9011).
The court provides written notice to creditors not later than ten days after the petition date if a presumption of abuse arises in an individual's case.
The United States trustee files a statement with the court determining if the current case is presumed to be an abuse of the bankruptcy system.
A hearing is held on the motion to convert or dismiss based on abuse if applicable.
The debtor provides the most recent return to the trustee no later than seven days before the 341 meeting.
The § 341 meeting of creditors is held.
The trustee checks for assets.
The trustee approves and files a report of no distribution.
For individuals, the court enters discharge (normally 90 to 120 days after the filing of the petition) or enters denial of the discharge (for individuals).
The court approves the no asset report and excuses the trustee.
The case is closed.
Chapter 7 Asset Process under BAPCPA. The steps in a Chapter 7 Asset bankruptcy typically are:
The debtor attends credit counseling briefing within 180 days prior to filing a petition.
The petition is filed.
The debtor files Form 22A, Statement of Current Monthly Income and Means-Test Calculation, with the petition or within 15 days thereafter.
The debtor's attorney certifies the client's filing is not abusive (Bankruptcy Rule 9011).
The court provides written notice to creditors not later than ten days after the petition date if a presumption of abuse arises in an individual's case.
The trustee files a statement with the court determining if the current case is presumed to be an abuse of the bankruptcy system.
A hearing is held on the motion to convert or dismiss based on abuse if applicable.
The debtor provides most recent return to the trustee no later than seven days before the 341 meeting.
The § 341 meeting of creditors is held.
The trustee files an interim report of assets.
The trustee checks for any additional assets.
A proof of claim is filed.
The court enters discharge (for individuals).
The trustee administers the case, including 1) liquidating all assets that create a benefit for the estate; 2) objecting to questionable proofs of claim; 3) determining the distribution of proceeds; and 4) filing a final report.
Overview. Commodity brokers are not eligible to file Chapter 11 or Chapter 13 bankruptcies, leaving Chapter 7 as their only option. A commodity broker is a licensed agent involved in the trading of commodities also known as commodity "futures " trading. (See Exhibit 5.9.1-1, Glossary of Common Insolvency Terms..) A broker may be an individual or a company. 11 USC §§ 761 through 767 provide requirements and procedures for commodity broker bankruptcies.
Commodity Futures Trading Commission (CTFC). The CTFC is an independent agency of the US government that oversees futures markets to:
encourage competition and efficiency
ensure their integrity
protect against manipulation, abusive trading practices, and fraud
ensure the financial integrity of the clearing process
CTFC and Bankruptcy. A commodity broker must advise the CTFC within one business day of filing a bankruptcy. Its role is to regulate liquidating commodity brokers. The CTFC may:
exempt the trustee from time limits imposed by the Commission
extend time limits imposed on the trustee
inspect trustee records
become involved in account transfers
Although the CFTC has regulatory authority over an insolvent commodity broker, the Bankruptcy Code still applies.
AIS Processing. The Centralized Insolvency Operation (CIO) will do initial clerical processing of commodity broker bankruptcies as they would for any other Chapter 7 bankruptcy.
Normal Chapter 7 Procedures. Commodity broker bankruptcies are handled by the Field Insolvency office that handles that court's jurisdiction.
TFRP investigations will be conducted and assertions will be made as in any other Chapter 7 bankruptcy.
Unfiled tax returns must be addressed.
Claims are filed with the bankruptcy court.
Payments will be posted through AIS according to Chapter 7 priorities.
Collection from exempt, abandoned, or excluded property should be addressed in the case of individual filers.
Discharges will be processed following Chapter 7 guidance provided in IRM 5.9.17, Closing a Bankruptcy Case.
Payment Preference. The allowed claims of customer creditors (see Exhibit 5.9.1-1, Glossary of Common Insolvency Terms) generally receive priority preference with respect to all other claims, except administrative expense claims under 11 USC § 503 that are attributable to the administration of customer property. The IRS will never be a customer creditor. After distribution is made to customer creditors, distribution on other claims are treated as in a usual Chapter 7 Asset case (11 USC § 507).
Counsel Guidance. Issues surrounding commodity broker bankruptcies not covered by this IRM should be discussed with Counsel.
Subordination. 11 USC § 724(b) provides for the distribution of the proceeds of property encumbered by a valid prepetition tax lien. Specifically it provides that holders of unsecured priority claims under 11 USC § 507(a)(1) through § 507(a)(7) are paid before the holder of the tax lien is paid. This is referred to as a subordination of the tax lien (taking a lower position). ( See IRM 220.127.116.11, Distribution, and IRM 188.8.131.52.1(6),Certificate of Discharge.)
Administrative Expenses. For cases filed before October 17, 2005, the Service's claim for administrative expenses that accrue during the bankruptcy proceeding is entitled to priority classification under 11 USC § 507(a)(1). Accordingly the Service's secured tax claim will be subordinated to the payment of the Service's administrative tax claim, if any.
On cases filed prior to October 17, 2005, in addition to the federal secured tax claim, state and local secured tax claims are also subordinated.
BAPCPA Amendment. BAPCPA has amended 11 USC § 724(b) for Chapter 11 cases filed on or after October 17, 2005, which are converted to Chapter 7 Asset cases. In those cases the tax lien will not be subordinated to administrative claims incurred in the prior Chapter 11 case except for the following:
Further before the trustee can subordinate a tax lien on personal or real property, the trustee must:
exhaust the unencumbered assets of the estate, and
recover from property securing an allowed secured claim the reasonable and necessary expenses of preserving or disposing of the property.
Tax liens arising in connection with ad valorem taxes on property, are no longer subordinated with exceptions being claims for wages, salaries, and commissions, or for contributions to an employee benefit plan.
Lien Interest. When the trustee disposes of the debtor's assets by selling property, and the IRS has a valid prepetition notice of federal tax lien on file, the Service's rights to distribution based on its lien interest in such property is unknown until all priority claims, including administrative expenses, are determined. Thus Insolvency should not interfere with, or object to, any sale of property by the trustee without specific cause.
Chapter 7 trustees have in the past avoided the fixing of the Service's lien on motor vehicles by arguing they assume the status of purchaser under IRC § 6323. Under the provisions of BAPCPA, trustees cannot assume the status of a purchaser.
Certificate of Discharge. A need to issue a Certificate of Discharge may arise, if requested, to clear title concerns after the completion of a sale. If appropriate, a no interest lien discharge may be considered. (See IRM 220.127.116.11.1,Sale of Property Considerations. )
