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CHATTANOOGA, Tenn.-- The University of Tennessee at Chattanooga Mocs (11-17, 5-8 SoCon) gnabbed a tough win over the UNC Greensboro Spartans (13-12, 7-6 SoCon) Friday night at Maclellan Gym.
Before the match, senior outside hitter Heather Parman (Ooltewah, Tenn.) and her family was recognized as the contest was played in memory of her father, the late Eddie Parman, who passed away in the spring. Afterwards, Parman received attention for her performance on the court.
The senior recorded a season-best 15 kills and a .220 hitting percentage en route to a Chattanooga win. Freshman Briana Reid (Houston, Texas) put up her fourth double-double of the season with a match-high 17 kills and personal-best 26 digs. Fellow freshmen Lauren Gainer (Boca Raton, Fla.), Sarah Batterton (Colbert, Wash.) and senior Christina Teter (Signal Mountain, Tenn.) each downed double-digit kills, 11, 13 and 12, respectively.
Senior Paula Passmore (Merritt Island, Fla.) was the Mocs defensive leader with 29 digs, while Reid followed with 26 and Melissa Green (Boca Raton, Fla.) had 23. Junior Bridget Camacho (Cumming, Ga.) also recorded a double-double with 12 digs and a career-high 60 assists.
Greensboro took the first two sets by very small margins of two and three points. The Spartans jumped out to a 1-0 lead in the first set with a 25-23 victory and took the second frame with a 25-22 win going into the intermission. UNCG enjoyed hitting a match-best .341 in the first frame and a decent .227 in the second. The Greensboro defense kept the Mocs off-balance in the second stanza, forcing Chattanooga to hit a team-worst .074.
The Mocs surged back in the third set with a 25-22 set win, cutting the Spartans lead to 2-1. The Mocs gave up the lead just once in the third game, 11-10, but rode the rails to a three-point win to seal a victory. Back-to-back Gainer serves warranted a UNCG attacking error and a Batterton kill.
Chattanooga claimed the fourth game by the widest margin of the night with a 25-19 victory. The six-point win tied the match at 2-sets-apiece going into the deciding set. The Mocs took the first lead in the final set and never gave it up. Despite a 5-2 run in the final minutes of the match, Reid downed a spike for match-point, giving the Mocs a 3-2 victory.
"I think that moment can be a signature moment for Chattanooga volleyball," Head Coach Travis Filar said. "We were recognizing Eddie Parman and Dr. Carolyn Thompson tonight and we fought hard tonight. We didn't get down, we found a rhythm in the third set and we began to put pressure on UNCG. This is my proudest coaching moment."
The Mocs are back in action tomorrow night as Chattanooga hosts Elon on senior night at Maclellan Gym. The match is set to start at 6 p.m. with seniors recognized beforehand. Admission is free and post-match autographs will be offered at the scorers' table immediately following the match.

subset: commoncrawl


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Recently Completed Studies
The following studies have recently been completed by researchers at the Center for the Treatment and Study of Anxiety.
This project is a joint effort between The Center for the Treatment and Study of Anxiety (CTSA) at the University of Pennsylvania and Women Organized Against Rape (WOAR). It to examine the effectiveness of a treatment developed for post-traumatic stress disorder (PTSD) in female adolescents exposed to child sexual abuse (CSA) and sexual assault. Adolescents who choose to participate in the study will be randomized to one of two types of therapy, Prolonged Exposure (PE) or Client-Centered Therapy (CCT). Both types of therapy are once weekly, individual counseling sessions that last for approximately 1 1/2 hours each. PE focuses more on processing the teen's trauma, whereas CCT focuses more on problem solving and current life stressors. CCT has been shown to be extremely effective for treating PTSD symptoms in adolescents, and two pilot projects utilizing PE for adolescents also show excellent results. Treatment will include up to three preparation sessions and 14 sessions of active treatment. A CTSA clinician will conduct evaluations at mid and post-treatment. In addition, there will be follow up evaluations 3, 6, and 12 months after treatment has ended. Information from this study will directly benefit clients by guiding appropriate treatment planning. Clients in the treatment study will benefit from receiving a comprehensive evaluation by study staff and well-delivered treatment for PTSD.
OCD Augmentation Study
This study, funded by the National Institute of Mental Health, is a collaboration between Dr. Edna Foa from the University of Pennsylvania and Dr. Blair Simpson from Columbia University-New York State Psychiatric Institute. The purpose of the study is to compare two different, but effective augmentation treatments in order to examine how to maximally improve symptoms of OCD for those who are already taking SSRIs but still have OCD symptoms. Those who participate in the study will continue to take their SSRI and will be randomly assigned to receive one of three different add-on conditions: Cognitive Behavioral Therapy (CBT), Risperdal (RIS), or placebo (PBO). Initial treatment will last for 8.5 weeks. Individuals who benefit from the add-on treatment will be invited to continue with the same treatment for 6 additional months. Individuals who do not benefit from the initial add on treatment (CBT, RIS, or PBO) will be offered 8.5 weeks of treatment with one of the alternative active treatments (RIS or CBT). The add-on treatments will be provided at no cost. Men and women ages 18-70 with OCD who are currently taking SSRI medication are eligible to participate in this study.
Naltrexone and CBT in the Treatment of Alcoholism and PTSD
This study is its sixth year of funding from the National Institute of Alcoholism and Alcohol Abuse. The PI's of the study are Edna B. Foa, PhD and Joseph Volpocelli, MD, PhD and the study coordinator is David Yusko, PsyD. PTSD and alcoholism are frequently found to co-occur in persons exposed to traumatic events. This study examines the utility of established treatments for each disorder when used to treat persons who have both PTSD and alcohol problems. Naltrexone has been found effective in combination with psychosocial interventions at reducing alcohol problems; prolonged exposure has been found effective in the treatment of PTSD. Men and women who experience both PTSD and alcohol problems are eligible to participate in this study.
Effectiveness of Treatment for PTSD in Community Agencies
This 5-year study, a continuation of our 16-year program of research on treatment of PTSD resulting from rape and nonsexual assault, was awarded funding in October, 2001. Elizabeth A. Hembree, PhD, is the PI on this project with Edna B. Foa as Co-PI and Paul Ctrits-Christoph, PhD, as Co-I. This investigation aims to establish the external validity of treatments for PTSD by proposing two studies to evaluate the effectiveness of an empirically validated treatment for posttraumatic stress disorder (PTSD), Prolonged Exposure (PE) a brief cognitive behavioral therapy, in each of two community-based agencies. We recently completed a study in which we demonstrated that PE can be successfully implemented by counselors of a community-based agency dedicated to providing services for sexual assault victims, Women Organized Against Rape (WOAR). The present study aims to examine whether counselors at WOAR can maintain their success with PE with reduced CTSA expert involvement. In addition, we will replicate the training procedures utilized at WOAR with counselors at Joseph J. Peters Institute (JJPI), another community based agency that provides services for sexual assault victims to examine the generalizability of our training procedures.
Biological and Psychological Correlates of PTSD (Primary Grant)
This study, funded by the National Institute of Mental Health, is a collaboration between Dr. Foa from the University of Pennsylvania and Rachel Yehuda, PhD, of the Mt. Sinai School of Medicine, New York City. Dr. Cahill is a co-investigator on this grant and serves as the study coordinator for the University of Pennsylvania site. The University of Pennsylvania site is expert in the psychological treatment of PTSD and Dr. Yehuda is an expert in the biological correlates of PTSD (e.g., changes in circulating levels of cortisol and catecholamines, changes in negative feedback inhibition of cortisol release). The goal of this study is to evaluate changes in salivary and urinary cortisol and catecholamines before, during, and after treatment with treatment for chronic (at least one-year post-trauma) PTSD. We intend to determine whether these biological variables associated with PTSD represent "trait-like" variables that do not change with symptom resolution, and therefore may reflect a biological vulnerability to developing PTSD. Alternatively, these biological variables may reflect "state" variables that change with symptom resolution. Women with symptoms of PTSD lasting at least one year are eligible to participate in this study.
Cognitive Behavior Therapy Augmentation of Serotonin Reuptake Inhibitors (SRI) for OCD
Recruitment for this NIMH-funded study recently ended. The study was designed to examine the potential benefits of augmenting SRI treatment for obsessive-compulsive disorder with cognitive behavior therapy (CBT). The study was conducted at the University of Pennsylvania (PI: Edna Foa, PhD) and at the New York State Psychiatric Institute (PI: Michael Liebowitz, MD). Although SRI treatment leads to some improvement in symptoms among patients with OCD, many are left with residual symptoms that are still in need of help. Therefore, this study examined the immediate and long-term value of adding CBT to continuing SRI treatment for reducing these residual symptoms and increasing general functioning and quality of life. The data are currently being processed and analyzed for this study.
Sertraline and Prolonged Exposure in the Treatment of PTSD
This was a three-center study that included the University of Pennsylvania (Edna B. Foa, PhD, PI), Duke University (Jonathan Davidson, MD, PI), and Emory University (Barbara Rothbaum, PhD, PI) and was funded by Pfizer, Inc. The study coordinator for the University of Pennsylvania site was Shawn P. Cahill, PhD. The goal of this study was to determine whether adding prolonged exposure to medication improved treatment outcome. Further information on this project is available from Dr. Shawn Cahill at the Center for the Treatment and Study of Anxiety.
A Brief Program for Preventing PTSD
This study, funded by NIMH, examined the efficacy of a brief cognitive-behavioral intervention program designed to prevent the development of chronic PTSD among recent female sexual assault victims. The brief prevention program was compared with supportive counseling and assessment only control groups. The PI of this project was Edna B. Foa, PhD, and the study coordinator was Elizabeth A. Hembree, PhD. Further information about this study is available from Dr. Elizabeth Hembree who served as project coordinator. The main results of this study is currently "in press" at the Journal of Traumatic Stress (Foa,).
Treatment of Chronic PTSD
This NIMH funded research project examined the ability for clinicians from the Center for the Treatment and Study of Anxiety to train clinicians from other agencies to effectively use prolonged exposure to treat chronic PTSD among women assault survivors. This study was a collaboration between CTSA faculty and the community organization Women Organized Against Rape (WOAR) with treatment administered at both sites. The goal of the cross-site comparison was to determine whether prolonged exposure, which has been used successfully in academic settings such as the CTSA, can be effectively disseminated to non-academic settings. Dr. Edna B. Foa was the PI for this project and Dr. Elizabeth Hembree was the study coordinator. The main results of this study were recently published in the Journal of Consulting and Clinical Psychology (Foa, Hembree, Cahill, Rauch, Riggs, Feeny, & Yadin, 2005).
A Randomized Clinical Trial of CBT for PTSD in Women
This 4-year Cooperative Studies Program, funded by the Department of Veterans Affairs, evaluated the efficacy of cognitive-behavioral therapy (CBT) in treating PTSD and associated problems in female veterans and active duty military personnel. The study compared a cognitive behavioral therapy developed and extensively studies in the CTSA, Prolonged Exposure (PE), with a therapy that focuses on current problems, Present-Centered Therapy (PCT). Edna B. Foa, PhD, was the "master therapist" for prolonged exposure (PE) and was responsible for the training and supervision of all therapists conducting PE in this study. Elizabeth A. Hembree, PhD, was the coordinator of the study. The role of CTSA faculty in this study was to train and continuously supervise the 24 therapists who worked in the 12 VA and DoD clinics that were study sites. The data are currently being processed and analyzed for this study.
Treatment of Generalized Social Phobia
We recently completed this NIMH-funded multi-center study evaluating the immediate and long-term efficacy of group comprehensive cognitive-behavioral therapy (CCBT), fluoxetine (FLU), and their combination for adults with social phobia. The study was conducted at the University of Pennsylvania (Edna B. Foa, PhD, PI) and at Duke University (Jonathan Davidson, MD, PI). Additional information about this study is available from Dr. Jonathan Huppert, the study coordinator at the Center for the Treatment and Study of Anxiety.
CBT for Pediatric Trichotillomania (compulsive hair pulling)
The goal of this study, funded by NIMH, is to develop and test a CBT treatment program for children who compulsively pull their hair. Dr. Martin Franklin is the PI on this project. Participants received CBT aimed at habit reversal and stress management. Children and adolescents aged 7 to 17 inclusive who compulsively pulled their hair were eligible to participate in this study. Further information can be obtained from Dr. Martin Franklin at the Center for the Treatment and Study of Anxiety.


