text:
Prudential Financial (NYSE:PRU), not to be confused with Prudential plc (NYSE:PUK) of the U.K., is one of the largest life insurers in the world. Negative overall sentiment on any financial company has sent its stock toward its lowest levels over the past year. An appealing valuation and decent growth prospects overseas bode well for future shareholder returns.
Investopedia Broker Guides: Enhance your trading with the tools from today's top online brokers.
Recent Developments
On May 22, 2012, Prudential held its annual investor day and committed to raising its return on equity to between 13 and 14% by 2013. Implicit in this assumption is growth in its investment portfolio and stock market returns of 8% over the next couple of years. International growth, especially in Japan and parts of Asia, is expected to be the key growth driver. Cost cutting and share buybacks are also expected to make some positive impacts on per-share profits over the next couple of years.
SEE: A Breakdown Of Stock Buybacks
European Fears
Unlike U.K. rivals Prudential plc or Aviva (NYSE:AV), Prudential has minimal business exposure to Europe. As of the end of 2011, its primary exposure stemmed from its investment portfolio, which held roughly $17 billion in European sovereign government bonds, financial institutions and other entities. Though large in absolute levels, it is quite muted in the context of Prudential's investment portfolio of $355 billion and total asset base of $625 billion.
SEE: Investing In Sovereign Bonds
Outlook and Valuation
For all of 2012, analysts project total revenue growth of 9% and total revenues of nearly $43 billion. The consensus earnings estimate currently stands at $6.55 and is expected to rise nearly 19% to $7.76 for 2013. Based off book value of $74.35, this represents return on equity levels of 8.9 and 10.5% and forward P/E of seven and six, respectively.
SEE: 5 Must-Have Metrics For Value Investors
The Bottom Line
Prudential operates primarily in the U.S. and Japan, which are the two largest life insurance markets. According to a study provided in its investor day presentation, the market share of the global life insurance market came in at 27 and 24%, respectively, with the rest of Asia (excluding Japan) the next largest at 23%.
Japan is expected to be a future growth driver. Prudential is a leader domestically and now the third largest player in Japan, with a share of around 10.4%. Other rivals include Sumitomo Mitsui Financial Group Inc. (NYSE:SMFG) and even Sony (NYSE:SNE). Overall, the combination of decent international growth prospects, prospects for improved shareholder profits and a compellingly low valuation, bode well for future shareholder returns.
Use the Investopedia Stock Simulator to trade the stocks mentioned in this stock analysis, risk free!
At the time of writing, Ryan C. Fuhrmann did not own shares in any of the companies mentioned in this article.


text: Healthy Recipes Cassoulet-Style Chicken Thighs Recipe E-mail recipe Print recipe To save this recipe, register now! Quick Info: Servings Quick Meal Contains Wheat/Gluten Contains Red Meat Nutritional Info (Per serving): Calories: 370, Saturated Fat: 3g, Sodium: 749mg, Dietary Fiber: 10g, Total Fat: 13g, Carbs: 40g, Cholesterol: 68mg, Protein: 29g Carb Choices: 2 Recipe Source: Prep Time: 15 mins Cook Time: 25 mins Total Time: 40 mins Ingredients 30 ounce(s) beans, white, rinsed 3/4 cup(s) bread crumbs, soft whole-wheat, fresh 2 tablespoon oil, olive, extra-virgin, divided 1 pounds chicken, thighs, boneless, skinless, trimmed of fat and cut into thirds 1 large onion(s), chopped 6 clove(s) garlic, roughly chopped 1/2 teaspoon rosemary, dried 1/2 teaspoon thyme, dried 1/2 teaspoon pepper, black ground 1/2 cup(s) wine, dry white 1/2 cup(s) broth, chicken, less sodium 1/2 cup(s) water 1/2 pounds sausage, turkey, kielbasa, low-fat, sliced into 1/2-inch pieces 2 tablespoon parsley, fresh, finely chopped Preparation 1. Put 1/2 cup beans in a small bowl and mash with a fork. Add the remaining beans and set aside. 2. Toss breadcrumbs with 1 tablespoon oil in a small bowl. Heat a large skillet over medium-high heat. Add the breadcrumbs and cook, stirring often, until golden and crisp, 2 to 3 minutes. Transfer to a plate and set aside. 3. Heat the remaining 1 tablespoon oil in the skillet over medium heat. Add chicken in a single layer and cook until browned, turning once, 2 to 3 minutes per side. Transfer to a plate. 4. Add onion and garlic to the skillet and cook, stirring occasionally, until the onion is softened, about 5 minutes. Add rosemary, thyme and pepper and cook, stirring, until fragrant, about 30 seconds. 5. Add wine, increase heat to high and cook, stirring with a wooden spoon to scrape up any browned bits, until the wine has reduced by about half, 1 to 2 minutes. Add broth, water, kielbasa, the reserved beans and chicken; bring to a boil. Reduce heat, cover and simmer until the chicken is cooked through, 3 to 5 minutes. Top with the toasted breadcrumbs and parsley. E-mail recipe Print recipe To save this recipe, register now!

subset: commoncrawl


text:
New Moon
Day and Night
Beginning of Night
The Day
The Week
The Month
The Year
Three Periods of History
The history of a Jewish Calendar is divided into three periods: the Biblical, the Talmudic, and the post Talmudic. During the Biblical period the understanding of the Calendar was based entirely upon the observation of the sun and the moon. The Talmudic period rested upon observation and reckoning, and the post Talmudic period rested entirely upon reckoning. The Hebrews studied astronomy very carefully because of their intense need for accurate dates in keeping the festivals. The Lord gave the command in Deuteronomy 16:1:
"keep the month of Aviv,"
and made it necessary for the Hebrews to become very acquainted with the position of the sun. Also the command:
"observe the moon and sanctify it,"
made it necessary for the Hebrews to study the phases of the moon.
Calendar Numerals
Originally, the Hebrews employed numerals to distinguish one month from another. The month by which the spring season (Aviv) commenced was the first month (Exod 12:2; Deut 16:1), the other months were referred to as the second month, the third month, etc. The Bible reveals some traces of names of months: Aviv is revealed as the first month; Ziv, the second month (1 Kings 6:1); Etanim, the seventh month (1 Kings 8:2); and Bul, the eigth month ( 1 Kings 6:38).
Note: In post exilic books Babylonian names are employed.
The Jewish Calendar in Ancient Hebrew History
Bible History Online


text:
Nike Men's Vapor Carbon Elite TD NFL Team Football Cleat
$129.99 $154.99*
Save $25.00 (16%)
Product Information:
Become unstoppable this year in the Carbon Elite. A zero-space fit synthetic leather upper with nano-lasered quarter panels delivers lightweight comfort and support while ensuring a tight locked in fit. The Nike® Vapor Carbon Elite TD football cleat has a carbon fiber propulsion plate with injected TPU traction layout that provides maximum acceleration, grip and performance to take your skill to another level.
- NFL Team Colorway with team logo on the insole
- The newest top of the line cleat created for the untouchable football player, The Nike® Vapor Carbon Elite TD Football Cleat
- Lightweight synthetic leather upper with zero-space fit offers maximum lock down, durability and stability while a Nano-lasered quarter panel provides a mixture of comfort and support
- Carbon fiber propulsion plate and injected TPU spike configuration delivers the most explosive performance of your career
- Weight: 10.2 oz
- Style: 657441
- Nike
Country of Origin: VietnamWeb ID: 33580256
Customer Reviews:
Rated 4.8 out of 5�by 24 reviewers.
Rated 5 out of 5�by JG Product is lightweight and perfect fit. Son wears for football loves them wants pair for baseball that light July 29, 2015
Rated 5 out of 5�by Vik Awesome cleats My son loved his new cleats. Runs true to size. Shipped quickly. Will order again in future. Thanks Dicks Sporting Goods! July 26, 2015
Rated 4 out of 5�by Riggs Description My son chose his team shoe and read that the logo would be on the insole. The logo is not there.... Are we missing something? July 18, 2015
Rated 5 out of 5�by jp77 Great purchase! Fast shipping and very easy to order! My son loved them! Bought for my son for the upcoming season. Was pretty bummed I received a $10 off coupon right after I received them in the mail so I didnt have a coupon at the time of order. I did give it to my friend to use for her son's cleats though:) June 26, 2015
Rated 5 out of 5�by Kaleb65 Great The Nike vapor cleats are the best cleats I have bought and worn yet. They are very light cleats which helped me out alot March 13, 2015
Rated 5 out of 5�by Shukurujustin123 Nike Vapor Carbon Elite TD cleats These cleats work great on the field, they are probably the best on the market. February 20, 2015
Rated 5 out of 5�by ocgirlie Best cleats !!! I ordered these cleats for my son, who plays high school Lacrosse. He wears a size 13 shoe, but in Nike cleats, we have found that they run a bit small, so he usually goes up a size to a 14. Since they did not have these cleats in store, we took the chance and ordered the size 14. We received them in less than a week, and my son has worn them to practice every day since. He said they did not hurt, nor did they require a break-in period. They are comfortable and he's really, really happy !! February 12, 2015
Rated 5 out of 5�by thebacom Great Cleats and Great Timing with the shipping. They arrived in two days, the cleats look amazing and stylish, also it is like wearing any sneakers, just doesn't feel like a cleat because of it's comfortness. WOW! December 23, 2014
Rated 5 out of 5�by TamalaJ Vapor carbon are a must buy! Purchased the cleats for my son and he absolute loves! The fit is good, he able to run fast in them and the look in his words are 'FIRE" September 21, 2014
Rated 5 out of 5�by Aortega1314 Great shoe This is a great shoe. My nephew loves it! I just don't like that the shipping is UPS. September 18, 2014


text:
No eBook available
The Question of God: C.S. Lewis and Sigmund Freud Debate God, Love, Sex, and ...By Armand M. Nicholi
Get Textbooks on Google Play
Rent and save from the world's largest eBookstore. Read, highlight, and take notes, across web, tablet, and phone.
Go to Google Play Now »


text:
"I ordered these w/the phrase, "Bring Pampers for a chance to be pampered!", as an incentive for my guests to bring a pack of diapers along w/their gift for a chance to be entered into a drawing for a gift certificate to a local nail spa. It was the perfect finishing touch!"
"I loved the design of the card. I love the quality of the paper, very sturdy. Because of the glittery "look" on the card, I think I sort of expected to see some real glitter on the card...obviously that wasn't the case. I'm not disappointed though, really love it for my sister's shower. The mailing was a pain, only because I bought these right when postage increased and the post office didn't have the new 70c stamps that go with the square cards, so I had to put three stamps on there."
"Great idea for favor size boxes, treat bags, candy buffet labels. Going to order more for other ideas for my daughters shower."
"Ordered for my daughter's first birthday's pretty in pink party. It is very dainty and elegant. Loved it! Quality is great as always."
"I was able to personalize these gift tags w/ the full date of the shower and then used them as sticker's to make keepsake book marks for my sister's guests! (we did a book-themed party since we didn't know the baby's gender of the baby!) Everyone loved them. We also used the stickers as cupcake toppers! We stuck them on different colored cardstock and cut them out, leaving just about an 1/8 inch edge and stuck them in our cupcakes - perfect complimentary shower decorations! Oh - we changed the graphic from the heart to the question-mark so it would match the invitations. So simple to make that request and Tiny Prints called and sent proofs showing me what it would look like both ways. So professional and courteous. I will definitely order from them again!"