Post-Discharge Liens. Tax liens filed against the individual debtor after a discharge from bankruptcy is granted may interfere with the sale of estate property. Because the bankruptcy estate is a separate entity, such post-discharge liens do not attach to estate property. Therefore, a no interest lien discharge may be provided.
Tax Consequences. The US Trustee encourages trustees to evaluate the tax aspects of any sale and discourages them from administering any property with significant tax consequences.
Objections to Sale. Insolvency caseworkers should review sale motions with tax consequences in mind and object to sales when appropriate, as provided in IRM 188.8.131.52.1(8), Tax Consequences.
In rare instances estate property may be abandoned after the debtor has received a discharge, but before the court has closed the case. If the Service records an NFTL after the debtor receives a discharge but before the abandonment of the property and court closure, the federal tax lien will attach to the property once it is abandoned (11 USC §554(c)).
Corporation and Responsible Officers in Bankruptcy. Assessment of the Trust Fund Recovery Penalty (TFRP) under IRC § 6672 becomes an issue when a corporation, having unpaid trust fund liabilities, files a Chapter 7 petition. In addition, the potentially responsible persons of the corporation may have filed their own bankruptcy petitions.
Objections Filed by Responsible Persons. The responsible persons frequently object to the TFRP investigation the IRS conducts against them, claiming trust fund taxes will be paid through the corporate bankruptcy proceeding.
Field Compliance Assignment. If research on corporate asset Chapter 7 cases shows balance due accounts or return delinquency periods assigned to field Collection, Insolvency should contact the revenue officer (RO) group to determine what information is available on the case.
Investigations. If an investigation of the TFRP is warranted, guidance in the IF/THEN chart below should be followed.
IF... THEN... local procedures provide for issuance of an OI to an RO group and the tolerance for a TFRP meets IRM 184.108.40.206(11), TRFP Investigation Criteria. an OI should be issued to the appropriate ro group to complete a TFRP investigation. local procedures provide for handling TFRP investigations within the Insolvency function and locally established tolerances are met, the case should be reassigned to a Field Insolvency employee with properly delegated authority to complete the TFRP investigation. -
TFRP Assessments Against Responsible Persons. IRM 126.96.36.199(14), Chapter 7, provides the TFRP should generally be assessed against the responsible persons of a corporate Chapter 7 debtor case unless compelling evidence exists the assets of the estate are sufficient to satisfy all of the liabilities of the debtor (which is rare).
Generally, Insolvency will recommend immediate assertion of the TFRP.
If the decision is made not to assess, Insolvency must indicate the reasons for non-assertion in the case history. The decision on withholding the TFRP assessment should be reviewed with the manager in accordance with local procedures.
Should the circumstances/factors change at a later date that prompted Insolvency to delay the TFRP assessment (e.g., a current review indicates non-compliance, plan deficiencies, etc.), reconsideration should be given to making the TFRP assessment. Also, if the limitations period for assessment will expire before the liability is paid in full, the assessment should be made before the period expires.
Field Assignment of Accounts. If a revenue officer group wants an account to remain open to field Collection, TC 520 with closing code 84 will not suspend a balance due account for the module on which it is input.
Although CC 84 is available for circumstances that require extensive field work and involve little risk of a violation of the Bankruptcy Code, caution must still be employed. The Service can be liable for damages if a violation of the Bankruptcy Code occurs.
Individual Chapter 7 – IRC § 1398. The bankruptcy estate in an individual Chapter 7 bankruptcy is a separate taxable entity required to file its own Form 1041, U.S. Income Tax Return for Estates and Trusts.
IRC § 1398 contains special provisions for an individual under Chapter 7.
Individual debtors have the right to terminate their tax year when the petition is filed.
The Chapter 7 trustee has a duty to file the estate's tax return.
The return filing requirements are generally the same as for individual Chapter 11 cases, as discussed in IRM 220.127.116.11,Internal Revenue Code § 1398 Issues.
No Separate Taxable Entity. In non-individual cases, no separate taxable entity is created. The trustee or debtor in possession (DIP) is responsible for filing any required returns.
Relief from Filing Requirement. A trustee or DIP can apply to be relieved of the return filing requirements in corporate cases when the corporation:
has ceased business;
has no assets to be liquidated by the trustee; and
has no income for the taxable year.
The procedures are found in Revenue Procedure 84–59, which has not been updated since the IRS's reorganization in 2000. These procedures are outlined below in paragraph (4) with supplemental guidance.
In addition to a bankruptcy trustee or DIP, these procedures may be used by a receiver or trustee of a corporation that is in receivership, dissolution, or in the hands of an assignee by order of a court, operation of law or otherwise. In particular, a trustee in a Securities Investor Protection Act proceeding may use these procedures to request exemption from return filing.
Content of Exemption Request. The bankruptcy trustee or DIP must submit a written request for exemption from return filing to the Service. The request should contain the following:
The name, address, and employer identification number of the corporation;
The facts, with supporting documents if necessary, explaining why relief from the filing requirements is needed; and
The following statement signed by the bankruptcy trustee or DIP:
"I hereby request relief from filing federal income tax returns for tax year(s) ending [ date(s) ] for the above named corporation and declare under penalties of perjury that to the best of my knowledge and belief the information contained herein is correct."
Trustees (other than a bankruptcy trustee or DIP), receivers, and assignees requesting exemption from return filing must also include in their requests the notice of appointment to act, as required under Treas. Reg. § 301.6036-1(a).
Procedures for Exemption Requests. The trustee must make a written request to the Service giving the reasons to support a filing exemption. The request must be signed under penalties of perjury.
Requests must be submitted to the local Insolvency office handling the case.
Requests must be reviewed by an Insolvency advisor or a grade 12 Insolvency specialist with assistance from Counsel if needed.
The preliminary determination (either to approve or deny) made by the advisor or specialist must be approved by an Insolvency group manager.
Upon manager approval the request and Insolvency's recommendation must be forwarded to the appropriate Exam bankruptcy coordinator within 45 days from the received date of the request.
Exam will review the request and Insolvency's recommendation and resolve any issues it may find with the recommendation.
Upon concurrence with Insolvency's recommendation, Exam will prepare and mail the Service's response to the trustee.
The determination to grant or deny the request must be made within 90 days of receipt of the request.