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Michael John Shanlian graduated with a Ph.D. from Tennessee Temple University Chattanooga, TN in organizational leadership on Saturday, May 4, with a G.P.A. of 3.8. Shanlian, who turned sixty years old on May 3, is resident gemologist and jewelry appraiser at Floyd & Green Jewelers, and an ordained minister. The title of his dissertation was Transformational Leadership in Church Revitalization: A Study of Heights Church in Aiken, South Carolina.
Shanlian earns his Ph.D from Tennessee Temple
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I have two users A and B. I want to grant B the permission to create, drop, etc. all tables in A's schema. As far as I can see, I can grant B full access to all schemas not a specific one. Is this correct?
You are correct that there is no way to grant a user create/drop/etc permissions on an entire schema. I suggest you look into proxy authentication. This basically involves altering user A to allow user B to proxy as A:
Then the connection uses user B's authentication, but gets the permissions of user A.
This question was somewhat covered by my more specific question here.
Note on Roles: Roles work well for giving Object Privileges to another user since the privileges are tied to a specific object. While Roles can grant System Privileges, they apply either to the users own schema or to the entire database and therefore can't apply to another schema. For example, the user B could be granted
You could just create a role with those permissions, and grant the role to whoever needs that ability.


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Israel News - Stay Informed, Pray Informed
The world turned its back on the Jews of Europe during the Nazi Holocaust. Many of those who miraculously survived became a part of a reborn Jewish state. But the ghosts of their horrific past linger, and far too many are living out their last days in poverty and loneliness.
Israel Today is proud to be among those providing physical aid, as well as emotional and spiritual comfort, to Israel's Holocaust survivors.
But, we need your help!
How special it is to inform these precious souls that it is thanks to the kind donations of Christians that we are able to provide aid and comfort, when so many of them have been left scarred by their treatment at the hands of supposedly "Christian" nations.
We'll supply a Holocaust survivor with several gift coupons that can be cashed in a number of Israeli supermarkets.
Last week the Israeli Parliament, the Knesset, approved an NIS 50 million increase in annual assistance (US$ 13.7 million) for Holocaust survivors living in Israel.
Prime Minister Binyamin Netanyahu recently committed to improving the welfare of Holocaust survivors living in Israel. This commitment has come about as a direct result of the efforts of Dora Roth, herself a Holocaust survivor, who made an impassioned speech in the Knesset during April, concerning the welfare of survivors.
The dire living situation of thousands of Holocaust survivors is a hot political topic in Israel. According to the coalition deal signed by Yesh Atid, a commitment has been made to increase the budget for Holocaust Survivor's services.


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You may return or exchange your jewelry within 60 days of purchase if you are not satisfied with it. The jewelry must be returned in its original condition for a refund or exchange. Engraved, personalized, photo, monogram, name and initial, chocolate and clearance items are not returnable or exchangeable.