text:
KVA girls bow out of state tourney
The Kerr-Vance girls basketball season ended Tuesday at Hickory Christian Academy in the first round of the state tournament.
The ninth-seeded Spartans (12-11) fell 37-34 at No. 8 Hickory Christian (16-4), which advanced to the quarterfinals of the N.C. Independent School Athletic Association Class 1-A Tournament to face No. 1 Northwood Temple Academy.
KVA was within three points of Hickory Christian at the end of each period, but never quite caught up.
"We knew they liked to shoot 3s," KVA head coach Brian Russell said of Hickory Christian. "They made five 3s and four in the first half."
Rachel Ross and Rebecca Ross each had 10 points for KVA and Russell highlighted the play of Rebecca Ross and her fellow captain Price Wester.
It was the first appearance in a girls state tournament in six years for the Spartans, who set a goal of reaching the postseason at the beginning of the season.
"This was a great group of ladies," said Russell. "I'm blessed to be their coach. They're just great kids. You hate to see the season end for them. I'm definitely going to miss those seniors."


text:
Girl drummers
View Single Post
Senior Member
Join Date: Aug 2012
Posts: 363
Re: Girl drummers
Originally Posted by
Mad About Drums
If you have no doubt there's some outstanding, talented female drummers out there,
why did you post such sexist comments?
It doesn't make sense...
This forum include several female drummers, some of which are extremely talented, do you really have to see them before your eyes to acknowledge their talent?
Female drummers are a minority in the drumming world, for sure, but they are as good and bad as any male drummers, to assume that a gender defines "good" or "bad" is utterly ridiculous, in drumming or any other instruments
(Almost missed this one at the bottom of the previous page - my apologies)
Because the women who post - 'female' drummer, to me, are suggesting that there is a different category, and are initially launching a sexist platform to be judged, as if it is a separate starting point (like the women's tee in golf).
And my comments may appear sexist, because sometimes - in real life - it works out that way. I don't always agree with it, doesn't make it not a reality. Life isn't as politically correct as we all wish.
View Public Profile
Send a private message to JasperGTR
Find all posts by JasperGTR


text:
Bishop Ishmael Charles, Overseer of Tortola, BVI, and some of Leewards Islands was appointed the Caribbean Field Director, replacing Bishop Fedlyn Beason, who retired after serving for 14 years at the General Assembly, which was held July 24-27 in Orlando, Florida. Bishop Charles is very experienced leader in that he has served on International Executive Council and many Boards of the Church of God. He was also re-elected to the Council of 18 and Executive Council.of the Church of God. He is also one of the most respected spiritual leaders in the Caribbean as he was recently appointed to Co-Chair the Empowered 21 Caribbean Cabinet. Please pray for him and his wife Patricia as they lead this area.
God bless you – John N Humes, AB/National Overseer


text:
Window resizing _very_ slow with compiz
I have a GeForce-6600PCIe/256mb and I am running compiz-0.5 on Xorg-7.2 with the latest drivers (AIGLX).
I experience very slow window resizing (about 2-4fps), the large the window which is resized gets, the slower the resizing happens.
Any ideas what could be wrong, or how I could improve things?
Thank you in advance, lg Clemens
Re: Window resizing _very_ slow with compiz
Window resizing with Composite is slow because every time the window is resized, the server creates a new pixmap (which starts out in system memory by default) and then copies the contents of the old pixmap into it, which does a readback from video memory. Then, when compiz creates a texture for that pixmap, that uploads it to video memory again. This is clearly inefficient. You can improve resizing performance considerably by setting InitialPixmapPlacement to 2 so that all that's required is a fast vidmem-to-vidmem blit. However, most of the time the copy is useless anyway because the application will repaint the entire window in response to a resize.
Re: Window resizing _very_ slow with compiz
I think the developers are aware of the problem judging from this thread on the xorg mailing list.
Re: Window resizing _very_ slow with compiz
Hi again,
Thanks for the hint with the pixmap-placement. I tried it but didn't help, at least it led to no noticeable improvement :-/
Is pixmap-allocation really that slow that only 2-4fps refreshes can be done it the window is 1280x1024?
Thanks, lg Clemens
Re: Window resizing _very_ slow with compiz
It's not the allocation that's slow. After allocating the new pixmap, the server copies pixels from the parent window into the new pixmap. For X.org 7.2 and earlier, this used XCopyArea but this turned out to be a security problem for certain windows, so they switched to the RENDER extension's Composite call instead for X.org 7.3. Since pixmaps start out in sysmem by default, this falls back to software *every single time the window is resized*.
Re: Window resizing _very_ slow with compiz
Hi AaronP,
thanks a lot for your reply!
Thanks, lg Clemens
Re: Window resizing _very_ slow with compiz
Is there any data I could provide which could point out what the problem could be?
Please help...
Thanks, Clemens
Re: Window resizing _very_ slow with compiz
While the readbacks Aaron describes do cause considerable slowdown, there are many factors affecting window resizing with comosite managers, and especially window resizing with compiz. In particular, creating GLX drawables is a slow operation for various reasons. It is not a matter of simply allocating the memory. Compiz currently must create a GLX drawable for every "frame" of the resize operation. As mentioned, the X.Org developers are aware of the general problem, and we're also aware of the bottlenecks specific to our driver, and we're of course working on improvements as time permits. At this point, we're not blocked by lack of information from users on this one.
Re: Window resizing _very_ slow with compiz
I actually don't have a problem with slow resizing but I do have the slow/laggy (un)minimize problem with my 8800GTS like many others with the higher end 8xxx series cards.
I tried Loose Binding and Setting InitialPixmapPlacement to 2 and that helped about 80%, but I noticed with .19 InitialPixmapPlacement can now be set to 0-4 instead of 0-2 as previous releases. Is there any danger setting this to 3 or 4 instead?
Reason I ask is because when I set it to 3, the problem with (un)minimizing goes away. 4 causes some distortion though.
Any insight to this?
Re: Window resizing _very_ slow with compiz
Same problem with slow resizing...
BUT! Why (If it's compiz and/or xorg problem) it works well on some systems???
(Without any problems)
AMD Athlon 64 3000+
512 MB ram
openSuSE 10.2
X.Org X Server 1.4.0 Release Date: 5 September 2007 (updated from http://download.opensuse.org/reposit...openSUSE_10.2/)
NVIDIA Driver Version: 100.14.19
Re: Window resizing _very_ slow with compiz
Does anyone can help?
Re: Window resizing _very_ slow with compiz
I'll try out compiz soon on my Intel-GMA950 laptop ... I am quite curious what the results will be ...
lg Clemens
|All times are GMT -5. The time now is 10:38 PM.
Powered by vBulletin® Version 3.7.1
Copyright ©2000 - 2015, Jelsoft Enterprises Ltd.
Copyright ©1998 - 2014, nV News.


text:
2014 Unit of Study
The session(s) below are for 2014. For Summer School 2014 unit of study availability please visit the Summer School website (main Summer session January/February 2014).
The University of Sydney session calendar shows exact dates for sessions.
|Business Placement C (Internship)
|UoS Code
|Credit points
|Semester 1, Intensive April, Intensive February, Intensive January, Intensive June, Intensive March, Intensive May, Semester 2, Intensive August, Intensive December, Intensive July, Intensive November, Intensive October and Intensive September
|For Bachelor of Commerce (and all combined courses administered by the Business School): 48 credit points, including 5 x junior core units; For Bachelor of Commerce (Liberal Studies): 48 credit points, including 2 x junior core units
|Assumed Knowledge
|Additional Information
|Permission is required to enrol in this unit. Please contact the Business Programs Unit for details: email@example.com
|Wks 1-4: 1x 3hrs class per week; Wks 5-12: 3 1/2 days a week internship; Wk 13: 1 x 3hr class
|learning contract (0%), work learning journal (20%), placement presentation (15%), and research report (65%)
|This unit is designed to consolidate students' knowledge and skills in business while conducting an internship in industry. The unit is structured around three assessed tasks which are designed to allow students to demonstrate their ability to apply and synthesise business concepts in a real world setting. During the internship, students may be involved in a variety of different industry and client-based projects, which will afford the opportunity to apply business skills and theories from prior learning. This will provide firsthand experience of how these skills and theories can support the solving of business problems in a real business context, identifying opportunities, developing strategies and designing processes, procedures and management practices in order to enable an organisation to fully realise its competitive potential. Further information and application process is outlined at http://sydney.edu.au/business/study/opportunities/industry_placement_program


text:
Bomb scare as mortar found at Totnes waste depot
Posted: October 30, 2012|
The recycling centre at Totnes was closed for 90 minutes yesterday morning while bomb disposal experts removed a rocket propelled mortar which had been placed in a skip and narrowly missed being crushed by a digger.
Devon County Council, which owns the site, confirmed that the site was evacuated while police, then bomb squad officers, were called.
Investigators removed the mortar in a bomb-proof container for further examination. It is not yet known whether the mortar had already been deactivated before being disposed of in the skip, or whether it had potential to explode.
Roger Croad, Devon County Council's cabinet member responsible for recycling centres, said the rocket should never have been placed in the skip in the first place.
"We like to think that we can recycle most things to avoid them going into landfill, but rocket propelled mortars are definitely not on our list of recyclables," he said.
"Seriously though, it's rather irresponsible to leave ammunition or explosives at your local recycling centre, and possibly endangering staff and the public."


