text:
Something sinister to it,
Lyric Meaning
Earl's music often has a dark, evil feel to it.
Earl and production duo Christian Rich made the beat with the help of The Neptunes' Chad Hugo. The duo constructed the drums, and Earl did the rest. Watch the "Making of" video here
This hook is in reference to his life and struggle, which had something sinister to it, as seen from his verses.
Given the final verse talking about his frustration with the press and the industry, this could easily refer to his feelings toward the rap game as a whole. There's something sinister to it and he is wary.
Improve the quality of Chum Lyrics by leaving a suggestion at the bottom of the page


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Regal Entertainment Group is proud to offer Cinema Art: independent, critically-acclaimed films from the around the world, including India, as well as restored classics.
Since 1999, more than 60 theatres across the country showcase these alternative and independent movies through our national network of Regal Cinema Art theatres. Regal Entertainment Group also hosts a number of film festivals which celebrate the independent spirit of film making.
Find a Cinema Art Theatre
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Synopsis: From director Antoine Fuqua (TRAINING DAY) and writers Kurt Sutter (SONS OF ANARCHY) and Richard Wenk (THE MECHANIC) comes SOUTHPAW - the story of Billy "The Great" Hope, Junior Middleweight Boxing Champion of the World. When tragedy strikes and he loses it all, Billy enters the battle of his life as he struggles to become a contender once again and win back those he loves.
Director(s): Antoine Fuqua
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Stars: Rachel McAdams, Jake Gyllenhaal, Naomie Harris
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Synopsis: A teen artist living in 1970s San Francisco enters into an affair with her mother's boyfriend.
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Synopsis: In Spanish, Sicario means hitman. In the lawless border area stretching between the U.S. and Mexico, an idealistic FBI agent is enlisted by an elite government task force official to aid in the escalating war against drugs. Led by an enigmatic consultant with a questionable past, the team sets out on a clandestine journey forcing Kate to question everything that she believes in order to survive.
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Director(s): Baltasar Kormákur
Writer(s): Simon Beaufoy, Lem Dobbs, Justin Isbell (screenplay), Mark Medoff, William Nicholson (screenplay)
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Synopsis: In this fact-based thriller, a single mother struggling with drug addiction is randomly taken hostage in her own apartment by a man on the run from the law for breaking out of jail and murdering the judge assigned to his case.
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Synopsis: American chess champion Bobby Fischer prepares for a legendary match-up against Russian Boris Spassky.
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Synopsis: A story that exposes the conspiracy of prominent German institutions and government branches to cover up the crimes of Nazis during World War II.
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Synopsis: The foot soldiers of the early feminist movement, women who were forced underground to pursue a dangerous game of cat and mouse with an increasingly brutal State.
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A Big Island man, accused of shooting his Nanawale Estates neighbor to death in May, is found to be competent to stand trial.
Seon Keoni Aki, 44, is a registered sex offender and was examined by three mental health professionals.
In October, Aki pleaded not guilty to second-degree murder for the shooting death of 40-year-old Mateo Balinbin Jr.
A trial date has been set for Jan. 27. Bail was set at $360,000.


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Communities focusing on activities around being an ACS member.
Explore ACS Communities for other member-related groups and forums
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Find answers to your questions about the ACS Network.
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Hello, fellow scientists,
I made this thread so we can discuss anything about LaTeX. LaTeX is a powerful markup language for writing scientific documents. I've personally used LaTeX for my undergraduate thesis. And I'm sure there are many people here who have too. So, let's make this thread a comfortable to discuss everything basic about LaTeX.
Retrieving data ...


text:
152,103pages on
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this wiki
Muspelheim is one of the Nine Worlds in Asgardian cosmology. It is a realm of eternal fire, and the home of the Fire Demons and their ruler Surtur. It was home to the Warlock's Eye, a device of such awesome power that Odin dispatched Thor, Volstagg, Hogun & Fandral to retrieve it in an attempt to ward off the coming of Ragnarok.
- No special notes.
- No trivia.
See Also
- Appearances of Muspelheim
- Media Muspelheim was Mentioned in
- Location Gallery: Muspelheim
- Images related to Muspelheim
- Fan Art Gallery: Muspelheim
- Marvel Staff members who were born in Muspelheim
Links and References
- None.