Rule for Individuals – Chapter 7 Postpetition Debts. In a Chapter 7 proceeding, the individual debtor is considered to be a separate taxable entity from the estate. Taxes on the individual debtor's postpetition wages are incurred by the individual debtor, while taxes on income arising from assets which are property of the estate are incurred by the estate. Therefore, a postpetition liability incurred by an individual debtor (rather than the estate) in a Chapter 7 proceeding cannot be claimed in the bankruptcy case.
Voluntary. Chapter 7 debtors may voluntarily convert their cases to proceedings under Chapters 11, 12, or 13 at any time, as long as the Chapter 7 case was not originally converted from a Chapter 11, 12, or 13 proceeding.
Involuntary. Involuntary conversions to Chapter 11 sought by creditors or the trustee can also occur.
Under BAPCPA. For cases filed on or after October 17, 2005, the IRS may move to dismiss or convert a Chapter 7 bankruptcy filed by an individual to a Chapter 11 or Chapter 13 case where a presumption of abuse of the bankruptcy process arises because of the means test.
Presumption of abuse because of the means test is explained in 11 USC § 707(b)(2).
Order of Distribution. The order of distribution in a Chapter 7 case for estate property not subject to liens is established in 11 USC § 726 and is as follows:
11 USC § 507 priority claims (includes administrative expenses, postpetition taxes incurred by the estate, including interest on these taxes, and priority tax claims) which are timely filed, or which are untimely filed but meet the filing timeframes outlined in IRM 22.214.171.124, Bar Dates.
General unsecured claims which are timely filed, or filed late due to lack of notice.
Late claims (other than those in items (1) and (2)).
Non-pecuniary loss penalties (punitive in nature, for example, failure to pay) and fines.
Postpetition interest.
The debtor receives the remainder of any distribution.
Rights of a Private Secured Party. The distribution does not affect the rights of a private secured party. If property in which a secured party has a lien is sold by the trustee, that creditor will be paid first from the sale proceeds after the expenses of the sale.
Treatment of IRS Tax Lien. The IRS, as a secured creditor, does not have the same rights as private secured creditors in a Chapter 7 case. This is because the tax lien is subordinated to certain priority claims, pursuant to 11 USC § 724. Other priority claims will be paid before the tax lien is paid. (See IRM 220.127.116.11, Subordination of Federal Tax Lien, and IRM 126.96.36.199, Sale of Property by the Trustee.) However, if the notice of federal tax lien has priority over the interest of a private secured party, the tax lien may be paid before the secured party depending on calculation under 11 U.S.C. § 724.
The following table outlines procedures to be taken on tax periods subject to a Chapter 7 trustee's request for turnover of a refund where the bankruptcy case has not yet been discharged. (For turnover requests on cases where the bankruptcy has been discharged before the debtor's refund has posted, see IRM 126.96.36.199.3(4), Refund Turnover Requests for Discharged Cases .)
When an invalid trustee turnover request is received, and the case is not on AIS, the tax examiner is not required to add the case to AIS. See IRM 184.108.40.206.3(4), Invalid Turnover Requests, for additional information.
IF the trustee turnover request applies to one or more prepetition returns that have been filed, and... | THEN... |
IMFOLI indicates that the refunds for all requested periods have been issued and there is no outstanding liability, and the case for which a turnover is requested is not on AIS, | notify the trustee that the requested refund(s) is not available and place the turnover request in classified waste. There is no need to add the case to AIS. No further action is required. |
IMFOLI indicates that there is an outstanding liability or all requested refunds have not been issued, and the case for which a turnover is requested is not on AIS, | secure the filing information from the court's electronic records and establish the case on AIS. Once the case is on AIS, continue with the instructions below. |
IMFOLI indicates a refund credit on the requested period(s), and no prepetition liabilities exist, | prepare Form 5792 to request a manual refund to the trustee and update the AIS history. Note: TTEE RFND is not required in the Classification field on the AIS Taxpayer Screen unless the trustee has requested turnover of refunds for returns not yet filed. |
IMFOLI indicates a refund credit on the requested period(s) and prepetition income tax liabilities exist, | complete a credit transfer to the prepetition income tax liabilities, and if credits remain, prepare Form 5792 to request
a manual refund to the trustee and update the AIS history. Note: TTEE RFND is not required in the Classification field on the Taxpayer Screen unless the trustee has requested turnover of refunds for returns not yet filed. |
IMFOLI indicates a refund credit on the requested period(s) and prepetition tax liabilities exist that are not for income (e.g., TFRP assessment), and no local rule or standing order exists allowing IRS offsets, | prepare Form 5792 to request a manual refund to the trustee and update the AIS history. Note: TTEE RFND is not required in the Classification field on the Taxpayer Screen unless the trustee has requested turnover of refunds for returns not yet filed. |
IMFOLI indicates a refund credit on the requested period(s) and prepetition tax liabilities exist that are not for income (e.g., TFRP assessment), and a local rule or standing order exists allowing IRS offsets, | complete a credit transfer to the outstanding liabilities, and if credits remain, prepare Form 5792 to request a manual refund
to the trustee and update the AIS history. Note: TTEE RFND is not required in the classification field unless the trustee has requested turnover of refunds for returns not yet filed. |
the Classification field on AIS is blank, | input a TTEE RFUND in the Classification field on the AIS Taxpayer Screen , input TC 520 cc 81 on related SSNs, and update the AIS history: "Recvd ttee turnover request for tax yr XXXX date stamped XX/XX/XX. 520 cc 81 input on XXX-XX-XXXX and XXX-XX-XXXX" [both SSNs if the debtor is currently married]. Input a 180 day follow-up on the AIS letter screen. |
the Classification field on the AIS Taxpayer Screen on AIS shows PDSC, and the case has not been discharged, | do NOT override the PDSC with the TTEE RFND. Input TC 520 cc 81 on related SSNs, and update the AIS history: "Recvd ttee turnover request for tax yr XXXX date stamped XX/XX/XX. 520 cc 81 input on XXX-XX-XXXX and XXX-XX-XXXX" [both SSNs if the debtor is currently married]. Input a 180 day follow-up on the AIS letter screen. |
the classification field on the AIS Taxpayer Screen shows PDSC, and the case has been discharged but the discharge has not yet been worked, | • work the issue represented by the PDSC classification (or take appropriate action); • once all issues are addressed and actions are taken, replace the PDSC classification with a TTEE RFND; • request ADS closing (RI); • if a DDR generates that cannot be resolved immediately, follow IRM 22.214.171.124 to address liens; • input TC 520 cc 81 on related SSNs, and update the AIS history: "Recvd ttee turnover request for tax yr XXXX date stamped XX/XX/XX. 520 cc 81 input on XXX-XX-XXXX and XXX-XX-XXXX" [both SSNs if the debtor is currently married]. • Input a 180 day follow-up on the AIS letter screen. |
Note: It may be necessary to establish dummy modules in some instances. IRM 18.104.22.168, Unassessed Liability/No Open Modules, provides instructions for creating dummy modules. |