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During the period of this S corporation tax update (July 10, 2011–July 9, 2012), some major changes that directly affect S corporations took place, which will be discussed here. This article then presents some tax planning ideas for S corporations and their shareholders.
A corporation must meet several requirements to qualify as an S corporation. Some of those requirements include the type of corporation that will qualify; the number of shareholders the corporation can have; the type of entity that can be an eligible shareholder; the type of stock the corporation can issue; and the type of income it can generate. In addition, there are several types of elections that the corporation or its shareholders must make to qualify as an S corporation, including an election to be treated as an S corporation; an election to treat a subsidiary as a qualified S corporation subsidiary; and elections by trusts to be treated as eligible shareholders. If any of the requirements are not met at any time, the corporation's S election will be inadvertently terminated. However, the taxpayer can request an inadvertent termination relief ruling under Sec. 1362(f) and, subject to IRS approval, retain its S status continuously. Congress requested that the IRS be lenient in granting inadvertent election and termination relief, and it is clear from the rulings presented here and in past years that the IRS has abided by congressional intent.
In all of the rulings this year, if the taxpayer could establish reasonable cause for not making a timely election and show that granting the relief would not prejudice government interests, the taxpayer was granted inadvertent termination relief as long as a proper election was filed within 120 days of the ruling. These rulings applied to the failure to file Form 2553, Election by a Small Business Corporation,1 Form 8832, Entity Classification Election,2 and Form 8869, Qualified Subchapter S Subsidiary Election (QSub),3 as well as the elections required by the beneficiary of a qualified subchapter S trust (QSST)4 and the trustee of an electing small business trust (ESBT)5 to be an eligible S corporation shareholder. The IRS also granted inadvertent termination relief when the wrong person (in these cases, the trustee and not the beneficiary) signed the election in Letter Rulings 201151004 and 201144018.6
A more complicated situation occurs when S corporation stock is held by a trust and the beneficiary dies. The trust can continue to hold the S corporation stock for two years. After that time, the trust must distribute the stock to individual shareholders or to a new trust that will qualify as either a QSST or an ESBT. Many times the stock is transferred correctly to a QSST or an ESBT, but the appropriate person forgets to make the required election and causes a termination. In those cases, the IRS granted relief from inadvertent terminations this year.7
Sec. 1361(b) restricts ownership in an S corporation to U.S. citizens, resident individuals, estates, certain trusts, certain pension plans (but not IRAs), and certain tax-exempt charitable organizations. In Taproot Administrative Services,8 the Ninth Circuit reaffirmed that a Roth IRA is not an eligible S corporation shareholder.
Historically, S corporations have been more successful with the IRS if they request inadvertent termination relief before they are audited and the issue is decided in the courts. This year, the IRS issued inadvertent termination relief to S corporations that had shareholders who were corporations,9 a limited liability company,10 a partnership,11 another S corporation,12 a nonresident alien,13 and nonqualifying trusts.14 In each case, the S corporation rectified the problem upon discovery and agreed to make any adjustments required by the IRS. The IRS allowed the S corporation to retain its status in these situations, but it otherwise did not rule on the tax consequences of the transactions.
Sec. 1361(b)(1)(D) prohibits an S corporation from having more than one class of stock, defined as equal rights to distributions and liquidations (but not voting rights). Santa Clara Valley Housing Group15 involved an S corporation owned by the Schott family using a technique, SC2, marketed by an accounting firm. The technique allowed the Schotts to convert ordinary income of the S corporation into distributions taxable as capital gains through a multistep plan involving the issuance of stock warrants. The key issue was whether the warrants were a second class of stock and therefore would invalidate the S status of the corporation and cause the distributions to be subject to tax as ordinary income under Sec. 301. The district court in California originally decided that the stock warrants were a second class of stock, but it is currently reexamining the terms of the stock warrants under the safe-harbor rules of Regs. Sec. 1.1361-1(l)(4).16 Two letter rulings17 issued this year allowed the S corporation inadvertent termination relief when warrants were issued.
Letter Ruling 20121800418 presents a fairly typical redemption agreement based on fair market or book value purchase price that is allowed without causing a violation of the one-class-of-stock requirement. On the other hand, Letter Ruling 20121603419 deals with a fairly complicated trust agreement where the primary beneficiary is the trustee and has discretion to distribute, substitute trust property, etc. The ruling holds that since the beneficiary is a qualified shareholder, the trust is an eligible shareholder.
Letter Rulings 201220024 and 20115003020 involved S corporations that made non–pro rata distributions to their shareholders. When the corporations realized that this violated the one-class-of-stock requirement, they immediately rectified the situation. The government held that the termination event was inadvertent and allowed the S status to continue unbroken.
In an interesting Chapter 7 bankruptcy case, In re Kenrob Information Technology Solutions,21 the shareholders had an agreement with the S corporation that a distribution would be made each year equal to the tax owed at the individual level at the hypothetical C corporation tax rate. In two years at issue, the corporation paid these taxes directly to the IRS on the shareholders' behalf. The court held that these payments were not fraudulent transfers. The contract only looked at the federal tax rate. If the state tax impact had been included and they lived in different states, then a second class of stock would have been in evidence.
If an S corporation has subchapter C accumulated earnings and profits (AEP), it will be subject to a tax under Sec. 1375 on its excess net passive investment income if its total passive investment income exceeds 25% of its gross receipts. In addition, if an S corporation's total passive investment income exceeds 25% of its gross receipts for three years, its S election automatically terminates the first day of the fourth year.
A ruling with multiple sins being forgiven, Letter Ruling 20122100822 involves three consecutive years of AEP with too much passive investment income, along with disproportionate distributions causing a second class of stock. The government permitted a retroactive deemed-distribution election to allow the S corporation not to be considered terminated. Likewise in Letter Rulings 201226013 and 201222003,23 an S corporation with AEP and excess passive investment income for three years was allowed to retain its S status as long as the company made a deemed distribution of its AEP.
An important statutory change that affects S corporation administration is the enactment of Sec. 6045B, which requires any change in the capital structure of a corporation (including S corporations) to be reported within 45 days to the IRS and the shareholder.24 What needs to be disclosed regarding a specified security (stock or debt) is a description of any organizational action that affects the basis of the specified security of the issuer; the quantitative effect on the specified security's basis resulting from the organizational action; and any other information the IRS may prescribe.
Corporate spinoffs and reorganizations would clearly be covered. What is unclear is what other actions that affect shareholder basis through the interaction of corporate and individual tax rules in the context of an S corporation would be included. For example, a distribution out of AEP would presumably not be a covered transaction. But what if the S corporation distributes cash out of the corporate accumulated adjustments account, which clearly affects shareholder basis under Sec. 1368?
Also, the IRS has recently issued a new Form W-9, Request for Taxpayer Identification Number and Certification, to better identify S corporation classification vis-à-vis a C corporation. This was done because, beginning in 2012, under the Sec. 6045 disclosure rules, if a covered security is acquired by an S corporation, adjusted basis reporting is required.
The Mortgage Forgiveness Debt Relief Act of 200725 enacted Sec. 6699, which originally imposed a penalty of $85 per shareholder per month (not to exceed 12 months) if the S corporation did not timely file its corporate return or it failed to provide information required on the return. The law applies to S corporation returns required to be filed after Dec. 20, 2007, and the penalty is imposed on the S corporation. The penalty is currently $195 per shareholder, which includes any person who was a shareholder during any part of the tax year, and applies to returns filed late or returns that fail to contain the information required to be disclosed under Sec. 6037. To calculate the penalty, shareholder husband and wife count as two shareholders.
Example 1: H and W and their two children own all the stock of XYZ Corp. In October 2011, the children gift some stock to their spouses. In 2012, the S corporation is late in filing its Form 1120S, U.S. Income Tax Return for an S Corporation, or forgets to include the distribution amount on the Schedules K and K-1 on the return. The S corporation could be liable for a penalty of $14,040 ($195 × 6 × 12) for this innocent mistake.
What is particularly disturbing about this provision is that, rarely, if ever, is the date of distributions included on Schedules K and K-1. Yet Secs. 6037(a) and (b) require the S corporation to report this information to the IRS and the shareholders. This provision is a trap for the unwary since anything left off the Schedule K-1—intentionally or not—could potentially trigger the penalty.
Ensync Technologies26 is not about a "boy band" but involves a high-tech S corporation whose major shareholder did not file a timely S corporation return under Sec. 6037, and the IRS imposed $6,408 of penalties under Sec. 6699. The taxpayer argued that he had included the Schedule K-1 items on his tax return and the nonfiling was inadvertent. The court allowed him a "reasonable cause" basis for waiving the penalties.
Dickerson27 involves a scenario similar to the 1994 Nicolas Cage movie, It Could Happen to You. An Alabama Waffle House waitress received a tip in the form of a lottery ticket and won $5 million. She tried to transfer the ticket to a newly formed S corporation that she owned 49% of (the remaining 51% was owned by other family members) to avoid gift tax. The court held that she was subject to a gift tax on the 51% she gave away.
Penland28 is a case in which the sole shareholder disavowed her ownership of an S corporation that included a miniature horse farm and used car dealership. The government found that she was nonetheless liable for the income generated by the S corporation.
In Garavaglia,29 the IRS argued that taxpayers' two corporations for which they had made invalid S elections should nonetheless be treated as S corporations because the taxpayers intended them to be S corporations. The Tax Court rejected this argument, saying that compliance with the procedural rules, not intent, governed whether a corporation was an S corporation. The taxpayers claimed that distributions from the corporations were nontaxable loan repayments, but the Tax Court held that they were income distributions.
Rogers30 involved a situation in which a tax attorney tried to use multiple S corporations and single-member LLCs to evade taxes and failed.
D'Errico31 involved several S corporations in which the owner had taken loans from the companies. The court held that he showed no intent to repay the loans and treated them instead as distributions, which reduced his basis in the stock. The IRS successfully asserted that personal expenses paid by the corporation (such as renting his father's home as a bogus office and the costs of an airplane not used in the business) were disguised dividends, and that the taxpayer understated his capital gain income upon the sale or liquidation of the corporations.
T.D. 9522, which applies to tax years beginning on or after April 11, 2011, distinguishes a controlled group under Sec. 1563 from the affiliated group rules of Sec. 1561. There was concern that the new rules would limit some S corporations' Sec. 179 deduction. Many practitioners believed that because S corporations were defined as "excluded corporations," two controlled S corporations could each take a maximum Sec. 179 deduction and pass them through to their shareholders. Informal discussions with the IRS National Office reveal that the new regulations were not meant to limit the Sec. 179 deduction and that each S corporation will in fact be entitled to its own $500,000/$2 million limitation.
Tax advisers should be aware of a National Research Program being implemented for 2010–2012 (involving 2,000 returns per year) on employment status (employee vs. independent contractor), reasonable compensation, S corporation distributions vs. salary, and matching taxpayer identification numbers. Fifteen hundred of the 2,000 returns per year will be from the Small Business/Self-Employed division. The program began in February 2010.
The David E. Watson case32 represents exactly what the IRS is trying to ferret out with this program. An experienced accountant worked 35 to 40 hours per week, 46 weeks a year, but took a salary of only $24,000. In addition, he distributed more than $200,000 in cash to himself. This taxpayer's behavior echoes a long line of cases going back to Radtke,33 Spicer Accounting,34 Joseph M. Grey Public Accountant,35 etc., in all of which S corporation owners failed in their attempt to avoid Social Security taxes by undercompensating themselves and instead taking money out as distributions. The court reclassified $67,000 of Watson's distributions as salary. It should not be a surprise to learn that the wage limit subject to Social Security tax for the relevant year was approximately $91,000. The Eighth Circuit36 affirmed the district court decision.
In a case where the taxpayer had a similar goal, Cave,37 a sole shareholder attorney treated himself and all his associates as independent contractors. The court held that all parties involved were "statutory" or "common law" employees and, therefore, the company should have withheld Social Security taxes. The taxpayer argued that Section 530 of the Revenue Act of 1978 should protect him, but it does not apply to statutory employees. This case was upheld by the Fifth Circuit.38
One of the confounding issues within the passthrough entity tax world is the application of the entity or the aggregate concept to a specific transaction. That is essentially the issue in Trugman,39 in which a wholly owned S corporation bought a home for the use of its shareholders. The shareholders tried to take a Sec. 36 first-time homebuyers' credit, but the court said that the S corporation is not an individual as the purchaser was required to be under Sec. 36, nor could the house be the corporation's principal place to live. The reader should note that the Sec. 121 $500,000 exclusion would likely not be available either. Presumably, the S corporation intended to use Sec. 119 (meals or lodging furnished for the convenience of the employer) to deduct normally personal items.
A major motivation for a corporation's choosing S status is the ability to flow entity-level losses to its shareholders. To be able to use this benefit, shareholders must keep careful track of their stock and debt basis. As a matter of fact, in discussions with IRS personnel, by far the hottest area for IRS review is adjusted basis. A shareholder must overcome several hurdles before losses are deductible, including Sec. 183 (hobby loss), Sec. 1366 (adjusted basis), Sec. 465 (at-risk), and Sec. 469 (passive activity loss) rules. Several court cases, a proposed regulation, and rulings were issued relative to these loss limitation rules.
Proposed Regs. Secs. 1.1366-2 and -5, which were promulgated on June 11, 2012,40 may be helpful, when finalized, to many taxpayers who use related entities to fund loss S corporation activities. Essentially, the regulations move away from the "economic outlay"/poorer-in-a-material-sense criterion of many court cases and instead use bona fide debt criteria. This may make it easier to use funds from related parties, back-to-back loans, and even, in some cases, the "incorporated pocketbook" concept. It may also allow "round tripper" lending where each leg of the transaction is bona fide.
For example, if an individual owns both a partnership interest and an S corporation interest, and the S corporation leases property from the partnership, the shareholder/partner may be able to borrow from the partnership (or take a distribution), lend to the S corporation on bona fide terms, and have the S corporation pay the rent. The crucial concept is: What is bona fide debt under general tax principles? The authors would argue, if the terms of the loan/note were similar to what an unrelated third party would lend at, then a bona fide debt would be present.
The proposed regulations also explicitly point out that guarantees and recourse debt arrangements will not give rise to Sec. 1366 basis for loss until they are actually paid. They also reiterate that Rev. Rul. 81-18741 still applies to limit the ability to increase basis by a shareholder's contributing his own unsecured demand note to the corporation.
Welch42 is an interesting adjusted basis in debt case in that the funds came directly from a nonowner, nonrelated party. There was no discussion of the motive of the third person in contributing $600,000 directly into a durable medical equipment, home health care business. There might have been a relationship with one of the owners of the company or a dodge around Medicare rules, but this was never explored in the case. Instead, the judges decided based on the evidence that the "economic outlay" doctrine was not met by the legal owners and therefore the losses were suspended. Even if the new proposed regulation standard of "bona fide" debt was used, this case would probably have still failed the test given the lack of contemporaneous records, no payments of principal or interest for several years, little collateral provided, and no attempts to collect past-due debt.