text:
Visiting Research Scholars
The Center for Health and Wellbeing (CHW), part of the Woodrow Wilson School, invites outstanding researchers to apply for Visiting Research Scholar appointments each year.
CHW supports research on the multiple aspects of health and wellbeing in both developed and developing countries. Successful candidates will devote an academic year or a semester in residence at Princeton to research, discussions, and scholarly collaborations concerned with the determinants of physical, mental, and emotional wellbeing, and the effects of public policy on health and wellbeing. Applications are welcome from researchers in a variety of disciplines, including medicine, psychology, biology, epidemiology, economics, sociology, and related social science disciplines.
Visiting Research Scholars participate in activities of CHW, including faculty-graduate seminars, workshops, and public lectures, and enjoy access to a wide range of other activities throughout the University. Scholars devote the major portion of their time to research and writing on issues related to health and wellbeing. Some Scholars may also have the opportunity to teach in one of Princeton's graduate or undergraduate programs. Any teaching is contingent on sufficient enrollments and must be approved by the Dean of the Faculty. Although most Scholars will stay for the entire academic year (September through June), applications for a single semester or a portion of a semester will be considered.
Applicants should have a doctorate or equivalent degree. The program is open to all regardless of citizenship, but it does not support work toward the completion of a degree. Salaries are based on the salary in effect at the Scholar's home institution. Scholars from academic institutions normally receive up to one-half their academic-year salaries from their home institutions for the appointment period. A supplement may be paid to Scholars who teach a course.
Visiting Research Scholars must be employed at an institution other than Princeton during their visit. Applicants who do not have a home institution from which to visit should refer to CHW advertisements for Post-doctoral Research Associates, defined as those within three years of receipt of the PhD or equivalent degree, and Associate Research Scholars, defined as those who received a PhD or equivalent degree more than three years ago.
Applicants are evaluated on the basis of (1) the quality of their achievements in their field of specialization and their ability to benefit from the activities of CHW; (2) the significance of their proposed contribution to CHW's mission; and (3) the contribution they are likely to make to research in the future.
To apply, please submit online a cover letter, a CV, a research paper, book chapter, or a dissertation chapter; a statement of no more than 1,500 words describing how you plan to use your time at Princeton; and a confidential statement indicating your current 12-month salary and what sources of financial support you are likely to have during your visit via: https://jobs.princeton.edu.
Search for "Visiting Research Scholar-Center for Health and Wellbeing," requisition number 1400692.
The deadline for submission is December 15, 2014. Applicants will be notified of the outcome of their applications in March 2015.
Princeton University is an equal opportunity employer and complies with applicable EEO and affirmative action regulations.


text:
Full detailed profile on Laura Koffman playing Rebecca Fowler on All My Children Daytime Soap Opera.
Laura Koffman (Laura Koffman)
Laura Koffman
Birthday: October 29, 1964
Laura Koffman is no stranger to Daytime television fans! She began her acting career in New England but soon moved to New York to pursue her dream. Her first roles were on "Another World" and "Against The Law", but her big break came in 1991 when she was cast as Cassie Cramer on One Life To Live.
She left the show to concentrate on her family but has reprised the role of Cassie several times. Laura is also a stage actress; she has appeared in two off-Broadway plays.
Laura returned to Daytime television in 2008 when she took on the role of Rebecca on All My Children.
Laura and her husband have two children.
There are no additional images yet
All My Children - Rebecca (October 28, 2008 - February 5, 2009)
One Life To Live - Cassie Cramer (1991 - 1999, 2001, 2002, 2003, 2004)
Another World - Lindsey (1991)
Against The Law (1990)