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Interesting post by an MD on healthcare as a good but not a right
It's a mistake to think of health care as a right. It is not a right; it is a good. Freedom of speech, by contrast, is a right, as is freedom of religious belief. They are privileges that inure to individuals as a consequence of the primordial right, free will. That is why we see them as inalienable. The exercise of these rights does not depend on any action of government, but rather on its inaction. Government may not legitimately interfere with their exercise, but nothing mandates that the government provide us with printing press or chapel.Read it all at the First Things blog.
Health care is different. It is more akin to the other goods which sustain life: food, clothing, and shelter. A well-ordered society exists to protect its members from the unlawful taking of life, and is structured to facilitate its members' acquisition of these goods.
But health care differs from these other goods: First, health care is not absolutely essential for all people on a daily basis; second, there is an insufficient supply in this world to meet the demand of those who would have it. There is enough food in the world to feed everyone. Hunger and famine are the result of its inadequate distribution, not its absolute dearth. There are enough garments in the world to clothe everyone, and enough roofs to protect all from the rain. Health care, in contrast, is a far scarcer resource. Descartes once remarked that common sense is the most equitably distributed attribute in the world, because we never see anybody who feels he doesn't have enough. Health care is not like common sense. We often see people who feel they don't have enough, or at least can't get enough at a price they're willing or able to pay.