Maguire43 involved two shareholders (father and son) who owned both a profitable and a loss S corporation. At the end of each year, the profitable company owned substantial accounts receivable due from the loss company. At the end of each year, the taxpayers received distributions of the accounts receivable from the profitable company and then contributed them to the related loss company to increase their bases in the loss company stock enough to allow them to deduct its losses. The IRS disallowed the loss deductions. The court held that shareholders in two related S corporations were not prohibited from receiving distributions of assets from one of their S corporations and then contributing those assets into another S corporation to increase their basis in the latter. Here, the transactions did actually occur and petitioners were entitled to their claimed losses.
Barnes44 involved a restaurateur who owned an S corporation that had losses. In one year, the taxpayer had insufficient basis to deduct the loss under Sec. 1366(d), but in the next year had enough basis to take the loss, but did not. Several years later, he took the suspended losses. The court held that the loss was usable in the earlier year and, since he did not use it then, he lost it. This is similar to the allowed or allowable logic for depreciation and a trap for the unwary.
Broz45 is another case in which an S shareholder did not have sufficient basis for loss. The taxpayer owned several S corporations but did not properly set up a back-to-back loan strategy. Instead, he used the other corporation's stock as collateral on the loan, which did not give rise to an economic outlay. To make matters worse, the court held that the "at risk" rules of Sec. 465 had not been met either.
The Small Business Jobs Act of 201046 modified Sec. 1374(d)(7) so no built-in gains (BIG) tax is imposed on an S corporation's net unrecognized built-in gain if the fifth year in the recognition period precedes the 2011 tax year; but it is not currently applicable to 2012. Nonetheless, some tax planning or unanswered questions may still apply to fiscal-year S corporations:
For the carryover basis provisions, the law seems to look to 12-month periods. For tax years beginning in 2011, the congressional report on the BIG tax holiday law makes it explicit that five 12-month periods are required.47
Letter Ruling 20115002348 involved a converted C corporation that received a prepayment on installment sales notes to avoid the Sec. 1374 tax liability. It is hard to tell with the redaction of dates, but it appears the conversion may have created some short years that were counted for its recognition period.
Anschutz49 involves an S corporation that was subject to Sec. 1374. Rather than sell investments for cash, it tried to structure a variable prepaid future contract so that gain would not be recognized until after the 10-year recognition period lapsed. The Tenth Circuit upheld the lower court ruling that the transaction was a sale and Sec. 1374 would apply to the recognized gain.
The flexibility engendered by the QSub disregarded-entity rules generated some merger-and-acquisition activity involving S corporations. For example, Letter Rulings 201144002 and 20114400350 involved a C corporation that was owned by ineligible shareholders such as corporations and partnerships. The ineligible shareholders distributed their stock to its shareholders/partners in a taxable transaction per Secs. 311 and 301. It then formed a holding company to hold the stock of the active QSub subsidiary. The government held that this would be a qualified S corporation.
In Letter Ruling 201126023,51 a foreign corporation owned by two trusts wanted to domesticate under state corporate law. It also wanted to elect S status and have the two owners be treated as ESBTs. The IRS ruled that this would be treated like an F reorganization and would not be subject to any tax under Secs. 357 and 361. However, the reorganization presumably would be subject to Sec. 1374 potential tax liability.
One issue that may arise more frequently as S corporations and QSubs are used in more-sophisticated situations is the application of Sec. 6501(c)(8) to extend the S corporation's tax return's statute of limitation for the nonfiling of Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. In Chief Counsel Advice (CCA) 201206014,52 an S corporation had five controlled foreign corporation disregarded entities. It did not file Forms 5471 as required by Sec. 6038. The statute of limitation for both the S corporation and the Form 1040 of the two major shareholders was extended due to this lapse. There is also a $10,000 penalty for each Form 5471 not filed.
In Letter Ruling 201219003,53 two families owned an S corporation. To prevent family disputes from disrupting the corporate business, they dropped half the assets into a controlled corporation and did a split-off to one family. Interestingly, the IRS was somewhat concerned that they did not accumulate accounts receivable or hold back on satisfying payables so that there was no gamesmanship (assignment of income). Also, liabilities remained with the distribution corporation even though some property may have had a liability related to it. The IRS ruled under Secs. 368(a)(1)(D) and 355 that there was no gain to the distributing corporation or the receiving shareholders.
In Recovery Group,54 involving a crisis-management company, an internal crisis caused a 23% shareholder to have his stock redeemed. The shareholder also received a $400,000 one-year covenant not to compete. The company deducted the covenant not to compete amount when paid, arguing that amortization under Sec. 197(d)(1)(E) only applied to substantial stock acquisitions. However, the court sided with the government and ruled that the appropriate treatment was 15-year amortization under Sec. 197(d)(1)(E).
The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 201055 maintained the capital gain and dividend 15% tax rates for 2011 and 2012 and extended the alternative minimum tax patch for 2011. It also extended the suspension of the itemized deduction and personal exemption phaseout for 2011 and 2012. In addition, the act allows first-year bonus depreciation at 100% for assets acquired and placed in service on or after Sept. 9, 2010, and before Jan. 1, 2012 (before Jan. 1, 2013, for certain property). For assets placed in service in 2012, 50% first-year bonus depreciation applies.
The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 reduced the Social Security rate for employees and the self-employed by 2% for 2011, and the Middle Class Tax Relief and Job Creation Act of 201256 extended this reduction in the tax rate through 2012.
The Small Business Jobs Act of 2010 expanded the dollar amount of new or used tangible personal property that may be expensed in the year placed in service under Sec. 179 to $500,000 for 2011. The phaseout of this tax benefit starts at $2 million and would be fully phased out for property acquired in the tax year that exceeded $2.5 million. For 2012, the maximum amount is $139,000 and the phaseout starts at $560,000.57 Note that the requirement of sufficient positive business income still applies. If the income (including salary) is not sufficient, then a carryforward is permitted.
Under the act, in an expansion of the Sec. 179 provision, for tax years beginning in 2010 and 2011, $250,000 of the $500,000 limit for the Sec. 179 deduction may be applied to qualified leasehold, retail, and restaurant improvements.58 This category of assets has a 15-year life, so it is likely that taxpayers that place these assets into service in these years will choose to apply Sec. 179 to them. If the Sec. 179 income limitation applies to a taxpayer for 2011, this category of asset carryover cannot be deducted under Sec. 179 in 2012. Instead, the remaining carryover amount is depreciated as property placed in service on the first day of 2011.59 This is a trap for the unwary.
The Patient Protection and Affordable Care Act of 201060 imposed an excise tax on amounts paid for indoor tanning services. This year, Treasury issued final and temporary regulations61 regarding how disregarded entities will be treated with regard to this excise tax. Under the new regulations, QSubs and other disregarded entities will be treated as separate entities for purposes of the excise tax on indoor tanning services. This treatment is consistent with the treatment for other excise taxes under Regs. Secs. 1.1361-4(a)(8) and 301.7701-2(c)(2)(v).
Because of the extension of the zero capital gains rate for individual taxpayers in the lower two tax brackets in 2011 and 2012, taxpayers should consider gifting appreciated S corporation stock to their children, grandchildren, or parents. In 2008, the tax law extended the "kiddie tax" to income (including capital gains and dividends) of 18-year-olds who do not provide more than half of their support, and to 19- to 23-year-olds who are full-time students62 and do not provide more than half of their own support. Thus, the 0% tax rate generally will be unavailable to students through age 23 unless they have significant earned income or possibly trust fund income that contributes to their own support.
This leads to a balancing act. Parents may hire a child to legitimately work for them and pay him or her enough to meet the 50% self-support test, but not so much that they exceed the first two bracket limits. Also, the parent will lose the dependency exemption.
Example 2: The taxable income bracket limit for the first two brackets in 2012 is $35,350. Child C, age 22, is in graduate school and has $5,000 dividend income and $2,000 ordinary income from an S corporation, plus $10,000 earned income from summer work and from helping his parents with computer work in their business. His total support is $18,000. In May 2012, C's parents give him stock worth $26,000, with a basis of $6,000 and a holding period of at least one year. He has a standard deduction and personal exemption that puts his 2012 taxable income in the first two tax brackets. Assuming that C sells the gifted stock in 2012, he will pay no tax (0% tax rate) on the $20,000 capital gain and the $5,000 dividend income, for a tax savings over his parents' hypothetical tax on the dividend and capital gains of $3,750 ($25,000 × 15%).
Example 3: The taxable income limit for the first two brackets in 2012 for a retired married couple is $70,700. Couple B take a required minimum pension distribution (RMD) and invest primarily in tax-exempt bonds whose interest they are living off. Their S corporation Schedule K-1 shows ordinary income of $40,000, and they receive distributions of $50,000 during the year. They have itemized deductions of $30,000. Their net ordinary income is $10,000 ($40,000 – $30,000). Therefore, if they recognized $200,000 in capital gains or dividend income through the S corporation or otherwise, $60,700 of the gain would be subject to a zero tax rate. The other $139,300 would be subject to the normal 15% tax rate. This results in a federal tax savings of $9,105.
Most practitioners are aware in the right situation (investment interest expense being less than net investment income) of the tax planning opportunity of increasing investment interest expense and investing in dividend-paying stocks to play the tax rate differential. Less well known is using interest charge domestic international sales corporation (IC-DISC) status to achieve the same results for companies that produce products in the United States but sell them overseas.
The IRS Statistics of Income Bulletin (Winter 2010) shows a 266% increase in the number of IC-DISCs from 2004 (425 taxpayers) to 2006 (1,209 taxpayers), and gross export receipts increased from $5.3 million to $19.3 million in that time frame. Considering that there are more than 4 million S corporations, there is obviously a very small percentage taking advantage of these provisions. Essentially the IC-DISC receives a commission based on the greater of 50% of net export income or 4% of gross revenue. Dividends to shareholders are qualified for the Sec. 1(h) 15% tax rate, and the producing entity corporation gets a deduction at 35%. To sweeten the deal, the producing entity can use Sec. 199 as well.63
The Health Care and Education Reconciliation Act of 201064 imposes a net investment income tax of 3.8% of the lower of net investment income or modified AGI over a base amount65 for tax years beginning in 2013. The key term is "net investment income" and how it is defined relative to S corporations. If the passthrough entity has investment income such as interest income, dividend income, certain royalties and rents, as well as capital gains, that will be part of net investment income. If the investor is considered not materially participating under the rules of Sec. 469, then the income reported on line 1 of Schedule K-1 will be considered net investment income. The S shareholder should note that estimated taxes are required for this Sec. 1411 tax. In addition, there is also a hospital insurance tax66 scheduled to apply beginning in 2013 that would impose a 0.9% tax on wages and self-employment income above the thresholds described in Sec. 1411.
To facilitate the generation of cash in a tax-free manner, a C corporation might form an employee stock ownership plan (ESOP) and sell at least 30% of the stock to the trust using Sec. 1042. As long as the sellers reinvested the proceeds in publicly traded stock and bonds, the realized gain on the sale to the ESOP would not be recognized. The buyers then might convert the C to an S corporation where the income allocated to the ESOP would not be taxable.
However, there are some fairly complicated provisions designed to prevent abuses of these very favorable rules. In particular, be aware of the normal fiduciary rules that apply to trusts as well as the Sec. 409(p) disqualified person rules when dealing with S corporations. It is important to note that the corporation should set up the ESOP before it elects to be an S corporation.
Love67 involved those issues. In this case, owners of McDonald's franchises incorporated a management company and an operating company as S corporations. Over time they implemented an ESOP for the owners as well as 275 employees. For various reasons, including a deferred compensation plan, the benefits of the ESOP for the company's employees were not being realized and, upon termination of the trust and an election to close the books on the date of the change in ownership, a loss inured to the individual owners. The court held that Sec. 269 did not apply and that Sec. 409(p) was not violated.
1 IRS Letter Rulings 201227004 (7/6/12); 201222034 (5/18/12); and 201216030 (4/20/12).
2 IRS Letter Rulings 201225001 (6/22/12); 201213009 (3/30/12); and 201144012 (11/4/11).
3 IRS Letter Rulings 201225006 (6/22/12); 201218005 (5/4/12); and 201208022 (2/24/12).
4 IRS Letter Rulings 201217010 (4/27/12); 201211007 (3/16/12); and 201146001 (11/18/11).
5 IRS Letter Rulings 201224014 (6/15/12) and 201201006 (1/6/12).
6 IRS Letter Rulings 201151004 (12/23/11) and 201144018 (11/4/11).
7 IRS Letter Rulings 201223007 (6/8/12); 201222032 (5/18/12); and 201208023 (2/24/11).
8 Taproot Admin. Servs. Inc., 679 F.3d 1109 (9th Cir. 2012), aff'g 133 T.C. 202 (2009).
9 IRS Letter Rulings 201221006 (5/25/12) and 201202002 (1/13/12).
10 IRS Letter Rulings 201203002 (1/20/12) and 201145002 (11/10/11).
11 IRS Letter Ruling 201202003 (1/13/12).
12 IRS Letter Ruling 201145001 (11/10/11).
13 IRS Letter Ruling 201150024 (12/16/11).
14 IRS Letter Rulings 201225005 (6/22/12); 201216025 (4/20/12); and 201208013 (2/24/12).
15 Santa Clara Valley Housing Group, Inc., No. 08-cv-05097 (N.D. Cal. 1/18/12 and 9/21/11).
16 For an in-depth look at this case, see Orbach, "Santa Clara Valley Housing Group: An S Corporation Abusive Tax Shelter," 43 The Tax Adviser 610 (September 2012).
17 IRS Letter Rulings 201214001 (4/16/12) and 201201009 (1/6/12).
18 IRS Letter Ruling 201218004 (5/4/12).
19 IRS Letter Ruling 201216034 (4/20/12).
20 IRS Letter Rulings 201220024 (5/18/12) and 201150030 (12/16/11).
21 In re Kenrob Information Tech. Solutions, Inc., No. 09-19660-RGM (Bankr. E.D. Va. 7/10/12).
22 IRS Letter Ruling 201221008 (5/25/12).
23 IRS Letter Rulings 201226013 (6/29/12) and 201222003 (6/1/12).
24 If a change in basis occurs in December, the due date for reporting will be Jan. 15 of the next year.
25 The Mortgage Forgiveness Debt Relief Act of 2007, P.L. 110-142, §9(a).
26 Ensync Technologies, T.C. Summ. 2012-55.
27 Dickerson, T.C. Memo. 2012-60.
28 Penland, T.C. Memo. 2011-274.
29 Garavaglia, T.C. Memo. 2011-228.
30 Rogers, T.C. Memo. 2011-277.
31 D'Errico, T.C. Memo. 2012-149.
32 David E. Watson, P.C., 714 F. Supp. 2d 954 (S.D. Iowa 2010).
33 Joseph Radtke, S.C., 712 F. Supp. 143 (E.D. Wis. 1989).
34 Spicer Accounting, Inc., 918 F.2d 90 (9th Cir. 1990).
35 Joseph M. Grey Public Accountant, P.C., 119 T.C. 121 (2002).
36 David E. Watson, P.C., 668 F.3d 1008 (8th Cir. 2012).
37 Donald G. Cave Prof. Law Corp., T.C. Memo. 2011-48.
38 Donald G. Cave Prof. Law Corp., No. 11-60390 (5th Cir. 3/22/12).
39 Trugman, 138 T.C. 22 (2012).
40 REG-134042-07, 77 Fed. Reg. 34884 (6/12/12).
41 Rev. Rul. 81-187, 1981-2 C.B. 167.
42 Welch, T.C. Memo 2012-179.
43 Maguire, T.C. Memo 2012-160.
44 Barnes, T.C. Memo 2012-80.
45 Broz, 137 T.C. 46 (2011).
46 Small Business Jobs Act of 2010, P.L. 111-240.
47 Joint Committee on Taxation, Technical Explanation of the Tax Provisions in Senate Amendment 4594 to H.R. 5297, The Small Business Jobs Act Of 2010 (JCX-47-10), p. 6, n. 20 (Sept. 16, 2010).
48 IRS Letter Ruling 201150023 (12/16/11).
49 Anschutz Co., 664 F.3d 313 (10th Cir. 2011).
50 IRS Letter Rulings 201144002 (11/4/11) and 201144003 (11/4/11).
51 IRS Letter Ruling 201126023 (7/1/11).
53 IRS Letter Ruling 201219003 (5/11/12).
54 Recovery Group, Inc., 652 F.3d 122 (1st Cir. 2011).
55 Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010, P.L. 111-312.
56 Middle Class Tax Relief and Job Creation Act of 2012, P.L. 112-96.
57 Sec. 179(b); Rev. Proc. 2011-52, 2011-45 I.R.B. 701.
58 Sec. 179(f).
59 Sec. 179(f)(4)(C).
60 Patient Protection and Affordable Care Act of 2010, P.L. 111-148.
62 This assumes that the children ages 19–23 are not married. If they are, then the new expanded kiddie tax will not apply.
63 For more on IC-DISCs, see Tax Clinic.
64 Health Care and Education Reconciliation Act of 2010, P.L. 111-152, §1411.
65 The base amount for married filing jointly is $250,000; married filing separately is half of married filing jointly ($125,000); single $200,000; and trusts about $12,000.
66 Secs. 1401(b)(2) and 3101(b)(2).
67 Love, T.C. Memo. 2012-166.
Stewart Karlinsky is professor emeritus at San José State University in San José, Calif., and is an associate member of the AICPA Tax Division S Corporation Taxation Technical Resource Panel. Hughlene Burton is an associate professor and chair of the Department of Accounting at the University of North Carolina–Charlotte in Charlotte, N.C., and is the former chair of the AICPA Tax Division Partnership Taxation Technical Resource Panel. For more information about this article, contact Dr. Karlinsky at email@example.com or Dr. Burton at email@example.com.