text:
- 188.8.131.52 Introduction to Pre-90-Day Income Tax Cases
- 220.127.116.11 Written Protests and "Small Case Requests" in Unagreed Cases
- 184.108.40.206 Receipt of a Pre-90-Day Case - Account and Processing Support(APS)
- 18.104.22.168 Receipt of New Assignment by an Appeals Technical Employee (ATE)
- 220.127.116.11 Returning a Case to Examination - ATE
- 18.104.22.168 Preliminary Review of a Case - ATE
- 18.104.22.168 Uniform Acknowledgment Letter Procedures - ATE
- 18.104.22.168 Conducting the Conference - ATE
- 126.96.36.199 Requesting Work from Tax Computation Specialist
- 184.108.40.206 Reaching a Conclusion in the Case
- 126.96.36.199 Closing the Case to APS
- 188.8.131.52 Processing a Pre 90-Day Case - APS
- 22.214.171.124 Assembly of the Administrative File
- 188.8.131.52 Closing Letter
- 126.96.36.199 Statute Open with Form 872-A
- 188.8.131.52 Computer Disks in the Case File
- 22.214.171.124 Closing Documents
- 220.127.116.11 Balance Due Over $10 Million - APS
Manual Transmittal
August 07, 2012
(1) This transmits revised IRM 8.2.1, Pre-90-Day and 90-Day Cases, Agreed 90-Day Income Tax Cases.
Material Changes
(1) Revised IRM to reflect new organizational titles resulting from the Appeals 2012 Alignment Project.
(2) Revised 188.8.131.52.4 (3) to define the term "Fully Paid" as a case in which the tax, penalties, and interest have all been paid in full.
Effect on Other DocumentsThis supersedes IRM 8.2.1 dated June 28, 2012
Effective Date(10-01-2012)
Susan L. Latham
Director, Policy, Quality and Case Support
This section covers processing a pre-90-day income tax case, also referred to as a non-docketed case, from the time it gets to Appeals until the time the case is closed. A pre-90-day case is a protested case on which a notice of deficiency or other final determination letter has not been issued.
Many of the procedures in this section are used on every case regardless of the type tax involved; however, certain cases also require special procedures. These special procedures are covered in separate IRM sections containing information solely applicable to that type case.
Special procedures take precedence over the general instructions found in this section. The following is a list of the cases and the IRM subsections where the special procedures are located:
Estate and Gift Tax - IRM 8.7.4
Excise Tax - IRC 8.7.10
Employment Tax - IRM 4.23.16
Bankruptcy - IRM 8.7.6
Claims and Overassessments - IRM 8.7.7
Appeals Tax Exempt and Government Entities - IRM 8.7.8
Joint Committee - IRM 8.7.9
Transferee/Transferor - IRM 8.7.5
Appeals Team Cases - IRM 8.7.11
Innocent Spouse Cases - IRM 25.15.12
These procedures are general in nature and are intended for Appeals Processing Services Tax Examiners (TE)s and Appeals Technical Employees (ATEs). The definition of an ATE can be found in IRM 8.1.1-1, Common Terms Used in Appeals.
References to Examination include the Small Business and Self Employed (SB/SE), Large Business Industry (LB&I) and Tax Exempt and Government Entities (TE/GE) groups.
See Publication 5, Your Appeal Rights and How To Prepare a Protest If You Don't Agree, for information on written protests and "Small Case Requests" in unagreed cases.
Verify the contents of the administrative file to determine if all documents, returns, etc. listed on transmittal Form 3210 were received.
The administrative file must contain the following items:
original or copy of one or more examined tax returns; IRM 188.8.131.52.1.
valid consents extending the statute (if needed);
examining officer's report;
other documents relating to the taxpayer's liability for the year or years involved, such as protests, claims for refund or abatement, and other pertinent documents or papers.
Depending on the type of case, the administrative file may also contain the following collection documents:
financial information;
other documents related to collection action taken on the taxpayer.
Determine the statute date and ensure there are at least 180 days remaining on the statute before accepting the case. See IRM 8.21, Appeals Statute Responsibility, for detailed procedures on statutes and consents.
Once the contents of the administrative file and the statute date are verified, sign the acknowledgment copy of the Form 3210, return it to the originator, and keep a copy in the case file.
When an examination is extended to a year not included in the original assignment, Examination occasionally uses the taxpayer's copy of the return rather than requisition the original return.
Except as noted in (3) below, if the examination is based on the taxpayer's copy, the original return is not required provided a copy of the return and a transcript of account are in the file. If the liability and credits shown on the copy differ from the transcript of account, Examination reconciles the information.
Original returns must be used in the following situations:
fraud cases
delinquent returns
jeopardy assessments
90-day cases
The cases referred to in (3) above may be accepted without the original return if the case file contains an unfilled requisition, a transcript of account, and a copy of the return. However, fraud cases are only accepted under this paragraph if the missing original returns do not seriously weaken the Government's position.
If it becomes necessary for Appeals to issue a notice of deficiency, or if the case develops into one of the other exceptions in (3) above, the original return must be requisitioned through APS.
The administrative files are transmitted to Appeals, along with a full AMDISA for each return reflecting a current AIMS Status of 81, or an AMCLS print for each return.
Update AIMS to Status 80 if the return is non-docketed using IDRS command code AMSTUA.
Verify the statute date on AIMS and, if necessary, update the statute date using IDRS command code AMSTUB.
An IDRS search for TFPRT can be used to secure a print of a return filed electronically. See ADP and IDRS Information, Document 6209, for additional information on TFRPT.
General procedures for APS receipt and control are contained in IRM 8.20.5, Appeals Case Processing Manual - Processing and Establishing New Receipts.
Establish work units on ACDS as follows:
Non-docketed - generally cases that have returns with the same TIN and MFT received at the same time and that are included in an RAR or other tax computation document are one work unit.
Non-TEFRA Flow Through Entity Returns - is a separate work unit.
In situations where multiple cases are assigned to a work unit, the following rules apply:
A work unit must have one case designated as the "key case."
A work unit must have one or more cases designated as the "related case(s)."
Use of key and related cases is most common when establishing petitioning and non-petitioning spouse cases or innocent spouse cases. Card-in multiple case workunits as follows:
the key case, i.e. the joint return
a related case, i.e. the petitioning spouse or the requesting spouse
a related case, i.e., the non-petitioning spouse or the non-requesting spouse
For more information on carding non-petitioning spouse cases, see IRM 8.4.1. For more information on carding innocent spouse cases, see IRM 25.15.12. For information concerning establishing key and related cases for Collection cases, see IRM 8.22, IRM 8.23, IRM 8.24, and IRM 8.25.
The APS TE will validate all critical data fields (CDFs) after establishing the case on ACDS. See IRM Exhibit 8.10.3-3 for the Create Validation critical data fields. Users will have the ability to access the validation screens by using "Search" , selecting a case and choosing the type of validation to be performed.
If the name and TIN on the reference return are the same as those on the case being established, control the reference return at the return level as part of the key case.
If the name and TIN on the reference return are different, establish it as a separate case within the work unit and use the TYPE = REF
In either situation, include the following information:
STATUTE DATE = The actual statute date, if applicable.
STATUTE CODE = If statute is not open, enter RFRTN
Update AIMS to the STATUS 80, if required to be on AIMS. (Reference returns are non-docketed, and must be updated to STATUS 80 even if related to a docketed case in STATUS 82.)
eCase allows for the electronic transfer of specific data fields to Appeals from ERCS (Examination), AOIC (Automated Offer-in Compromise) and ACS (Automated Collection System), and ICS (Integrated Collection System).
The TE who requests the transfer of information from eCase must verify the data and enter additional information when necessary.
After carding in a new receipt on ACDS, the APS TE will complete the Create Case Validation, confirming that all information in the Original Data Field matches the source documents. If any critical data field has an error, the APS TE will:
Change ACDS using the Update CDF fields
Designate the change as a Normal Update (N) or Error Correction (E)
Validate that the information in ACDS is now correct PRIOR to sending the case to the ATM for assignment.
An ATM will not be able to assign a case if it is received without a Create Case Validation. The ATM will receive an error message, and will be prompted to contact their servicing APS unit for assistance.
APS TE's must prepare an ACDS electronic Form 3210 to send a case to the ATM for assignment.
APS must monitor every case that leaves APS whether for assignment, rework, etc. regardless of whether or not they are physically located in the same office.
APS must follow-up on all unacknowledged Form 3210s ten days old or older, utilizing Form 10946 to maintain an audit trail.
For information on what the ATM does with the case upon receipt for assignment, see IRM 1.4.28, Resource Guide for Managers.
Upon receipt, the ATE must determine whether the case is fully developed by the examiner and is ready for Appeals' consideration.
The ATE must validate all critical data fields (CDFs). See IRM 8.10.3-3 for the ATE Assignment Validation critical data fields. Users will have the ability to access the validation screens by using "Search," selecting a case and choosing the type of validation to be performed.
If the case is not fully developed, it may be returned to the originating Field office for further development or other appropriate disposition. The ATE and the ATM will decide whether a non-docketed case is returned to the Field or retained in the ATE's inventory and considered on the basis of what is included in the file. Cases sent back to Examination are called "premature referrals."
The premature referrals with AIMS controls are returned using IDRS command code AMSTUB21
The ATE will prepare a memo Form 5402, Appeals Transmittal and Case Memo, which is approved by the ATM, explains what additional work must be done or what necessary information is missing, and release jurisdiction back to Examination.
APS must return the case and the AIMS controls using IDRS command code AMSTUB21.
A fully developed case has all pertinent evidence fully documented with an easy-to-follow audit trail. Generally, the case contains the evidence needed to support the adjustments proposed in the RAR.
Conduct a preliminary review as soon as possible to determine whether to return the case to the originating Examination function. Determine if the case requires further significant action or could have been disposed of without referral to Appeals, and include an explanatory memorandum citing the reason(s) why the case is being returned and the actions required. ATEs do not act as investigators or examining officers, but are not precluded from requesting additional information or evidence from a taxpayer. However, Appeals will not accept a case if it must obtain substantial additional information or evidence. The following circumstances, which are not all-inclusive, are grounds for returning a case:
substantial additional information is required to resolve an important issue;
significant unresolved factual variances exist between the examination report and the protest;
the protest, when required, fails to set forth the taxpayer's position, lacks substantive detail, or is otherwise seriously deficient, unless the lack of this information does not seriously hamper consideration of the case;
there is a clear misapplication of the law that renders an important issue indefensible;
new issues are discovered, which would be raised under the guidelines stated in policy statement P-8-2 (the grounds for such action is a substantial one and the potential effect upon the tax liability is material); See IRM 220.127.116.11 for additional guidance on raising new issues in Appeals;
contrary to Service practice, the case is a reopening of a previously closed case as set forth in Rev. Proc. 2005-32, 2005-23 IRB 1206;
some action must be taken or some event must occur before Appeals can adequately consider the case. For example, completion of Headquarters consideration of some aspect of the case (e.g., valuation of works of art), or required coordination with appropriate offices within Counsel, or a rebuttal to the taxpayers protest on large team cases;
there is a failure to secure timely consents extending the period of limitation for assessment unless the statute is open for other reasons, e.g., fraud, IRC 6501(e);
claims for abatement of excise tax, employment tax, or trust fund recovery penalty which are not deemed meritorious by the Service;
there is failure to comply with significant requirements of IRM Part 4 or IRM Part 5; e.g., the case should have been held in suspense in Examination pending clarification of Service position; required information was not included in the report or case file, etc.;
technical advice should have been requested or was pending at the time of the referral; or
agreed issues are not fully developed or are technically incorrect and have a material tax effect in a potential Joint Committee case.
If one or more statutes are extended using Special Consent Form 872-A,Form 872-IA, Form 872-0, or Form 872-R, send the taxpayer a completed Form 872-U, Change of IRS Address to Submit Notice of Termination of Special Consent to Extend the Time to Assess Tax. See IRM 8.21.3, Notifying Taxpayer of Change of IRS Address for Termination of Special Consents.
Close unnecessary original returns or files discovered during the preliminary review to the campus or the originating office, as appropriate.
During the preliminary review, the ATE identifies all Compliance Coordinated Issues (CCI), Appeals Coordinated Issues (ACI), Emerging Issues (EI) and International Issues found in IRM 8.7.3, Technical and Procedural Guidelines. It is the responsibility of the ATE to prepare and forward a referral, through their ATM, to Specialty Operations on Form 13381 when the case has any of the following issues:
International Issues (including International Penalty issues)
Compliance Coordinated Issues (CCI)
Appeals Coordinated Issues (ACI) (including category of case)
Emerging Issues (EI)
Referrals of E&G valuation issues with tax of $10 million or more are made in accordance with IRM 8.18.1, Valuation Assistance Procedures.
Refer all TEGE issues, Exempt Plans (EP) issues, Exempt Organizations (EO) issues, Tax Exempt Bonds (TEB) issues and Government Entities (GE) issues, to the Appeals TEGE Team Manager in accordance with IRM 8.7.8, Tax Exempt and Government Entities (TE/GE) Cases.
Generally, the ATM generates and issues Letter 4141 (CG), Uniform Acknowledgment Letter, or other approved UAL substitute (collectively referred to as UALs). See IRM 188.8.131.52, Resource Guide for Managers, Appeals Managers Procedures, for additional information on procedures taken by the ATM.
Within five business days from receipt of a newly assigned case, the ATE must verify that the UAL was generated and issued to the taxpayer. This can be verified by identifying the dated sub-action code "CO-UAL" entry on the case activity record (CAR) as well as locating a copy of the UAL in the case file. Also verify the accuracy of the automatic documentation entries and if differences are noted document the findings on the CAR.
Duplicate letters are not required for joint filers residing at the same address. See IRM 18.104.22.168.
Immediately inform the ATM if the UAL documentation is not on the CAR. The UAL must be generated using the Appeals Generator of Letters and Forms (APGolf) under the signature of the ATM. Document this activity on the Case Activity Record (CAR).
The documented "CO-UAL" entry is considered proof the UAL was issued to the taxpayer.
If at any time it is discovered the taxpayer did not receive the UAL, immediately take steps to provide the taxpayer with the UAL. The date of the letter for time frame compliance purposes is the date the letter was first generated.
The time frame for generating and issuing the UAL is no later than 30 days from the date the case is received in Appeals. There are no exceptions to this time frame for protested Pre-90-Day and protested excise and employment tax cases.
The publications or notices shown as enclosures on the face of the UAL are also identified on the CAR next to the "CO-UAL" sub-action entry. Recording the enclosures sent with the UAL serves as the employee's written explanation of the procedures described in the publications or notices to the taxpayer. For example:
By enclosing You are explaining - Notice 1016, How to Stop Interest on Your Account how to stop interest on a proposed or potential liability. Publication 4227, Welcome to Appeals the Appeals process. Publication 4167, Introduction to Alternative Dispute Resolution post Appeals mediation, fast track settlement, fast track mediation, early referral and arbitration. Publication 4576, Orientation to the Penalty Appeals Process the Appeals process, right to representation, and payment options for penalty appeals cases.
Appeals conferences are informal and intended to promote frank discussion and mutual understanding. Do not consider ideological kinds of arguments.
The ATE must handle cases objectively with the goal of reaching a sound decision based upon the merits of the issues in dispute and not with the attitude that settlements must be obtained. The ATE must be thoroughly prepared for all aspects of a case to maximize the possibility of closing the case with one conference.
Strive to resolve the disputed issues in a quasi-judicial manner. It is essential to have an open mind and genuine interest in working out a mutually acceptable agreement.
Conference techniques vary among cases and representatives, but there is no substitute for preparation, judgment and common sense.
The ATE, taxpayers, and representatives must set realistic target dates for the submission of additional information, proposals and counterproposals of settlement, and understand the need to adhere to them.
Hold conferences on dates and in locations reasonably convenient to taxpayers and representatives. Generally, they are held at Appeals offices, sub-offices, or other IRS-staffed posts of duty that are not temporary or part-time locations. However, managers may approve holding the conferences at other sites when feasible and necessary to provide a convenient conference opportunity. Ordinarily, the amount in dispute is not an important factor in approving another conference site.
Hold the number of conferences to a minimum. A frank discussion of the facts and law ordinarily brings a case to a prompt conclusion.
If a taxpayer indicates, during a phone conference, he or she wishes to consult with a qualified representative or otherwise seek advice, suspend the conference and reschedule. See IRC 7521. If the taxpayer makes the request during a face-to-face conference, the AO and taxpayer can try to complete the conference with the understanding the taxpayer will contact the representative afterwards.
If advisable, Appeals may request representatives of the Examination Area Director, engineering, or other experts to attend conferences. Area Counsel personnel are generally not involved in Appeals conferences but may be present in cases where criminal prosecution is recommended by the Department of Justice and the fraud penalty is contested.
In relatively uncomplicated Pre-90-Day cases, Appeals may request informal assistance from Counsel when advice is needed on the hazards of litigation, interpretation of the law, and/or evaluation of the evidence. This assistance is provided through informal arrangements between operating unit counterparts in Counsel and Appeals. This informal procedure is not intended to take the place of, or alter in any way, Technical Advice procedures.
In large dollar and/or complex cases, Appeals may request the cases be informally considered by Counsel. In addition, Counsel may be asked to attend settlement conferences. Counsel involvement must not violate any prohibitions against ex parte communications. See Rev. Proc. 2012-18. Counsel cooperates in providing this assistance as long as resources and workloads permit.
With regard to both paragraphs (1) and (2), Counsel acts solely as an advisor and/or consultant and does not assume authority for the disposition of the case.
If information is presented for the first time during the Appeals conference, and that information substantiates a deduction or shows the source of revenue, etc. and is used to support your conclusion, include a description of the information received in the Appeals Case Memorandum (ACM). If necessary, include originals or photocopies of the documents in the case file.
The ATE will review any additional evidence provided by the taxpayer during the consideration of a case.