subset: commoncrawl


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Sunshine31-I love fresh tortilla chips that they serve in most Mexican restaurants.
But I have to say that my favorite summer party appetizers are little finger sandwiches and pigs in a blanket. I usually buy the miniature hotdogs along with the Pillsbury crescent rolls.
I roll the dough and put a little hot dog inside and bake it. The finger sandwiches and the pigs in a blanket are nice quick summer appetizers that are great for any party.


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Have you ever wanted to dig deep into your customers (or prospective customers) head to understand what they think about your company, why they shop with you and not someone else or even to get reactions to new innovative ideas that could help drum up new business?
In the corporate world, we use many research techniques to address these type of questions but one that is quite often employed are focus groups. Focus groups are interviews with a group of people who are asked about their perceptions, opinions, beliefs and attitudes towards a product, service, concept, advertisement, idea, or packaging. Questions are asked in an interactive group setting typically in a designated facility, where participants are free to talk with other group members.
You may think that you don't have the money to implement anything like this. The reality is that you CAN actually employ this type of approach and it DOESN'T have to be expensive at all. Keep in mind that with focus group studies, there are several controls and procedures that ensure the unbiasedness and richness of feedback of which is typically managed by a trained moderator. However, the fundamental idea of having a direct dialogue with your audience is not something that should preclude you from doing it even if you aren't trained at moderating.
So how would you go about doing it on a shoe string budget? Here are the key elements that you will need to consider in order to conduct a focus group:
- Participant recruitment and Incentive
- First you need to determine who your specific audience is that you want to get feedback from and this could be done using some of the approaches that Amishi mentioned in her post (i.e. surveys, polls, etc.). Or an even simpler way is to just ask them if they want to participant in a focus group by reaching out to them using your current communication and marketing vehicles.
- In order to encourage sign-up, you'll need to reward potential participants with some incentive for spending time with you to share their thoughts. The easiest thing to do would be to offer some of your products/services for free or at a substantial discount rather than incenting them with cash. (i.e. coupon for a free meal, free products, discounted services). The key thing is to make sure your incentives are broadly appealing enough to get them to want to come and participate.
- Moderator's Guide
- It's very important that you create a "script" around what you want to ask your participants in the discussion you will have with them. This will keep you on task particularly as you may have folks that go off topic or you end up spending more time on one of the many areas you are looking to get learnings on. Your guide should include all the key questions and desired answers you want to get. Determine how much time you want to spend on each question up front and prioritize what learning is most important to you.
- Session Timing and Logistics
Before you start recruiting, there are some critical logistics you should consider.
- Focus group Location - Determine where you are going to hold this. Look no further than your own establishment if you happen to have a physical presence. If you happen to just operate online, you could actually do a focus group via the phone. While you may not get to see them face to face, you could certainly try to do this through a conference call and get input that way.
- Session Time – Most people are pretty busy these days so doing a focus group that lasts longer than an hour is probably going to be tough. Also small businesses aren't trained moderators so it's best to not overextend yourself by trying to facilitate a discussion with people longer than it would naturally go particularly if you don't have any experience.
- Logistics – If you are doing it in a physical location, then it's best to have your participants sit around a table where they can see each other and have you at the head of the table. Also this allows you to be able to see everyone as well. Also, definitely provide some refreshments and snacks otherwise you may have some cranky folks. And if you happen to do it during mealtime, certainly provides some real food. If you are virtual then that of course isn't an issue.
- Feedback documentation - You'll probably be so engrossed in the conversation that you don't have any time to take notes. If you happen to have a partner in crime that could sit behind the table and taking notes for you that could be ideal. Other things you could do is tape record the session or even videotape it. You'll need to tell your participants up front that you are doing this up front.
In the end the benefits and strengths of having this type of dialogue with your customers are the following:
- The discussion from your audience will produce data and insights that would be less accessible without the interaction found in a group setting—listening to others' verbalized experiences stimulates memories, ideas, and experiences in participants.
- Group members discover a common language to describe similar experiences. This enables the capture of a form of "native language" or "vernacular speech" to understand the situation
- Focus groups also provide an opportunity for disclosure among similar others in a setting where participants are validated.
So the next time you have important questions you want to have answered from your customers and you want to go in depth to hear what they think, consider doing a focus group.
Image: Flickr via ihtatho (Creative Commons)
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Priceless Picnics
You should always make sure that you invest in your most important assets in life – yourself and your loved ones. Always take the time to ensure not just your health but your wellness and those of your loved ones, too. Working too hard without having any breaks and some relaxation will burn you much earlier, and will make you unproductive during your peak years. Stress is a recognized and acknowledged killer, and you don't want to be a victim of it. A lot of successful businessmen and woman and career men and women suddenly lose all the drive to work and to be competitive because of sheer stress. Which could have been easily remedied by some distressing activities. And these activities don't even have to be very expensive. Because distressing means doing the things that you enjoy, no matter how cheap or extravagant it is. One simple distressing activities is to have a simple picnic with your friends and loved ones. Simply pack a picnic basket with your favorite snacks and beverages, invite your favorite persons in the world to join and you're off to having a good day. If you want to be on the healthy side, then get some fruit gift baskets whose contents will be perfect to eat in a setting of nature and beauty. The spring rich rewards is a great fruit gift basket that will be good for you and your companions. These simple times will surely give you some priceless picnic memories that can fuel you for the next months to come.


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David Musil
1993-04-09 |
Eligible for draft:
2011 |
Left |
2011 |
6-3 |
2nd round (31st overall), 2011 |
200 lbs. |
Prospect Talent Score
Probability of Success
2008-09: David Musil spent most of the season with HC Dukla Jihlava's Under-20 team. In 34 games for that team, he scored 11 goals and added 23 assists for 34 points to go along with 54 penalty minutes. Musil also played in 14 games for that organization at a higher level, picking up 1 assist in those games. He registered no points in 4 playoff games at that level. Musil had been chosen in a special draft by the WHL's Kootenay Ice who then dealt his rights to the Vancouver Giants prior to the 2009-10 season.
2009-10: In his WHL rookie season, Musil played in 71 games for the Vancouver Giants. He scored 7 goals and added 25 assists for 32 points to go along with 67 penalty minutes. In 16 playoff games, Musil scored 2 goals and added 2 assists for 4 points. Musil was drafted in the first round, 12th overall, of the KHL Draft by SKA St. Petersburg.
2010-11: In 62 games for the Giants, Musil scored 6 goals and added 19 assists for 25 points to go along with 83 penalty minutes. In 4 playoff games, he registered 1 assist. Musil played for the Czech Republic at the 2011 U-18 World Junior Championship, registering no points in 5 games. He was named one of the top 3 players on his team for that tournament. Musil played for Team Orr at the 2011 CHL Home Hardware Top Prospects Game, picking up 1 assist in Orr's 7-1 win over Team Cherry.
2011-12: Musil attended training camp with the Oilers before returning to Vancouver to skate for the WHL's Giants for a third season. He also played for the Czech Republic in the 2012 U20 World Junior Championship. He scored 6 goals with 21 assist and finished plus-nine with 104 penalty minutes in 59 games; suffering a late-season wrist injury that required surgery and kept him out of the playoffs. The Czech Republic finished fifth at the WJC and Musil was plus-five with no points and 4 penalty minutes. He signed a three-year entry-level contract with Edmonton in July, 2012.
2012-13: Musil returned to Vancouver for his fourth WHL season and played 12 games with the Giants before a trade to the powerful Edmonton Oil Kings at the end of October. In 62 WHL games between the two teams he scored 9 goals with 22 assists and was +29 with 74 penalty minutes. Edmonton finished first in the Central Division and lost to Portland in the WHL Finals. Musil was +10 with 6 assists and 26 penalty minutes in 22 playoff games. He was an assistant captain for the Czech Republic at the 2013 World Junior Championship and was an even plus/minus with no points and 18 penalty minutes in six games.
Talent Analysis
Musil boasts good size and is a strong character-guy. Primarily considered a shutdown defender at this point, he has good puck skills and an offensive side that could evolve over the next few years, however it is unlikely he will be a big time scorer at the NHL level. He plays a smart, contained, physical brand of hockey, boasts NHL bloodlines (son of Frank Musil), and has a skill set that should translate incredibly well at the pro level. He has had some issues with injuries in junior, which is never good, however has thus far avoided anything too serious.
Musil will play his first pro season in 2013-14, likely in a third or fourth line depth role. He will need to ensure that his physicality and puck movement skills that he possessed in junior translate over to professional hockey to avoid the slump that plagues many as they adjust to the increased pace and skill of the game at that level.