text:
Elastic Waist Pleated Skirt
Style # 207819
Energize your new-season wardrobe with pretty prints in this luxury silk chiffon bebe skirt, featuring delicate pleating and a soft-hued geometric pattern. Try it with a white lace top for a pop of texture.
- 100% silk
- Center back to hem: 17" (43 cm)
- Polyester charmeuse lining
- Invisible zipper
- Dry clean
- Imported
- Imported
- Model is 5'9" and is wearing a US size S
Rated 3 out of 5�by 2 reviewers.
Rated 5 out of 5�by Jaimee31 FUN and FLATTERING I am a small curvy girl and I love this skirt! Everyone has said it looks great. I wear it with a long white button up collared chiffon shirt and chartreuse cashmere sweater and nude heels... to die! I think it matters what top you wear it with I was lucky to match it well. June 6, 2013
Rated 1 out of 5�by DRESSEDTOKiLL NOOO!! I saw this skirt at my local bebe and thought it would be super cute for spring. Boy, was I wrong. This skirt made me look like spongebob! It was so boxy on me! I have a hourglass figure, and it was NOT flattering. I don't like the way it fit. Pass on this ladies. March 22, 2013
1-2 of 2


text:
Kiko Saddle Bag - Mardi Gras Solids
Price: $70.00Availability: Out Of Stock
Special Price: $49.00 Ex Tax: $49.00
Special Price: $49.00 Ex Tax: $49.00
Model: HDK857
Dimension (L x W x H) 15.0 in x 4.0 in x 13.0 in
HDK857 Kiko Saddle Bag:
Saddle up with the HADAKI Kiko Saddle Bag, a stylish sidekick for all your adventures. From work to dinner, the Saddle bag is suited for any dress code and sure to generate compliments. The bold shape turn this over-the-shoulder bag into something special while the flap closure reveals a main compartment ready to haul all your essentials.
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Crocs Duet AthensSKU: #7897474
Product Information
- Please note this style runs in whole sizes only. For customers that are a half size, the brand recommends ordering a half size smaller than your normal shoe size.
- These stylish Crocs® sandals are the perfect addition to any warm-weather outfit!
- Fully-molded Croslite™ upper in a classic, flip-flop design.
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- Imported.
- Measurements:
- Weight: 9 oz
- Product measurements were taken using size Men's 12, Women's 14, width Medium. Please note that measurements may vary by size.