If the new information or documentation is significant, you must give Examination the opportunity to timely review and comment. "Significant new information" is information of a non-routine nature which, in the judgment of the ATE, has an impact on the examiner's findings or changes the ATE's evaluation of the litigating hazards.
When it appears the new information or documentation was purposely withheld from the originating office, release jurisdiction and return the entire case to the originator.
If the new information was not purposely withheld from the examiner and it relates to issues raised in the Revenue Agent's Report (RAR), consider retaining jurisdiction of the case and refer only the new issues or information to Examination for review and comment. Always provide Examination with your expected response due date
Where the taxpayer or representative offers to make payment of additional tax liability for slush fund or improper payment deductions, or reveals their existence to Appeals officials for the first time, discontinue Appeals consideration of the case. Return the case to Examination for appropriate action.
Create a Schedule of Adjustment to identify the needed adjustments
Generate Form 3608, Request for Tax Computation Specialist (TCS) Service, from APGolf.
Boxes 1 through 6 - Populated with information from ACDS, when available
Box 7 - Mandatory Entry. If Other include a brief description of the type of work requested.
Box 8 - To be completed only when Priority Consideration is requested.
Box 9 - Complete as applicable
Box 10 - Identify the disposition of the case/issue.
Box 11 - Completed by the ATCTM
Box 12 - For use only if there are supplemental instructions to the Schedule of Adjustments
Use secure e-mail to send Form 3608 and the Schedule of Adjustments to the designated Appeals Tax Computation Team Manager (ATCTM).
If there is no access to APGolf, complete the Form 3608 available on the TCS web site.
If a situation arises when an immediate computation is needed, the AO may take the computation request to a local TCS to prepare the computation. The AO must send a concurrent e-mail to the ATCTM.
The ATCTM will determine the grade of the case and assign it using the TACS program on ACDS. For additional information on the procedures taken by the ATCTM, see IRM 1.4.28, Resource Guide for Managers.
The ATCTM notifies the requester which TCS will work the case. The employee requesting the work, generally the AO, has responsibility for delivering the case to the assigned TCS.
This subsection covers actions taken by an ATE after carefully considering and discussing facts, law and arguments of the case with the taxpayer and either reaching a basis of settlement or determining there is no mutually acceptable basis for settlement.
When the case is agreed, discuss the conclusion with the taxpayer to ensure they have a complete understanding of the effects of the settlement.
For example, where allowance of a net operating loss deduction reduces or eliminates a potential deficiency, advise the taxpayer that interest will be assessed on the potential deficiency. Where desirable or advisable the taxpayer may also be advised in writing.
When the case is unagreed, explain the following to the taxpayer.
the evaluation of the case
additional action to be taken
taxpayer's rights
Unagreed case dispositions generally fall into three categories.
Pre-90-day case disposition with a deficiency (defined in IRC 6211). A statutory notice of deficiency is issued to dispose of the income tax (subtitle A), estate and gift tax (subtitle B), or excise tax (chapter 41, 42, 43 or 44 of subtitle D) case. The tax can be litigated in Tax Court.
Pre-90-day case disposition without a deficiency. A statutory notice of deficiency is not issued to dispose of the case because there is nothing (no deficiency) to litigate in Tax Court.
Protested excise tax (subtitle D other than chapter 41, 42, 43 or 44) or protested employment tax (subtitle C) case disposition. A statutory notice of deficiency is not issued in order to dispose of the case because these taxes cannot be litigated in Tax Court. See IRC 4.23.16.
See IRM 8.17.4, Settlement Computations and Statutory Notices of Deficiency, Notices of Deficiency, for details on preparing a statutory notice of deficiency in an unagreed case.
The conclusion in the case is set forth in Form 5402, Appeals Transmittal and Case Memorandum, accompanied by a settlement computation (sometimes called an audit statement). Preparation of an Appeals Case Memorandum (ACM) is discussed in IRM 8.6.2, Conference and Settlement Procedures, Appeals Case Memo Procedures, and preparation of a settlement computation is discussed in IRM 8.17.2, General Settlement and Rule 155 Computations.
When agreement is reached, the ATE will send an agreement letter, i.e. Letter 969, and enclose an agreement form and in most instances, the settlement computation. When the agreement letter used does not contain a stated interest amount, there is no requirement to include an interest computation. However if the agreement letter used, i.e. Letter 969 w/Interest, includes a stated interest amount, a detailed computation of interest must be included.
IRM 8.6.4, Conference and Settlement Procedures, Reaching Settlement and Securing an Appeals Agreement Form, includes additional information concerning soliciting agreement forms.
Actively encourage the taxpayer to pay any deficiency in full. If the taxpayer indicates they are unable to pay, discuss alternatives to full payment such as installment agreements or offers-in-compromise.
Prepare the appropriate closing letter to be sent out after the reviewing official accepts the settlement proposal.
See subsections below for information on acceptance and rejection of the settlement proposal by the reviewing officials
Form and pattern letters for use as agreement letters and closing letters are contained in ACDS under APGolf (Appeals Generator of Letters and Forms).
If the taxpayer disagrees with a settlement that is approved by the ATM or other reviewing official the taxpayer is not entitled to a conference with the reviewing official.
When a reviewing official rejects a settlement proposal and determines it should be more favorable to the government, the reviewing official will discuss the case with the ATE. The discussion will include the facts, law and argument the ATE considered in reaching his/her conclusion, and the position of the reviewing official. In these instances, the taxpayer has a right to a conference with either the ATE or the reviewing official.
In instances where the reviewing official rejects the ATE's settlement proposal and determines it should be more favorable to the taxpayer, the taxpayer is not entitled to a conference; however, a conference may be granted in order to close the case.
When the ATE accepts the reviewing official's position or when a compromise is reached, the ATE will contact the taxpayer to discuss the status of the case, the reason(s) for the change in the settlement, and their right to a conference with the ATE or the reviewing official.
If requested, the ATE will hold the conference and secures all revised tax computations and agreement documents reflecting the new settlement.
The ATE will maintain inventory control of the case including monitoring the statute, preparing the case for final closing, etc.
The ATE will prepare a revised ACM with the revised settlement and processes the case through normal closing procedures.
If the ATE does not accept the reviewing official's position, the ATE will prepare a rebuttal against making the change, that clearly states the ATE's position.
The reviewing official will:
contact the taxpayer, advise them of the right to a conference, and grants and holds the conference once a written request is received
discuss the new settlement and the outcome of any conference with the ATE
prepare an addendum to the ATE's original ACM with the facts, law and argument detailing the new settlement position, the reason(s) why the case was rejected and the outcome of the conference
make the appropriate entries of his/her actions on the ATE's Case Activity Record.
The ATE will secure all required tax computations and agreement documents reflecting the new settlement position.
The ATE will maintain inventory control of the case at all times, including monitoring the statute, preparing the case for final closure, etc.
The ATE will assemble the administrative file in chronological order and include all documents necessary for APS to close the case.
For detailed information covering the procedures taken by the ATM when the case is submitted for closing by the AO, see IRM 1.4.28, Resource Guide for Managers.
After the ATM completes the "Closing Cases" on ACDS and inputs an ACAP date, the case information automatically goes to the PEAS Unassigned box.
The ATM either walks the case into APS or mails it to the appropriate APS office.
Appeals will expedite the closing of a certain "agreed and unpaid deficiency" or overpayment case, if the case meets the "large dollar" criteria described in IRM 4.4.18, Large Dollar Cases. This guidance does not apply to a deficiency and/or overpayment case that requires Joint Committee Review. See IRM 126.96.36.199.
A case meets the large dollar criteria, if the total amount of a period's "agreed and unpaid deficiency" plus penalties (or overpayment plus penalties) exceeds $100,000.
Expedite processing is required to accomplish the following:
To avoid the unnecessary accrual of overpayment interest under IRC 6611 for "large dollar" cases.
To avoid the unnecessary suspension of deficiency interest in respect to "large dollar" income, estate, gift, and/or certain excise taxes. IRC 6601(c) requires an interest suspension if notice and demand is not made within 30 days of the filing of a waiver of restriction on the assessment.
Interest is suspended if notice and demand is not made within 30 days of IRS' receipt of a Form 870 type agreement. If the case involves a Form 870-AD type agreement, interest is suspended if notice and demand is not made within 30 days of the execution (by the ATM or ATCL) of the special agreement form. See IRM 220.127.116.11. Agreement Forms Secured in Appeals Cases. Also, see IRM 8.7.10 to identify the excise taxes that require deficiency procedures.
The following procedures apply for expediting certain "large dollar" cases:
The ATE will identify and "flag" the case for expedite closing, by attaching any "expedite sticker, note, or tag" that contains a notation similar to the following:" $100,000 Agreed and Unpaid Deficiency" and/or "$100,000 overpayment" . The ATE will include a similar notation on Form 5402. The AO will close the case within five (5) calendar days of Appeals' receipt of the waiver form. The ATCL will close the case within ten (10) calendar days of the receipt of a Form 870 type agreement or within 10 days of the execution of a Form 870-AD type special agreement. The ATE should include an explanation for the delay (if any) on the case activity record (CAR).
The ATM will ensure that the case is properly "flagged" for expedite processing. The ATM will close the case to APS within 10 days of the Appeals' receipt of the waiver form.
IRM 8.20.7, General Case Closings Requiring Special Actions, covers some of the specialized issues that may arise when closing cases. The following is a list of those issues along with a link:
Carrybacks - Deficiency from Adjustment, IRM 188.8.131.52
Conversions, IRM 220.127.116.11
Department of Justice Cases, IRM 22.214.171.124
Earned Income Credit, IRM 18.104.22.168
Non-filer Returns Closed by Appeals - Delinquent Returns; Substitute for Return Cases, IRM 22.214.171.124
Non-Master File Processing, IRM 188.8.131.52
Non-petitioning Spouse - Assessed on MFT; Assessed on NMF; NOT Assessed Previously, IRM 126.96.36.199
Premature Referrals or Improper Referrals - Jurisdiction Released; Jurisdiction Not Released, IRM 18.104.22.168
Transfer of Work Units Between Areas, IRM 22.214.171.124
This section contains the procedures for APS and the general processing of a pre-90-day case and related returns and the expedited processing of certain large dollar cases.
Arrange the administrative file to be sure it includes all returns, documents, and other papers which were in the case file when it was received plus any returns and papers added while Appeals had the case. Remove all documents from the left side of the case file since that is usually torn from the file once it gets to the Campus.
Arrange the contents chronologically (date order).
Complete Form 5403. See IRM Exhibit 8.20.7-1 for instructions on completing Form 5403.
If there are two or more agreements on the case, see IRM 126.96.36.199, Form 5403 When There Are Two Agreements.
Form 2285. Form 2285 is needed for cases involving carry backs to prior years and on some cases where the IDRS modules are restricted (with Transaction Code 340). The TCS function completes the top portion of the form, and APS is responsible for completing the bottom half. However, since DMI is now used to recompute the module, APS rarely uses this part of the form.
Remove duplicate material intended for retention by Appeals.
Verify the agreement form, settlement computation and Form 5403 all have the same:
tax period
Date and verify signatures on Form 5402.
Ensure there are sufficient copies of Form 5402 or other transmittal, and mark each copy for transmittal to the designated persons. Follow local office procedures for distribution. Generally the distribution of the Form 5402 is:
original Form 5402 remains in the administrative file
copy of Form 5402 is returned to the office that originally worked the case (Examination, Collection, EP, EO). If the case is an employment tax case that originated in Collection, send the copy directly to the Employment Tax Examination (ETE) Coordinator, Collection, for your respective local office.
Follow local procedures for Campus cases.
Place all tax returns in the administrative file. Where local procedures apply, attach an assessment label to the return showing the amount of the deficiency or overassessment.
Follow local office procedures for forwarding a copy of the return and the settlement computation to the State Tax Office. The Disclosure Office has information on the agreement reached between the State agency and the IRS.
If it is local procedure to use Form 5403 or Form 5570 as a follow-up control, place of copy of the form in the follow-up file.
APS will assign the case on PEAS for expedite processing, in the case of a large dollar "agreed and unpaid deficiency" or overpayment. APS will identify the number of days remaining on the 30-day period for assessing the deficiency to avoid an unnecessary suspension of interest. A quick assessment is required for an agreed deficiency in excess of $100,000
Returns associated with protested or petitioned cases for information purposes only (no proposed dollar adjustment), are "reference" returns. These reference returns include Form 1120-S and Form 1065.
Reference returns are controlled on AIMS in status 80.
Although reference returns controlled on AIMS are generally in status 80, there may be older inventory still in status 86 which may (other than return Form 1120-S and Form 1065) be closed using Form 5570, Appeals Short Closings. All non-taxable returns Form 1120–S and Form 1065 must be closed using Form 5403 in order to provide information in Items 802/805 on the Form 5403.
If Examination closes the reference returns on AIMS prior to sending the case to Appeals, APS will request the AIMS database from Examination.
Close reference returns from ACDS using CLOSINGCD 45.
Select "Close All Cases in WUNO" . However, if all cases in the work unit are not being closed, select "Closings Update."
Select the case to be closed.
Update the following fields if they are active (not greyed out)
Pre-90 (non–docketed) Closing Codes Closing Code Description 03 Agreed Pre-Ninety 04 a) Agreed Notice of Deficiency
b) non-filer case where the agreement constitutes the delinquent return
05 Defaulted Notice or Determination letter 14 Campus Claim Fully Disallowed/Penalty Appeal Fully Sustained 15 Campus Claim Fully Allowed/Penalty Appeal Fully Abated 16 Campus Claim Partially Allowed/Penalty Appeals Partially Abated 20 Premature Referral 30 Transfer 40 Re-assignment 45 Reference return closing (TYPE = REF) 98 Reject Corrected and closed 99 Case removed (erroneously established on ACDS)
DATECLSD – Date case is closed
ACAPDATE – Date ATM or Appeals Team Case Leader (ATCL) approved case (signed 5402).
TODATE – Date case is closed
FROMDATE – With the exception of premature referrals, the Tax Examiner (TE) does the final closing (assessment) on Pre-90-Day income tax cases so input the FROMDATE and the TODATE at the same time.
STATDATE – statute date
CODE – statute code
P – Paycode (See table below)
Pay Code Explanation 1 Full Paid 2 No payment made and payment was required 3 Partially paid 4 Installment agreement received with payment 5 Installment agreement received without payment 6 Offer in Compromise received from a taxpayer instead of a payment. The offer doesn't have to be accepted, only received. Paycode 6 is never used when closing an OIC case. 7 Payment not applicable (no change, OIC, ABINT, overassessment, etc. Note #1 Payment codes are entered with closing codes 3 through 19. Record whether Appeals received a payment for the tax period and the type of payment. A case is considered fully paid if the tax, penalties, and interest have all been paid in full. A case is not considered fully paid unless interest computed on the penalties is also paid. Note #2 If Appeals receives a payment within 90 days of closing the case, correct ACDS and AIMS. Use AMAXUA to update AIMS. If payment is received more than 90 days after the case is closed, no corrections are made.
RevsdTax– revised tax
Revsdpen – revised penalty
DD AMTDIS – amount of claim disallowed (claim received from Examination)
APPEALS AMTDIS – amount of claim disallowed (claim received from a Campus or directly from a taxpayer)
Select Submit Return
Select "Quit" to close another case or select "Return to Main Menu"
After the TE updates the case for Closing, a Closing Validation will be required. The TE will be prompted to confirm that all original and updated data fields match the source documents. If the ACDS data is correct, the TE will select "Validate" from the screen menu and submit. ACDS will be updated in "real time." The TE will transmit the file to Collection, Exam, etc. using local guidelines.
Update FROMDATE when receipt of case is acknowledged.
Below is a list of forms prepared in different cases but not necessarily in every case. The following guidance is provided for handling these forms.
Agreement Forms with AD Extensions ( Form 870-AD, Form 2504-AD, etc.) – Send a copy of the agreement form to the taxpayer with the closing letter. Fasten the original agreement to the administrative file. Keep a copy in the closed file.
Form 5403 - Attach Form 5403, the Form 5403 Worksheet , and the IDRS transcripts on top of the fastened material in the administrative file.
Form 2285 (for Restricted Interest) - Attach original form to reverse side of the front page of return. Keep a copy including all the computations, including the DMI interest computation, in the closed office file.
Form 1331 or Form 1331-B, Notice of Adjustment - Attach the original to Form 5403. Keep a copy in the closed office file.
Form 885-F, Self-Employment Tax Adjustment - Attach behind the return or to the face of the return.
Form 885-T, Adjustment of Social Security Tax on Tip Income Not Reported to Employer - Attach behind the return.
Form 6674, Statistical Sampling Examination Report - AO and the ATM complete Part III. Attach one copy of the Form 6674 to the ACM and return it to Exam. The other copy remains in the closed file for local use.
Form 866 and Form 906 (Closing Agreements) - Attach a copy of the closing agreement to each return. Include a copy with the closing letter. Keep a copy in the closed office file. Send a copy to Examination for follow-up, if noted on Form 5402.
A closing letter is sent to notify taxpayers Appeals has taken final closing actions on their case. At the time of closing, date the closing letter addressed to the taxpayer and distribute it as follows:
Mail the original and one copy to the taxpayer and/or representative as indicated on the Power of Attorney. If there is no Power of Attorney, mail the original to the taxpayer.
Fasten one copy in the administrative file.
If the statute is open under a Form 872-Aand the return is closed no-change, prepare a Form 872-T and send it to the taxpayer with the closing letter.
Exercise caution prior to sending a Form 872-T on a no change case. You must ensure carryback years with statutes controlled by the originating year Form 872-A are protected or assessed. The statute date for any carryback returns open under an originating year Form 872-A is 90 days from the date Form 872-T is mailed.
In cases where the examiner elected to use a computer to create electronic work papers, RAR, etc., follow local procedures regarding the disposition of the disk. This may include:
Returning the disk to Examination for recycling.
Recycling the disk in Appeals.
Appeals will make no changes to the original data disk. If a case is returned to Examination for further development, include the original data disk in the case file.
APS will maintain original closing agreements as required by IRM 8.13.1.
For each tax period with a Balance Due of $10 Million or more, including interest and penalty, APS must follow the procedures in Examining Process - AIMS Procedures and Processing Instructions - Large Dollar CasesIRM 188.8.131.52 and send a copy of the following forms to the CFO's office:
Form 5402
Settlement Computation
Agreement or Decision Document
Form 2859
Any special instructions