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Paris Saint-Germain owner Nasser al Khelaifi has rubbished reports that the French club could make a move for Lionel Messi.
Speculation has increased in recent months that the Ligue 1 champions would be willing to match Barcelona's €250m asking price for the Argentine.
But the Parisiens owner has insisted that is not the case.
"I haven't spoken to Messi, because I'm not interested in signing him," he told reporters.
"I would never pay what they say he costs. I'm realistic, and that amount is not."
Think you know your Spanish football? Share your knowledge, tips and comments to win cash prizes in OLBG's tipster competition - £11,000 to be won monthly!


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For your convenience we have created an online version of our 600 page catalog. Although the site is online, we are actively working towards organizing it better so you can find the products you are looking for easier. Thank you for your patients over the next few days as we improve the navigation.
YOU ARE HERE: Indexes Wire Rope page142
The following is a fairly comprehensive listing of critical inspection factors. It is not, however, presented as a substitute for an experienced inspector. It is rather a user's guide to the accepted standards by which ropes must be judged.
Rope abrades when it moves through an abrasive me rum or over rums an sheaves. Most standards require that rope is to be removed if the outer wire wear exceeds 1/3 of the original outer wire diameter. This is not easy to determine and discovery relies upon the experience gained by the inspector in measuring wire diameters of discarded ropes.
All ropes will stretch when loads are initially applied.
As a rope degrades from wear, fatigue, etc. (excluding accidental damage) , continued application of a load of constant magnitude will produce incorrect varying amounts of rope stretch.
Phase 1. Initial stretch, during the early (beginning) period of rope service, caused by the rope adjustments to operating conditions (constructional stretch).
Phase 2. Following break-in, there is a long period—the greatest part of the rope's service life-during which a slight increase in stretch takes place over an extended time. This results from normal wear, fatigue, etc. On the plotted curve— stretch vs. time—this portion would almost be a horizontal straight line inclined slightly upward from its initial level.
Phase 3. Thereafter, the stretch occurs at a quicker rate. This means that the rope has reached the point of rapid degradation; a result of prolonged\subjection to abrasive wear, fatigue, etc. This second upturn of the curve is a warning indicating that the rope should soon be removed.
Any marked reduction in rope diameter indicates degradation. Such reduction may be attributed to:
In the past, whether or not a rope was allowed to remain in service depended to a great extent on the rope's diameter at the time of inspection. Currently this practice has undergone significant modification.
Previously, a decrease in the rope's diameter was compared with published standards of minimum diameters. The amount of change in diameter is, of course, useful in assessing a rope's condition. But, comparing this figure with a fixed set of values can be misleading. These long-accepted minimums are not, in themselves, of any serious significance since they do not take into account such factors as: 1) variations in compressibility between IWRC and Fiber Core; 2) differences in the amount of reduction in diameter from abrasive wear, or from core compression, or a combination of both; and 3) the actual original diameter of the rope rather than its nominal value
As a matter of fact, all ropes will show a significant reduction in diameter when a load is applied. Therefore, a rope manufactured close to its nominal size may, when it is subjected to loading, be reduced to a smaller diameter than that stipulated in the minimum diameter table. Yet under these circumstances, the rope would be declared unsafe although it may, in actuality, be safe.
As an example of the possible error at the other extreme, we can take the case of a rope manufactured near the upper limits of allowable size. If the diameter has reached a reduction to nominal or; slightly below that, the tables would show this rope to be safe. But it should, perhaps, be removed.
Today, evaluations of the rope diameter are first predicated on a comparison of the original diameter—when new and subjected to a known load—with the current reading under like circumstances. Periodically, throughout the life of the rope, the actual diameter should be recorded when the rope is under equivalent loading and in the same operating section. This procedure, if followed carefully, reveals a common rope characteristic: after an initial reduction, the diameter soon stabilizes. Later, there will be a continuous, albeit small, decrease in diameter throughout its life.


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Brain Fair 2014
An event for kids of all ages to learn how their brains work.
After a tremendous success last year, the Neuroscience Program at Florida State University is excited to announce the third annual Brain Fair. This year, the theme for the FSU Brain Fair is 'Your Brain is a Superhero!'. An exciting range of lectures, demonstrations, and hands-on activities are planned to illustrate how the brain helps us perceive the world around us!
The 2014 Brain Fair offers interactive demonstrations and hands-on activities that will open your eyes to the wonders of the brain. Additionally, leading scientists from the FSU Neuroscience Program will present some of their latest research.
The Brain Fair offers something interesting for all ages. Come learn how to make your own neuron, experience illusions and understand how your senses work, see real brains, and much more! We aim to provide information on our central nervous system and how the brain controls our sensory systems. Please join us for an afternoon of fun this spring!
- Day: April 19th
- Time: 12pm - 4pm
- Venue: FSU Department of Psychology Building, 1107 W. Call Street
- Cost: Free
- View Pictures from the 2014 Brain Fair
For more information about the Brain Fair, please contact Sean Ogden