text:
« Exit photo gallery
John Kerry's career
John Kerry's career milestones throughout the years.
John Kerry addresses participants and supporters of Operation RAW (Rapid American Withdrawal) in Valley Forge, Pa., on September 7, 1970, after returning from service in Vietnam. Later, Kerry became the first Vietnam veteran to testify before Congress about the war.(Photo: Reuters)
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text:
NSSF News Release
NSSF News Release
Sadly they didn't mention the Kalashnikov, the greatest modern auto-loader.
Disclaimer -- the preceding message was a work of fiction, portrayed by actors over the age of 21.
There are varying degrees of evil, we urge you lesser forms of filth not to push the bounds and cross over into true corruption, into our domain. But if you do, one day you will look behind you and you will see we three and on that day you will reap it. And we will send you to which ever god you wish. --The Boondock Saints


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DENVER, COLO. (Jan. 26) - A late attempt to make a comeback fell short for the New Mexico State Aggies as the team slipped 67-58 to the Denver Pioneers on Saturday afternoon at Magness Arena. The Aggies drop to 9-10 on the season and 3-6 in Western Athletic Conference play.
Shooting 34.9 percent from the floor was not far from Denver's 35.9 percent, but the Pioneers worked for 23 bench points to beat out the Aggies. Senior Stefanie Gilbreath led the team with 18 points and six rebounds, while fellow senior Kelsie Rozendaal worked for her fourth double-double and second consecutive with 11 rebounds and 13 points on the day.
"It's hard to pinpoint just one thing, but really what it comes down to is making shots," head coach Mark Trakh said. "That doesn't mean we didn't do some really good things today. Abby (Scott) played well for us and Stefanie and Kelsie both did some nice things on the floor. It just has to be more consistent for more of our players."
Scott worked for nine points on the game with three defensive rebounds, contributing to the Aggies 43 total boards. The team had seven steals with two coming from sophomore transfer Danesia Williamson. Senior Camila Rosen was second for NM State defensively with seven rebounds.
The Pioneers struck first off a free shot and continued to an eight point lead before Gilbreath put the Aggies on the board with a layup in the paint. Williamson turned around for another Aggie layup and freshman Shay Young hit two from the line before Denver answered back with nine points to put them ahead 17-6 on the Aggies.
After a layup under the basket by Weber, the Pioneers hit a three at the arc to increase their lead. NM State found its groove as the team closed the gap to eight points with less than five minutes to play in the opening period.
Denver wasted little time increasing its lead to 32-20 with two more buckets, but NM State held the Pioneers scoreless in the final three minutes of play. Williamson sank the final points of the half for the Aggies with a layup from just under the rim and a free shot to close the period down nine (32-23) to the Pioneers.
Scott led the team with six points and Rozendaal worked for seven rebounds in the opening half of play. The Aggies shot 30 percent from the floor, while Denver managed 38.9 percent in the first half.
Denver took the lead in the second half as well, with four points before Gilbreath and Rozendaal brought the Aggies to life. After trading buckets, freshman Abby Scott hit a three from the top of the arc, giving the Aggies a push. Gilbreath sank a shot from the top of the key after hitting two free throws out of the second media timeout.
Rozendaal and Gilbreath helped the Aggies with a 10-2 run over the Pioneers in the middle of the half. Junior Jasmine Rutledge and senior Chrissy Fletcher kept the team moving forward as the Aggies tightened the gap to 62-55 with just over three minutes to play.
While the Aggies managed three more points on the day, Denver out-scored NM State with six free throws in the final seconds.
The Aggies now get back to the Pan American Center to host Texas State on Jan. 31 and UTSA on Feb. 2.