text:
Madison Area Technical College students can take Air Force ROTC courses at UW-Madison under an agreement signed Friday by campus officials.
Previously, MATC students had to transfer to UW-Madison before they could enroll in Air Force ROTC. That made it difficult for them to complete officer training, which takes three years.
The agreement will allow MATC students to pursue officer status in the Air Force and compete for scholarships.


text:
Cooking and Baking
Calling out to all of you tart lovers
I need a great easy tart crust recipe. Its not a sweet crust. Any help would be great.
Talk is closed, but that doesn't mean the conversations have to stop!
Check out this post for a more thorough explanation, and jump onto our Facebook page or our Twitter feed to keep the conversations going!


text:
Martinez, who spent the last two years in charge of Levante, takes over the reins from Miroslav Djukic who stepped down as Valladolid coach at the end of last season before joining Valencia.
A statement on the club's website read: "The club and the new coach have reached an agreement for 'JIM', as he has recently become known in the football world, to be in charge of the first team for the next two seasons, with the option of a third."
The 48-year-old Martinez will be presented at Valladolid's Jose Zorrilla stadium on Tuesday morning.
Valladolid finished 14th in the Primera Division standings last season having been promoted back to the top flight the previous season under Djukic.


text:
This item has been discontinued and is no longer available
Ordering for a Team?
Let our Team Division Help!
Item has a Minimum Qty
NEW!Now you can comment & reply on customer reviews. Simply click "comment" below any review.
They are a very comfortable pair of shoes
Fletcher, NC
Fit: Feels true to size
Report abuse
Your comment has been posted.
These casual cruiser shoes were very nice. but were too small.. I gave them to my sister and she loves them. A good slip on and go shoe..
Fit: Feels too small
Cute and cumfy, just a little to big
I needed a white pair of slip on shoes and thought these could be the ones, little disappointed. There were a little big, they don't slip off or anything but my feet have a little to much room inside.
Monica S.
Sacramento, CA
Fit: Feels too big
Good slip-ons for casual errands
I keep these by my door because I'm usually barefoot in the house. Very handy and comfy.
Susan M.
CA Desert
Liked the "broken in" look
I usually wear an 8 womens but I will be returning these for an 8.5 if they have half sizes. Liked the "broken in" look and feel of the canvas.Light weight and perfect to wear when I need a little more foot coverage than flip flops.
New York
Get an alert when we add new styles of Roxy! Simply sign up and we'll notify you.
Realizing there was a largely untapped women's surf market in the 1990s, Quiksilver™ developed Roxy™, a line completely dedicated to the women. Roxy was the first brand of its kind, and is credited with being the first to create the women's board short, which quickly became a staple of female surfers everywhere. Now Roxy wetsuits, Roxy rashguards and Roxy swimsuits are the stylish and sleek way to dress when you hit the beach.
Roxy is for women and teens that want swimsuits for both fashion and sporty endurance. Roxy has the pros covered with top-of-the-line Roxy wetsuits, surf booties and board shorts. The Roxy rashguards have a great cut, look and color wheel so you get to stand out against all of the grey. And when you get out of the water, Roxy is there with beautiful dresses, hoodies, tops, pants and shoes. Feel free to keep your change of Roxy clothes in you cute Roxy tote or duffle bag. Roxy thought of everything to keep women and girls looking their best in a beachy environment.
Roxy's lines are created under the mantra of "daring, confident, naturally beautiful, fun, alive" giving its customers an exciting variety of top-notch products. Roxy is there to provide colorful, flattering and supportive options for women, girls and even the youngest future surfers in the Roxy Teenie Wahine line. Now mothers and daughters, or sisters can match and both look fabulous while they have fun.