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Want to make a quilt like this? Join the Paintbox Quilt-Along! See other people's Paintbox Quilts here.
I'm a woman on a mission this week. Last week, one of my students asked me how many quilts I have going at any given time and I was embarrassed to admit that I'd lost count of my WIP quilts. So, this week I'm trying to get as many as possible completed!
This quilt is approximately 62" x 72". I should have known this since, you know, I wrote the pattern, but I was still surprised by how big this finished quilt seemed!
The finished quilt includes 40 different Kona solids and 200 different prints. The sashing is Essex cotton/linen (White and, on the back, Putty).
When I was dividing up the fabrics for the blocks, I accidentally used one of the prints in two different sets of blocks, meaning the total number of prints before binding was actually 199. I added an extra print to the binding though, bringing the total to an even 200.
I made my scrappy binding from 28 different prints, each cut to 2.5" x 10.5". I sewed them end-to-end and made double-fold binding.
If you want to make binding for your Paintbox Quilt from a single fabric, you'll need 1/2 yard fabric (at least 42" wide), cut into 7 strips 2.5" x WOF.
I love the back of this quilt! I had debated putting words on it (like the original one) but I'm glad I didn't. I love all the negative space.
And, of course, you can't go wrong with a swatch block like this!
The 40 solids I used were: Black, Coal, Ash, Brown, Bright Pink, Berry, Copen, Mulberry, Jade Green, Caribbean, Lagoon, Pacific, Azure, Peacock, Pistachio, Candy Green, Lime, Grass Green, Clover, Kiwi, Chartreuse, Peridot, Olive, Cactus, Canary, Buttercup, Corn Yellow, Ochre, Tangerine, Orange, School Bus, Mango, Red, Rich Red, Coral, Tomato, Pomegranate, Candy Pink, Cerise, and Melon.
George-Michael has already adopted this quilt. I'm not sure I'm ever going to get to use it!


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Lung Cancer: Fact, Fiction & Prevention
Tuesday, April 23, 2013
Riverside Medical Center Specialty Services in Watseka
1490 E Walnut St. Suite A
Watseka, IL 60970
Presented by Dr. Ahsan Basha
Oncologist/Hematologist, Rush-Riverside Cancer Institute
More people die of lung cancer each year in the United States than any other type of cancer. Yet when it's detected early, there are more treatment options and higher survival rates. Learn the latest about your risks, prevention advice, advanced detection and treatment options.
Smoking cessation experts will be onsite to assist those interested.
Register online at www.RiversideMC.net/events or call Riversource at (866)268-6866 toll-free.


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Mary Clark, Traveler
Writing a travel column for the Paris News has brought together my life experiences and my life outlook. After 29 years of practicing law, I was ready for this change and it's been fun. I didn't want to manufacture the usual travel column with a few hotels, restaurants, and sites thrown in (although I'm told that's what most people want). What I wanted was to personalize cultures with stories. These encounters are not limited to foreign countries. The United States is richly diverse and reflective of the world and is a great source for the column. And, interestingly, I consider Paris, Texas itself a microcosm of the world and some stories will reflect that.
My essays are now being read on my new show and podcast, Mary Clark, Traveler, on 88.9 KETR, public radio for Northeast Texas.


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David B. Fein, United States Attorney for the District of Connecticut, announced that MICHAEL P. WEINSTEIN, 70, of West Hartford, waived his right to indictment and pleaded guilty today before United States Magistrate Judge Holly B. Fitzsimmons in Bridgeport to one count of filing a false federal income tax return.
According to court documents and statements made in court, WEINSTEIN lawfully engaged in gambling in Connecticut and elsewhere. In 2009, WEINSTEIN had approximate gambling winnings of $448,400 and gambling losses of $268,990, resulting in net winnings of approximately $179,410. In April 2010, WEINSTEIN signed and filed his 2009 U.S. Individual Income Tax Return, Form 1040, which under reported his income. Consequently, he failed to pay an additional $50,235 in federal taxes that were owed for 2009.
In 2010, WEINSTEIN had approximate gambling winnings of $475,800 and gambling losses of $475,800, resulting in net zero gambling winnings. On his 2010 tax return, WEINSTEIN failed to report his gambling winnings or losses, which affected the Alternative Minimum Tax on his return, and which resulted in his not paying $1,405 in federal taxes.
WEINSTEIN is scheduled to be sentenced by United States District Judge Janet C. Hall on December 26, 2012, at which time WEINSTEIN faces a maximum term of imprisonment of three years and a fine of up to $250,000.
As part of the resolution of this case, WEINSTEIN has paid restitution in the amount of $51,640 and has agreed to pay any penalties and interest for the 2009 and 2010 tax years. WEINSTEIN also has agreed to forfeit $143,562.46, which the IRS seized on November 22, 2011, from two of WEINSTEIN's bank accounts pursuant to a federal court-authorized seizure warrant.
WEINSTEIN is released on bond pending sentencing.
This matter was investigated by the Internal Revenue Service, Criminal Investigation Division with the assistance of the Stamford Police Department. The case is being prosecuted by Assistant United States Attorney Peter S. Jongbloed.
Tom Carson
(203) 821-3722


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At the Kids' Table: How the Kitchen Has Changed
RSVP required
How The Kitchen Has Changed
Saturday, January 12th 2-4 pm
What does eighteenth-century Tupperware look like? How about a nineteenth-century toaster? In this program, you'll go on a family scavenger hunt in the New-York Historical Society to uncover the kitchens of the past. Then we'll cook together, making cinnamon toast from SCRATCH—everything from grinding the sugar to making butter by hand! You'll find out how much the kitchen has changed from 1813...to 1913...to 2013!
Cornelia van Varick (1692-1733)
Cornelia van Varick was a Dutch girl who lived in Flatbush, Brooklyn, around 1700. A great deal is known about her household and family because when her widowed mother died, executors compiled an estate inventory that still survives.
Business and Industry Collections
Dutch New York Between East and West: The World of Margrieta van Varick (Bard Graduate Center)


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quote:Just imagining the fear Breesus can strike into a defender when he surveys the field and starts audibling.
quote:cornerback Michael Huff understands things will have to be tightened up considerably.
quote:"It can't happen this week," Huff said. "He's one of the smartest, one of the greatest quarterbacks out there. Pre-snap, he kind of knows already what you're in,
quote:They could drop some exlax in his cheesy Mac?
quote:If I started listing his strengths, reading defenses at the line and how quickly he can go through progressions (because of how clearly he understands the defense) might be the top of the list.
quote:Beefy mac, whodatfan. Good thing you're on our side. You'd be terrible at sabotaging Brees.
quote: Image: http://guycodeblog.mtv.com/wp-content/uploads/2012/01/drew_brees.gif