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Yeah, hard to believe nobody has thought of combining streaming and live TV yet in a cohesive way since so many people want that. It's really not that difficult, there's just big money and entertainment industry politics involved. And figuring out a payment method consumers will accept.
Apple television plans still bogged down in media negotiations
For those waiting on a full-on Apple television set, or even an enhanced Apple TV will more traditional capabilities, it looks like you'll have to keep waiting, at least for now. While Apple is likely ready to go from a technology standpoint, they can't seem to come to agreements with entrenched, terrified media companies over the future of the living room interface and experience. Adam Satariano and Alex Sherman report for Bloomberg:
In recent negotiations, the main stumbling blocks with cable companies have included a tussle for control over the software that determines the screen interface -- the look and feel of the viewer's experience, said people familiar with the discussions.
Bloomberg also succinctly sums up what Apple's plans are for the living room:
Since the middle of the last decade, Apple's engineers have been working on a more advanced product to allow viewers to quickly find shows and movies, blending both live and recorded material, the people said. It would recommend content based on interests and work seamlessly with Apple's family of other devices. An iPhone or iPad would double as a remote control, the people said.
According to Bloomberg, Apple most recently focused on deals to gain access to live programming from cable companies, without having to make completely new content deals. Apparently, however, the cable companies are worried that Apple will intermediate their customer relationships and don't find the prospect of more future-thinking business models appealing enough to risk the old, decaying ones.
And that's the downer in all this -- even if Apple's negotiations pan out, the best we'll get with this type of deal is an Apple TiVo, and not the product Apple really wants to make. Short of using some of that $100 billion in the bank to buy cable companies -- and they could never buy enough, globally enough -- and drag them kicking and screaming into a new and better world, we're all going to be held hostage to the fears, contracts, and comfort of the past.
Read the whole, sordid story via the link below.
Source: Bloomberg
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Reader comments
Apple television plans still bogged down in media negotiations
People have thought of it. Often.
Google TV is probably the best example (cautionary tale) for Apple. They went after combining these elements in a big way, but for the most part they gave into the various cable/sat companies, creating a mish-mash that few people bought. If Apple cannot do better at the negotiating table, their best efforts will fall between Google TV and XBox Live -- a sorta-nice thing to have to supplement regular TV, but nowhere near its own system.
Lots of people have had the thought to make TV better and use on demand and live. Cable/satellite companies refuse to relinquish control over an old system that makes them tons of money. That's why Google TV and Apple TV set top boxes have been lackluster. They started out as great ideas that could of been standard must haves, but got neutered by people controlling the content on has been technology. Why give customers the channels and content they want on the cheap when you can charge them over $100 a month for everything to get the 10 channels of content they actually want to watch...
Sorry, I worded that poorly. I realize plenty of people have thought of the concept, it's just that nobody has figured out how to deliver the content because as you said more money can be made "bundling" channels nobody wants.
At some point this will change. If current content creators aren't willing to do it, you can bet that at some point somebody else will. There is a growing demand for it, and where there is demand there is money to be made. It may take time, but it will happen.
This is not surprising or hard to understand. Content creators, that is movie & tv studios, make profits selling shows and networks to cable companies. Cable companies sell the distribution channels, the cable pipes to customers. Neither really has any incentive to let Apple in on either revenue stream. If it's not gonna make them a ton more money then they already make they have no incentive to help apple do anything. They bit with music and it pretty much gutted their business. They aren't going to go that way again easily. If apple really wants in they need to start or buy a cable company and merge it with a movie/tv studio, like comcast is doing, Time Warner did, etc.
I think there is a market right now for both regular cable subscribers, and content subsribers. Before I was married, I did not even have cable. All my viewing came from Netflix and my own personal collection. If I had had the option, though, to say, have an Apple TV, and buy channels individually, for example, even without cable I like Comedy Central, and a few others. Even at 5 bucks a month each channel I would be saving a TON! Still making the networks money. With subscription services, and a device to pick up the content, it would eliminate a lot of excess charges. Currently, I think some shows have it right by offering the "Season Pass" option in iTunes. Its not what I would prefer, to pay for a show individually, but, its a start. I did the math recently and if my wife and I just used a credit card to buy a season pass to all the shows we watch, even at current pricing, we would save an estimated $400 a year. Well, she is one of those people I am talking about that still wants cable for surfing and discovering new channels so she shot down my suggestion. We are close though. Podcasts are amazing and offer a way to cater to niche audiences, it would be nice if the rest of the industry would jump onboard.
ESPN has already done it. Their app on Xbox 360 streams live tv, but you can also watch any past event on demand. All for free. Or at least the cost of xbox live.
So it's not actually free, I would assume Microsoft is paying the subcription price. ESPN does something similar with ESPN360. If your ISP doesn't pay the subscription, you can't access local live programming.
Sounds like a way for them to make the money they need, but I shudder at the thought of ISPs controlling access to "premium" sites. Before long the "premium" sites will be cluttered with junk just like TV packages and prices will go way up.
yeah it's totally not free. you have to, one, pay for xbox live, and two pay a cable company for service or you don't get it. that's the key you're not getting it on xbox live until you enter your cable service too. See ESPN is fine with streaming as long as it doesn't threaten cable. Now if internet or digital services somehow prove they can make more profits then people will switch but so far, none have. Consider that ESPN is paying the NFL $15.2 Billion with a "B" to air monday night football through 2021. They HAVE to make that back and a bunch more to be profitable. They aren't simply going to give it away for free online. I'd love everything to be free but if they can't make money they won't do it. They have zero interest in doing anything to kill cable anytime soon. Not with a ton of networks and programs they are paying to show. It's not just cable companies, the content creators aren't exactly begging for free online services or a video equivalent of itunes as the major way to deliver video content. Simply because they don't make nearly as much money that way.
I don't need anything to be free, I just want a better experience for me, and I would be williing to pay for it. I understand how programming works, and I know that its great we get to watch sporting events and sitcoms and dramas on network tv, but to allow the user MORE control of HOW the media is received, that would be nice.
Actually you don't have to have cable tv at all. I don't have cable or satalite, just Xbox live. It's not like HBO go.
I think its a little ridiculous how archaic the industry can be. My brother-in-law currently has a Google TV and one of the things I like the most is that the cable box goes THROUGH the Google TV and its nice not having to swap between inputs to go into the Google TV options. I think it would be extremely convenient if I was watching something on tv with my wife, but wanted to show her a trailer or video from my phone using Airplay and could just start the video, pause Live TV and then when video is done, go right back. In addition to that, cable companies already work with TIVO and my brother has it with his company and it creates a MUCH nice user experience for him than a standard cable box. I can only imagine what even an enhanced Apple TV can do.


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Bill Roundtree and Jay Strange presented the program for the Nov. 28 meeting of the Rotary Club and answered questions following their presentation.
Strange said early acquisition of three of the 74 parcels began in January of 2008 and acquisition of the remaining parcels started in 2010. He said so far the GDOT has acquired 63 of the parcels, and the remaining eight are at the point of closing.
He said the let date for the project is Feb. 15, 2013, which means that is when it will be put out for contract bids.
The speaker said an ecological study found more wetlands, but that should not stop the project. He said Board of Commissioners Chairman Preston Hawkins keeps in close contact.
"Mr. Preston is all about Jones County. He calls at least twice a month to check on our progress," he said.
Roundtree said environmental conditions are constantly changing, and federal funding means a lot of red tape.
For the full story, pick up a copy of this week's newspaper or subscribe to our e-Edition at http://ee.jcnews.com.


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« Exit photo gallery
Ken Salazar's style
Interior Secretary Ken Salazar brightens up the expected suit and tie uniform with a bolo tie and cowboy hat.
Interior Secretary Ken Salazar speaks at a Hispanic caucus, before first lady Michelle Obama, Wednesday, Sept. 5, 2012, in Charlotte, N.C.(Photo: AP Photo)
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See other Ho Chi Minh properties
Duc Vuong Hotel
195 Bui Vien Str, Dist 1 Ho Chi Minh, Ho Chi Minh, Vietnam, Distance from city centre: 3.2km
Real Reviews
Real reviews from fellow travellers
These are trusted reviews from guests who have actually stayed here. We hope you find them helpful.
Note: we only give a property a rating once it has received a minimum of 3 reviews.
- Page:1/1
- " Their in-room wifi was down during our stay, which was quite inconvenient. I hope they'll change the music at their rooftop restaurant to make it a more relaxing and chillout place for guests. Our room was good, loved the rainshower. "
- 20 Feb 2013 Ngo Yi Hong Kong
- " Highly recommended !! Nice location, friendly & helpful staffs, good breakfast & dinner. Value for money. So suprised that Duc Vuong celebrated my birthday, bought me a cake/sang birthday song & prepared dinner for my family. Thanks Duc Vuong for the unforgotable night. Duc Vuong upgraded our rooms as my birthday gift, thanks again :) "
- 07 Aug 2012 BEE CHIN