text:
Hundreds of unique traditional and contemporary Star of David necklaces by top Israeli artists. Makes the perfect gift for a wedding, birthday, Bat Mitzvah, or any special occasion.
The Dead Sea Scrolls are among the most important archaeological treasures ever found in the Holy Land.
Whether you're looking for a classic wool tallit, a modern tallit, or even highly fashionable artistic tallit, you will find what you're looking for here!
This gorgeous wall hanging features the Biblical verse from King David's wisdom, Im eshkachech Yerushalayim, tishkach yemini ("If I forget you, O Jerusalem, may my right hand forget itself.") (Psalms 137:5). A beautiful prayer for our times, and a wonderful gift for anybody.
Beautify your home with a breathtaking work of Jewish art! David Fisher's internationally acclaimed masterpieces combine the modern craft of laser cutting technology with a passion for tradition. Guaranteed to transform your walls into a source of meaning and joy.
Covered in highly embossed leatherette, with the page edges painted in gold leaf, the book is a beautiful as it is practical. This book, intended for the entire family, features an array of blessings, dedications, prayers, and hymns for the Sabbath and holidays.
This new treasury of Sabbath favourites will earn an honored place in your home.
The incredible story of Israel's rebirth - this landmark series is the masterpiece of Israeli documentaries and the crowning achievement of Israeli television.
Show your support for the strong alliance of America and Israel, who share the role as the world leading representatives of the values of freedom, democracy and human rights.
This is one of the most unforgettable tastes of Israel. Turkish coffee, popularly and affectionately called "mud" in Israel, is the strong (usually sweet) drink served at coffee houses throughout the Middle East.
Castel Grand Vin - Castel's premium red wine. It is made from a selection of the best vineyards. It is a blend of 70% Cabernet Sauvignon, 22% Merlot and 8% Petit Verdot, Cabernet Franc and Malbec.
This beautiful seven-branched menorah is modeled after the golden menorah that once stood in the Holy Temple of Jerusalem.
The centerpiece of the Passover Seder, the Seder plate holds various ritual Seder items. Choose from a wide variety of elegant traditional designs, including historical replicas, or go for a more modern design by one of Israel's top contemporary artisans. An instant conversation starter!
This wonderful gift set comes beautifully packaged with four special treatments for the body and senses from AHAVA Dead Sea cosmetics!
The beautiful ceremony marking the end of the Sabbath can be made even better with a beautiful Havdallah set! As the Sabbath departs, a time-honored Jewish ritual bids it farewell and welcomes the coming week with wine, aromatic spices (besamim), and a multi-wick Havdallah candle.
Displaying items 1 - 24 of 58
Best Sellers
By Name (A -> Z)
By Name (Z -> A)
By Price (Low to High)
By Price (High to Low)
By Manufacturer (A -> Z)
By Manufacturer (Z -> A)
List Price $9.95Your price $5.99
List Price $15.95Your price $10.95
Your price$6.95
List Price $50.00Your price $39.95
List Price $99.00Your price $69.99
List Price $17.00Your price $9.99
List Price $120.00Your price $79.99
List Price $16.95Your price $12.95
List Price $119.00Your price $79.99
List Price $149.00Your price $89.95
List Price $149.00Your price $89.99
List Price $17.00Your price $11.95
List Price $24.99Your price $14.99
List Price $120.00Your price $89.95
List Price $140.00Your price $89.99
List Price $299.00Your price $269.00
List Price $60.00Your price $39.99
List Price $70.00Your price $49.99
List Price $240.00Your price $199.00
List Price $59.95Your price $49.95
List Price $135.00Your price $89.99
Follow Us On:
Owned by JWG Ltd, maintains its offices and warehouse in Jerusalem, Israel.
© 1999-2012 JWG Judaica and Dead Sea Cosmetics


text:
TAMPA, FLORIDA (WFTS) – Authorities are looking for four men who beat up a young soldier as he was walking home after his car broke down in South Tampa.
Police said it started Wednesday with an unexpected punch that knocked the MacDill-based soldier to the ground.
That's when four men unleashed a relentless beating on Johnny Aparicio, punching and kicking him during a nearly minute-long attack.
A neighbor glimpsed a very injured Aparicio, after he managed to pull himself to his feet, long enough to knock on her family's door for help.
"He was bloodied and he was beaten and he was really upset and hurt," said the woman. "He had a really bad contusion on his face, possibly even a fracture."
Tampa police are reviewing the video captured by a motion detection camera at a neighborhood home.
Tampa Police Department's Lt. Mary O'Connor said the incident was one of the more vicious attacks she's ever come across.
To complicate matters further, the assailants were all wearing hoodies, which concealed the faces of every attacker.
Pat Chumley, who manages the complex Aparicio was trying to get to when he was attacked, said he has only lived there for a month.
She has watched the video of the beating that put her tenant in the hospital and hopes it will lead to arrests.
"I'm just glad somebody was able to catch it on tape," said Chumley. "Hopefully they can recognize somebody that's there."


text:
|Blurbarian Since
|February 2008
|Business Name
|Alexis Clark Photography
|Business Web Site
|Business Phone Number
|About My Business
I am a Brisbane based photographer who specialises in Portraits, Wedding and Events.
I love the idea that the photos i take today will become tomorrows family heirlooms and have a great passion for making photo books.
|Areas of Expertise
|Photography,Custom layouts, Colour Matching,Design, Restoring photos, scanning, tailoring the books to your needs.
|Professional Affiliations
Dipolma of Professional Photography
|Nov 24, 2010 12:00
|HELP!!! Importing previous book is no...
|i have this problem now, how do i fix...


text:
Texas on the Potomac
Washington news with a Texas accent
Posts filtered on Tag
A prominent GOP supporter of assault weapons ban, background checks? It's George W. Bush
There's a Texas Republican who vocally stated that he supported background checks to keep guns away from those who shouldn't have them. And an assault weapons ban. Don't believe it? Former President George W. Bush said he supported background checks during the 2000 and 2004 presidential debates. Check out the video proof posted by […] [Read More]
NRA offers plan to arm, train school personnel
A National Rifle Association task force on Tuesday recommended a training program to help arm school personnel as a way of preventing a repeat of the Sandy Hook Elementary School shooting that took 26 lives in Newtown, Conn. [Read More]
The Top Ten: Rick Perry's not quite dead (politically). Hugo Chavez is.
Every week Texas on the Potomac gives you a second glimpse of our most popular stories. Here are the stories that you viewed the most for the week ending March 9. 1. Stockman deletes tweet joking Koch brothers instigated Chavez's cancer. The conservative lawmaker's twitter account poked fun at the Venezuelan leader's death, though a […] [Read More]
The Top Ten: Sheila Jackson Lee v. Antonin Scalia
Every week, Texas on the Potomac gives you a second glimpse of our most popular stories from last week. Here are our 10 most viewed stories. 1. Sheila Jackson Lee slams Scalia's 'racial entitlements' remark on Voting Rights Act: The Houston representative defended a Voting Rights Act section that required states with a history of […] [Read More]
Gun it! 'NRA 500′ to come to Texas Motor Speedway this April
It's a match made in conservative political heaven: NASCAR and the NRA. Two well-known national brand names with overwhelmingly conservative and Republican followings are teaming up for a race that is not political (as in an election). After years of partnering with the racetrack, the NRA will become the newest title sponsor for this April's NASCAR Sprint […] [Read More]
The NRA, unvarnished
The National Rifle Association has more in common with the White House and Congress than you think. Its switchboard has been overwhelmed since the Dec. 14 massacre at Newtown's Sandy Hook Elementary School. So much so that the organization's lobbyi… [Read More]
Is NASCAR taking a different kind of left turn … on guns?
Michael Waltrip will be the sentimental favorite in Sunday's running of the Daytona 500 for Connecticut. The two-time winner of the "Great American Race" will be driving the No. 26 car as a tribute to the 26 victims of the Sandy Hook Hook Element… [Read More]
Ted Cruz to be closing speaker at CPAC conference packed with conservative stars
Freshman senator Ted Cruz has created buzz throughout the halls of Capitol Hill ever since the 113th Congress convened on Jan. 3. And the conservative movement has taken notice. The American Conservative Union announced Thursday the Texas senator will be the closing speaker at next month's Conservative Political Action Conference, America's largest annual gathering of […] [Read More]
Show More


text:
JP Grace: What should be done about gun violence?
Goldie Taylor, a journalist and commentator on MSNBC-TV who divides her time between New York and Atlanta, has given up her gun.
She so announced on the Sunday morning MSNBC talk show "Up with Chris Hayes" as she, Hayes and a panel of other journalists were mulling over the Newtown, Conn., massacre of 20 first- and second-grade children and eight adults.
The victims included the shooter, Adam Lanza, who committed suicide after first killing his mother, Nancy, at home, then barging into the Sandy Hook Elementary School and carrying out unspeakable mayhem with an AR-15 semi-automatic rifle and two Glock semi-automatic pistols.
The Newtown shootings clearly were the catalyst for Ms. Taylor's decision to disarm herself voluntarily. However, she cited troubling statistics as the broader context for what many gun owners would surely describe as "a radical move" on her part.
Those stats show that handguns purchased for self-defense and kept at home are far more likely to be used to fire upon family members, friends or neighbors, or else heisted by minors and turned to criminal purposes, such as the Lanza affair, rather than used against intruders.
Police in Newtown said that all three guns employed by Adam Lanza in the massacre had been purchased legally -- by his mother.
Poignant also -- and seldom talked about -- is the reality that of the roughly 30,000 deaths by gunshot recorded in our country annually, more than half are suicides. It's impossible to know, of course, whether those who took their own lives by putting a bullet into their head or heart would have had recourse to pills or to jumping from a building if a gun had not been available.
The fact remains, in any case, that the United States of America ranks among the most violent countries in the First (or industrialized) World, especially for homicide by gunshot. Here are a few comparisons:
From the UK Guardian newspaper, for 2007, is a listing by country of total gun homicides and of gun homicides as a rate per 100,000 population:
Canada, 173, 0.51.
France, 35, 0.06
Germany, 158, 0.19
Israel, 6, 0.09
Japan, 11, 0.01
England, 41, 0.07
South Africa, 8,319, 7.03
An author and blogger named Juan Cole -- whose blog is titled "Informed Consent" -- had this comment:
"Americans are so brutalized by gun violence that they don't know what it is to live in a low-murder society. They are in with the South Africans and the Mexicans."
What do I think personally? I've already said (in a column published here 8/7/2012), but I'm happy to restate my thoughts:
All gun sales should include a background check on the purchaser and a five-day waiting period.
Gun shows should be outlawed, as well as private (one-to-one) sales with no background check.
Training should be mandated in the use of whatever firearms are purchased. This should include precautions to assure that guns at home are safely locked away out of the reach of minor children.
More needs to be done to flag aberrant or suspicious behavior that could indicate suicidal or homicidal ideation. People who pass a certain threshold of instability -- and I realize that that point may be difficult to determine -- should not be allowed to have access to guns.
The ban on purchase of semi-automatic and automatic weapons, which Congress let lapse in 2004, should be restored.
John Patrick Grace was formerly a reporter, editor and foreign correspondent for The Associated Press. He also lived in France, a low-gun-homicide country, for nine years, teaching at the university level. He is now a book editor and publisher based in Huntington.
The Herald-Dispatch welcomes your comments on this article, but please be civil. Avoid profanity, obscenity, personal attacks, accusations of criminal activity, name-calling or insults to the other posters. Herald-dispatch.com does not control or monitor comments as they are posted, but if you find a comment offensive or uncivil, hover your mouse over the comment and click the X that appears in the upper right of the comment. If you do not want your comment to post to your personal Facebook page, uncheck the box below the comment.