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I know what you're thinking.
Does the world really need one more book on Search Engine Optimization? Another list of to-dos you don't understand and don't have the time to do even if you did understand? Another blogger-turned-author masquerading around as an "SEO Guru" spewing off more self- aggrandizing nonsense about the complexities of search engine optimization in an effort to make themselves feel more important than they are while making you feel more overwhelmed than you should?
Absolu…wait, did you just say no?
Good. Because this book is different. Different from all of those other SEO books you have tried to muscle through over the years. Different from the advice that you have been given and the promises that you have been made that always ends up being too good to be true. Different from the latest flavor-of-the-month link building technique that will have stopped working by the time you finish reading this sentence.
What you are about to download is a new way to look at an old problem. A problem you know intimately well as "no one is visiting my website." The same problem that has cost you and your business more time and money than you care to admit to and has left you frustrated and in some cases void of all faith in humankind.
But it is a problem that can be solved. And you can be the one who solves it. Without a smarty-pants Ph.D. in computer science. And without a Geek- to-English dictionary. Yes. You can do this. And you can do this with the knowledge you already have within you. You don't need to know what Meta tags are. You don't need to be able to calculate your keyword density. And you don't need to understand the complexities of link building.
None of that matters.
So if you are ready, throw away everything you think you know about search engine optimization, enter your e-mail address in the form below and I will send you a FREE copy of "Search Engine Humanization: The Art of Turning Ordinary Words Into Extraordinary Clients" RIGHT NOW!
If you have been looking for a better mousetrap, you just found it.


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Answered by
the Fatwa Department Research Committee - chaired by Sheikh `Abd al-Wahhâb al-Turayrî
Scholars disagree over this issue. The opinion of most scholars is that it was legislated in the second year after the emigration to Madinah (in other words, 2 AH). Other scholars have placed the date even later, while still other scholars, among them Ibn Khuzaymah, have said that it was legislated before the Prophet (peace be upon him) departed from Mecca.
It can safely be said that the obligation to give charity was imposed in Mecca, in at least a very general sense. Evidence that charitable spending was already obligatory upon the Muslims while they were still in Mecca can be taken from the verse: "And woe to those who join gods with Allah, those who do not pay Zakâh and who even deny the Hereafter." [Sûrah Fussilat: 6-7]
This verse was revealed in Mecca, and is evidence that Zakâh was already something obligatory and not merely preferable. Therefore, the obligation of paying "Zakâh" was already in place during the Meccan period. However, there is no evidence that there was a fixed rate for it or that its rulings had been set forth in any detail. Therefore, it was probably simply an obligation for charitable spending in a very general sense.
Later on, in Madinah, the various legislations regarding Zakâh were revealed. These include the types of wealth which are subject to Zakâh, the percentage that must be levied on each types of wealth, when and how often Zakâh is due, and those who are entitled to receive it.
Before that, Muslims were simply asked to help the needy, feed the poor, ransom prisoners of war, and assist anyone in trouble.
The general duty of charitable spending existed in Meccan society even before the advent of Islam. Therefore, when Islam commanded Zakâh in Mecca, there would already have been a general understanding in place of what this entails, allowing the early Muslim community to put the general principle of Zakâh into practice long before the detailed rulings were revealed.
For example, it is mentioned in Sahîh al-Bukhârî (4) and Sahîh Muslim (160), that Khadijâh, the wife of the Prophet (peace be upon him), reassured him when he received his first revelation: "By Allah, He will never let you down, for you uphold ties of kinship , help people in difficulty, give to the needy, honor the guest, and give assistance in calamities."
And Allah knows best.
Source: Islam Today


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King Louie - I Love Money Feat. Lil Durk
I Love Money King Louie Feat. Lil Durk
King Louie and Lil Durk are joining forces for "Project X." This is the first single off the project, which has some autotuned ish going on.
Give I Love Money a listen - it's a new offering from King Louie, featuring Lil Durk. It was dropped on Thursday, November 8th, 2012. King Louie's musical situation is improving with every new release, and I Love Money will most definitely help the cause. It's a fine addition to the growing body of work King Louie has been developing since stepping foot in the game. We're looking forward to what King Louie has in store.
Hear more of King Louie on Flexin'. If you're down, make sure to visit King Louie's profile page for the newest info, news, songs, and mixtapes. Make sure to hit King Louie with a follow and/or like on Facebook and Twitter.
Who else would you like to have seen on the track? Can you appreciate the bars here?


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El Centro, Buenos Aires
Buenos Aires
Concierge.com's insider take:
Buenos Aires and its suburbs form one of the world's largest metropolitan regions and its throbbing heart—all commercial bustle and sensory overload—is the Centro. The area hinges on the Plaza de Mayo, home of the Casa Rosada, and it includes the teeming pedestrian mall of Calle Florida, the theater row along Avenida Corrientes (the Broadway of B.A.), the nearly 500-foot-wide Avenida 9 de Julio, the soaring (if somewhat pointless) Obelisco, and the magnificent Teatro Colón, one of the world's great opera houses. For a respite, duck into Café Tortoni on the rambla-like Avenida de Mayo for a quick cortado (espresso cut with milk).


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School votes for communism-themed dance dubbed 'prom-munism' ALBUQUERQUE, N.M. (AP) — Seniors at a New Mexico high school have voted to hold a prom with a communism theme, which they've dubbed "prom-munism. Full Story |
(Charles Dharapak/AP) Documentary filmmaker Albert Maysles dies at 88 NEW YORK (AP) — Albert Maysles, the acclaimed documentary filmmaker who helped pioneer feature-length nonfiction movies that used lightweight, hand-held cameras to spontaneously record the lives of both the famous and the unexamined, has died. Full Story |
(AP Photo/Damian Dovarganes) Harrison Ford undergoes surgery after plane crash The "Star Wars" actor broke his arm and pelvis Thursday when he crash-landed his small plane on a golf course near the Santa Monica Airport. |