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Morning vs. Evening
Avoiding the midday sun is an obvious way to duck the heat. But should you ride closer to when it rises or sets? You decide.
Air Temperature
Morning: Lowest after sunrise, but the day's not getting any cooler
Evening: Heat absorbed by road surfaces radiates and keeps air warm
Morning: Cooler air has more relative moisture, so sweat evaporates slower and you take longer to cool
Evening: Drops as the temperature rises; sweat evaporates (and you cool off) faster
Body Temperature
Morning: Lower just after you wake up
Evening: Higher later in the day
Three More Ways To Chill
Deflect the sun. You learned in middle-school science that pale colors reflect light, while dark ones absorb it. But few of us can legitimately rock a blinding-white skinsuit. Instead, try Pearl Izumi's new dark-colored kit made with coldblack, a special fabric treatment designed to reflect sunlight. Jerseys, bibs, and shorts start at $100.
Ice your legs. Cyclists who soaked their lower bodies in cold water for 20 minutes before a 40-minute time trial on a hot day generated, on average, 20 more watts of power than when they skipped the soak, reports the journal Medicine & Science in Sports & Exercise. No pool? The Transformer shorts ($110) made by clothing manufacturer 110% Play Harder come with ice packs that slip into built-in panels. Try wearing them for 20 minutes before riding on the hottest days.
Drink protein with carbs. The combo helped cyclists go faster inan eight-day race in 90-degree heat than those who fueled only with carbs. "Protein helps the body retain water, so there's more blood to divert to the skin to cool you," says study author Chris Easton, PhD. During a long ride, sip a drink with a 4:1 carb-to-protein ratio, aiming for 56 grams of carbs and 14 grams of protein per hour.
(Key Skill) Make A Preride Slushie
1 cup ice + 1 cup water + 1/4 cup sports drink
Icy-beverage devotees were stoked last year when research concluded that slurping a slushie before exercise helps you go 20 percent longer in the heat than sipping cold water. Toss the above ingredients into a blender. Start drinking 40 minutes pre-ride and try to finish it about five minutes before you roll.
Why It Works Your body shuttles warmth to your stomach and away from your extremities to melt the slushie, which prolongs the time it takes you to overheat, says study author Paul Laursen, PhD, a physiologist at the Sports Performance Research Institute of New Zealand. The electrolytes in the sports drink enhance hydration.


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Monday, January 14, 2013
Seniors Patrick McCardle and Julian DiPaolo led the Fort Dorchester Hockey Club to an 8-4 victory over the District 5 Fusion Dec. 21.
McCardle finished the game with a hat trick and DiPaolo scored two goals and made two assists as the Patriots improved to 7-1-1 on the season. Junior Brandon Doss scored the Patriots final goal of the evening and had a pair of assists in the game.
DiPaolo received a pass at mid-ice early in the opening period and made a beeline to the Fusion goal to put the Fort up 1-0. The Patriots gained more momentum when Nick Davidson won a puck in front of the Fusion goal and flipped a backhand shot off the goalie. Blake Thompson was there to get the deflection and score with 8:33 remaining in the period.
The Fusion answered the goal, but Fort Dorchester stuck again with 3:08 left in the period. After a shot bounced off the Fusion goalie, DiPaolo slapped the puck back to McCardle who sent a shot into the net.
The Fusion cut the lead back to 1 early in the second period, but Todd Braga scored for the Patriots shortly after to keep the momentum in the Forts favor.
The Fusion kept fighting and found the net again with 11:02 remaining in the period, but the Fort had a goal from DiPaolo with assists by Doss and Chandler Murphy and an unassisted goal from McCardle to take a 6-3 lead into the final period.
McCardle scored his third goal of the game with 13:39 remaining for a 7-3 Patriot lead. The Fusion answered with an unassisted goal at the 16:16 mark but couldnt cut into the Forts lead any more.
With just more than four minutes remaining, DiPaolo and Doss broke past the defense to put the Fusion goalie in a bind. They passed back and forth and then Doss slipped the puck into the net for the 8-4 margin.
The Fusion dropped to 2-5 with the loss.
At 7:30 p.m. Dec. 28 the Fort will take on Bishop England/Porter-Gaud at the Carolina Ice Palace. With a 5-1 record, the team is tied for second place in the league. The Patriots enter the game as the leagues top team.
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That backing fabric makes me so happy! I put this one in the shop while I contemplate whether or not I should keep it. But after filling 5 of those giant silver tubs with quilts during moving I've decided I should probably try to cut back. Luckily this one wouldn't take up that much space right? I say that about every single one I keep. That's why I have tub(s) full.
Wednesday, August 12, 2009
Little Wonky Cars Quilt
31 comments:
- Jeni said...
I LOVE this one! My little guy is 9 now but I still love that boy stuff. Thanks for sharing your wonderful ideas!!!
- August 12, 2009 at 9:56 AM
- Di~ said...
Very Cute Quilt. I love the quilting you did. Simple loops.
- August 12, 2009 at 10:22 AM
- Heather said...
This is adorable. I love all the little cars, and the loops are awesome!
- August 12, 2009 at 10:32 AM
- Heather said...
Okay, that is so cute. I like that fabric a lot. Great little quilt :)
- August 12, 2009 at 10:40 AM
- Heather said...
Love it!!! Seriously cute stuff. Oh and did you notice I am now the third Heather to comment - must be a record or something - LOL!
- August 12, 2009 at 10:45 AM
- anne said...
Super cute. And I really like the red binding.
- August 12, 2009 at 10:47 AM
- Kelly said...
It's usually hard to find really cute quilts for boys, but not so today!! GREAT job!
- August 12, 2009 at 11:08 AM
- scrapworking said...
It's wonderful! Love everything about it. I'd want to keep them all too. You know, someday you'll have grandchildren, right?!?! Justification.
- August 12, 2009 at 11:22 AM
- Jenny said...
the quilt is just fabulous...i love this desgin, did you get the pattern from a book or tutorial you can tell me about?
krousegirl2 at aol dot com
- August 12, 2009 at 11:25 AM
- Anna said...
Where did you find that backing?? I simply must have some!
- August 12, 2009 at 11:41 AM
- Robin said...
I love that quilt! It is so bright and happy!! What a great job!!!
- August 12, 2009 at 1:10 PM
- e.c said...
So! incredibly cute. Nice work.
- August 12, 2009 at 1:27 PM
- Cheryl Arkison said...
Perfect binding!
Shh, I'm the same way with my machine. No service since I got it 4 years ago. I can't bear to part with it for that long.
- August 12, 2009 at 2:10 PM
- Jilly's Space said...
So CUTE!! Turned out great.
- August 12, 2009 at 2:18 PM
- Sarah Seitz said...
I love, love love the wonkiness! Just out of curiousity, what kind of a machine do you use?
- August 12, 2009 at 2:38 PM
- Gillian said...
Very cute.
- August 12, 2009 at 2:46 PM
- Nancy said...
I love this! It is adorable!
- August 12, 2009 at 2:52 PM
- Blue is Bleu said...
The backing is just brilliant!!! I love love love it :) Love the loopy quilting too!
- August 12, 2009 at 3:38 PM
- Tracy T. said...
Incredibly adorable. I love the swirly quilting, and you've given me encouragement to quilt my Nine-patch top in all white, it looks great on this. But, damn you for making me all nostalgic for cute wee little boy things - mine are now old, old, men of 5 and 7!
- August 12, 2009 at 4:12 PM
- Andi said...
What a sweet quilt for a little man!!
- August 12, 2009 at 4:45 PM
- Cindy said...
very cute quilt!
- August 12, 2009 at 4:46 PM
- Leslie said...
this is so so so adorable. i love it. The quilting is so fun. i want to give that a try.
- August 12, 2009 at 5:20 PM
- shannon said...
What an adorable quilt!
- August 12, 2009 at 7:10 PM
- Marianne Penner Design said...
This quilt is really very, very beautiful.
- August 12, 2009 at 9:24 PM
- I Love Baby Quilts! said...
Love it! That is going to make some little boy very very happy. Or little girl too!
- August 13, 2009 at 8:41 AM
- True Blue Nana said...
I stumbled on to your blog today and I love this quilt. How big are the large squares and how big are the small car blocks? What a darling idea!
- August 13, 2009 at 1:42 PM
- tasha said...
it's nice to see a cute boy quilt! very nicely done!
- August 14, 2009 at 9:33 AM
- erica said...
- August 17, 2009 at 5:32 AM
- Melvin said...
Very Cute Quilt. I love the quilting you did. ....
Great work...
Get your company name famous across the world with online marketing
- August 17, 2009 at 10:17 PM
- Jenny said...
I have to say that I LOVE this quilt. Definitely inspires me to do something like it.
By the way, I love seeing the LDS link at the bottom of your sidebar!
- September 17, 2009 at 6:24 AM
- kate said...
I have been inspired by this quilt to create my own. If you are interested it is here: http://jemimaquilts.blogspot.com/2011/08/project-peanut.html
- August 7, 2011 at 4:25 AM


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Google Docs and Google Drive don't offer the option to find public files, but you can do that using Google search. Now that the Google Docs robots.txt file allows search engines to index most of the public files, you should be able to find them, assuming that there are some links that point to them.
Search engines only index the files that are "public on the Web". By default, files are private, but you can change the visibility from the "Share" box.
Here are some useful queries that let you find public Google Drive/Docs files (you can append some keywords to the queries):
* [site:docs.google.com/document/d] - find text documents
* [site:docs.google.com/presentation/d] - find presentations
* [site:docs.google.com/drawings/d] - find drawings
* [site:docs.google.com/file/d] - find files: images, videos, PDF files, Microsoft Office documents and more (you should click "repeat the search with the omitted results included" since there are many files with similar titles)
* [site:docs.google.com/folder/d] - find folders (collections of files and other folders)
* [site:docs.google.com/open] - find other documents, folders and files (the links redirect to other URLs)
Public spreadsheets and forms can't be indexed by search engines.
July 14, 2012
Find Public Google Docs
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