text:
Was $59.95 NOW $9.95
Made from a fabric with a bonded-in bug repellent, this is the camp shirt with protective mosquito netting that extends from its short sleeves to also cover the arms. EPA-registered permethrin is bound to the entire shirt's lightweight, wrinkle-resistant cotton, resulting in wearable, odorless protection against mosquitoes, ticks, ants, flies, chiggers, and no-see-ums. When more protection is required, netting secured by hook-and-loop fasteners within the cuffs of the short sleeves deploys to cover both arms. Besides fending off biting insects, the shirt's moisture-wicking properties help you stay cool. With two front chest pockets, and a buttoned front closure. The insect repellent maintains its effectiveness for 70 machine washings. Olive. Sizes M (40-42"), L (43-45"), and XL (46-48"). (6 oz.)
Lifetime Guarantee
The Mosquito Thwarting Camp Shirt comes with The Hammacher Schlemmer Lifetime Guarantee at no additional charge. If this product ever disappoints you, for any reason, you may return your Hammacher Schlemmer purchase for exchange, credit, or refund.Should you have any questions, we are available 24 hours a day, seven days a week. Please call 1-800-321-1484 to speak with a product specialist or email us at firstname.lastname@example.com to receive a response within one hour.
Sale item quantities are limited — please order soon.
May we recommend:
(based on 4 reviews)
Ratings Distribution
5 Stars
4 Stars
3 Stars
2 Stars
1 Stars
of respondents would recommend this to a friend.
Best Uses
Feels too small
Feels true to size
75% (3 reviews)
(3 reviews)
Feels too large
Reviewed by 4 customers
Sort by
Displaying reviews 1-4
Back to top
(1 of 1 customers found this review helpful)
Unique Design
By Mighty Mallard
from Columbia, SC
This will be a big help working in the yard on those SC summer evenings.
Bottom Line Yes, I would recommend this to a friend
Was this review helpful? Yes / No
- flag this review
Share this Review
The Mosquito Thwarting Camp Shirt: great for outdoors
By Mom of Teenage Boy Scout
from Raleigh NC
Bought this shirt for teenager's summer backpacking trip. Ended up using it myself for gardening--NC is hot. Our native mosquitos mostly fed at dawn & dusk, but recent accidental import, the Tiger mosquito, feeds all day. Shirt Washes easily & dries quickly. No sticky, smelly bug spray.Cool mesh sleeves.
good coverage
By ck
from hicksville, NY
Good protection. Know that the shirt runs about a full size smaller.
(0 of 1 customers found this review helpful)
Not what I expected
By Mosquito Magnet
from Greenville, NC
The shirt needs elastic at the end of the sleeves to fit snugly around the wrists and avoid bugs crawling or flying up into the mesh. I was disappointed that the fit was not snug.
Bottom Line No, I would not recommend this to a friend
COPYRIGHT © 2015 HAMMACHER SCHLEMMER & COMPANY, INC. ALL RIGHTS RESERVED. W102HAMMACHER SCHLEMMER • 147 E. 57th ST • NEW YORK, NY • 10022 • 1-800-_321-1484


text:
S K Printing
7550 Main Street
Sykesville, MD 21784
Tel: 443.609.4787
| Visit our Website | Email |
Mon - Fri, 8am - 6pm; Sat - Sun, closed
SK Printing, Inc is available for the very best in quality printing at extremely competitive prices. If you want grayscale or four color printing, we are at your service. We provide customized T-Shirts, Screen Printing, Embroidery, Promotional Items, Signs, Banners, Graphic Design, and Vehicle Signs. Business cards and stationery make that first impression which is both compelling and memorable. We can deliver full color promotional flyers, posters, blueprints brochures, mailers or cards, that really promote your organization's products and services.


text:
There's no there, there.
Several years ago, I was standing in the lobby of a major healthcare company, waiting for my client, looking at a huge banner strung across the cavernous lobby. The headline was something about how great their people were, with photos of doctors, nurses, office workers, and janitors–all stock photos. How much trouble would it have been to hire a photographer for a half-day to snap a few pics of real employees? Did the employees know...Read More


text:
When Ohio started removing science and social studies from its elementary school curriculum, Patty Elwell took action. Rather than opting for a private school or home school, however, Elwell in 2004 became one of the first parents to enroll her kids in an online public school.
?In spite of everyone?s best efforts the local school couldn?t meet their academic needs,? says Elwell, a former full-time teacher in southwest Ohio who has a son in 12th grade and a daughter in ninth. ?My only regret was I didn?t do it sooner."
Both children are enrolled in the Ohio Virtual Academy, an online charter school that is tuition free to state residents. The digital curriculum enabled her kids to take high-school courses in eighth grade, and today offers access to advanced placement and honors courses being cut in traditional classrooms.
Elwell is in the vanguard of a growing number of parents and educators leveraging technology to transform grade-school education. Enrollment in online public schools supported by education software provider K12 has grown from about 1,000 students 10 years ago to more than 100,000 today.
Overall, more than half a million students are learning online full-time in the U.S., according to education researcher Ambient Insight. Forty-eight states and the District of Columbia have virtual schools, while 29 states offer full-time online schools.


text:
Dropping his head? Weird.
He's very protective of his pic-a-nic basket.
Contributed with apologies to the PITB crew by your humble moderator.Tags: Brent Seabrook knows the instant his shoelaces are untied, Raffi Torres, Tanner Glass, tanner glass is the one, Torres
@HawksChumps2010 Really? The hit was completely legal, and he got up and went after Torres. Then, like a dumb oaf, he decided to keep playing and continued to get knocked again. Its not like he was taken off the ice in a stretcher. What do you expect? Should we post a link to Sarah McLaughlan's "I Will Remember You" and have a memorial service for him? Maybe for his career? The guy's an idiot. He's been hit in the head a few times the past couple weeks and is too ignorant to take a good clear look at the impact these hits have had. Nor has he learned to keep his head up in the area known as the "hit zone", as a D-Man. If he keeps it up, he'll have no career but, it'll be to no fault of Vancouver, nor the person -who had no involvement with the hit- who posted these pictures. We're rival teams, and we're having fun. I understand that it might hurt your heart a little but, grow up… at the very least, grab a box of Kleenex and go join Toews and Kane in a group hug.
A very apt analogy. But a driver should still make the effort to not kill the pedestrian, even if it isn't the drivers own fault and many drivers are sent to prison and ticketed on what is in large degree a pedestrians poor judgement.
ie: "cheap shots" were never illegal, they are still nasty that provide short term advantage (and vulgar entertainment) at the now considerable long term toxic consequences.
I used to think otherwise until I found myself on the victim end of the Moore – Naslund hit.
Nonetheless, as a PITB admirer, still found the post amusing.
"have a memorial service for him? Maybe for his career? The guy's an idiot. He's been hit in the head a few times the past couple weeks and is too ignorant to take a good clear look at the impact these hits have had"
as one commentator said, "Have some respect for your career." He takes a hard hit that may or may not have been dirty and then goes back on the ice. Respect your career man. This is your livelihood.


text:
Browse ShowsBy CategoryFeatured DiscountsPopular Shows
The Daily Scoop
US Reviews
US is a 21st century American love story. It explores how we meet, communicate, have sex and fall in love in the age of technology. Set against the backdrop of the year we elected Barack Obama, US involves a man ...
Write a Review Share
Latest Reviews for US
There are currently no reviews for this show.
Did you see this? Tell us what you think!
Discount tickets for Broadway shows, attractions, and much more.Get Discount Alerts
© 2002 2015
BroadwayBox.com is a trademark of BroadwayBox, Inc.
BroadwayBox.com is a trademark of BroadwayBox, Inc.
Popular Shows


text:
Anne Bronte's
headstone in England
Anne Bronte's Grave
O, let me be alone a while,
No human form is nigh.
And may I sing and muse aloud,
No mortal ear is by.
Away! ye dreams of earthly bliss,
Ye earthly cares begone:
Depart! ye restless wandering thoughts,
And let me be alone!
One hour, my spirit, stretch thy wings,
And quit this joyless sod,
Bask in the sunshine of the sky,
And be alone with God!
Back to Transatlantic Romantics Home
English Department • Centennial Hall 4102 • University of Wisconsin-Eau Claire • Eau Claire WI 54702-4004
Phone: 715-836-2639 • Fax: 715-836-5996Questions/Comments: firstname.lastname@example.com Updated: July 11, 2011
Copyright © 2015 UW-Eau Claire and the Board of Regents of the University of Wisconsin System


text:
Barcelona midfielder Jordi Alba is starting to get a taste for goals after scoring his third of the season against Celta Vigo.
The former Valencia man wrapped up a 3-1 Primera Division victory over Celta having enjoyed strikes against Deportivo and Celtic in recent weeks.
He told Marca: "I'm getting used to scoring goals but it's not my speciality as I'm a left winger, but it's always good when it happens.
"I like joining the attack and I'm lucky to have team-mates who give good service.
"It's a very important win and I'm happy with the goal.
"Celta are a really quick team on the counter, and can be very dangerous, and I think if we'd read the game better then we would have played better."
It was a rare night off goalscoring duties for Argentinian striker Lionel Messi, who witnessed the birth of his first child this week.
"Congratulations to Messi. It's a great feeling becoming a parent," Alba added.
Celta boss Paco Herrera was encouraged by his side's display, despite the Celestes missing the chance to climb into the top half of the league table.
"The same dynamic lasted throughout the match, with Barca attacking and us trying to close down the spaces," Herrera said.
"We wanted to try and keep the ball as long as possible and then break forward.
"We just tried to do the right things, nothing more.
"The best conclusion that we can draw from this game is that we are getting stressed from playing so many away games.
"Tito (Barcelona coach Vilanova) told me after the game that we had really made them run, so that's something to take away."
Click here for completely free £10 bet with Sky Bet & £5 free every week