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Beyond its 1080p30 movie capture and waterproof body, the Ghost has useful extras to help it stand out.
The popular block-building-sandbox game is creeping into the third annual Hour of Code, a worldwide campaign to spark students' interest in programming.
A psychology student wants to see if a certain vitamin can make sleepy people have more lucid dreams. Is it Vitamin Zzzzzzzzzzzz?
A prototype wheelchair with a cellular radio illustrates the benefits of connected devices.
Researchers from MIT have designed an interface that allows a robot to tap into the reflexes of a human controller to eradicate typical robot clumsiness.
Technically Incorrect: Funded by billionaire Yuri Milner, the project will be listening very hard for alien noises, with Hawking and other scientists in support.
Two women on stage might not seem like a big deal, until you realize that -- until now -- only two women had made an appearance since 2007 at the developers' conference. And they didn't even work at Apple.
The best way to recruit more women into tech? Convince them when they're young that tech is cool.
Do-it-yourselfers using electrical currents to stimulate their brains may be doing more harm than good.
Tech companies say they want more women and minorities. But who's actually doing something tangible?


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Picture: John Brosnan, as George Harrison, performs on stage during the 'Classical Mystery Tour', a note-for-note live reincarnation of The Beatles at the Sony Centre...
Rare and never-before-seen items belonging to late Beatles star George Harrison have been unveiled at the Grammy Museum in Los Angeles.
Harrison's widow, Olivia, invited the museum's bosses to the home they shared together in Henley-on-Thames, England, and allowed them to hand pick the items for the display, which ends on 26 March (12).
The museum's deputy director, Rita George, was overjoyed to get her hands on the rare memorabilia, telling the Bbc, "George has been gone for just over 11 years now. It's a great story. He was known as the quiet Beatle and it's great to be able to tell his story.
"It's a treasure trove of personal effects, lyrics and costumes. We were lucky to go in and hand pick the items from Olivia's collection. Many of the items will be seen for the first time in public and (it) is likely to be the last time. We are sending it directly back to Olivia after the museum display is finished."
Harrison died in 2001 after a battle with lung cancer.


text:
2003 Infiniti G35 • 95,000 miles
When I turn the head light one flickers
February 5, 2012.
February 5, 2012.
Replaced wiring harness in 1988 S10 Blazer and have 2 wires that i dont know where they hook up, also fuel pump is not engaging
14 answers • 1988 Chevrolet Blazer
I inherited someone elses problem... the engines in the cradle but none of the wires/sensors were hooked up, most are easy enough, but I want to make sure that I hook up the right wires...
2 answers • 1984 Oldsmobile Ciera • 100,000 miles
My interior lights power windows and moon roof still not working after changing fuse. Fuses just blow out. I can't find wiring schematics anywhere. I have spent too much money trying...
2 answers • 2008 Ford Fusion • 29,000 miles
I have a 2000 grand prix gtp s/c. I just did an engine swap but can't find where one wire goes. It's on the harness with the oil filter holder and it's a single plug but can't seem to ...
7 answers • 2000 Pontiac Grand Prix


text:
Dark chocolate gets a bad rap as the less-delectable choice of chocolate, but prepared correctly, it's just as decadent as its more popular counterpart.Read Full Story
When you have a sweet tooth to satisfy but don't want to have something that's too unhealthy, dark chocolate is always ready to come to the rescue. And if you're tired of your usual plain chocolate bars, you can simply melt them down and turn them into one of these fancied-up dark chocolate desserts.Read Full Story
Summer vacation is over. It's back to school for the kids and back to work for you! The kids might clamor for milk and cookies, but we know that grown-ups should snack better — and not out of a box. Here are five tasty, guilt-free homemade snacks to satisfy cravings for crispy, crunchy, creamy, sweet and fatty.Read Full Story
Valentine's Day is a day of love, but it is also a time for chocolate. Feeling guilty? You shouldn't. Chocolate is experiencing a medical renaissance of late. Over the past several years, numerous medical studies have demonstrated that people who ate chocolate regularly experienced health benefits.Read Full Story
Exercise and a balanced diet are well-known factors that improve heart health, but there are many other lifestyle factors that can reduce your risk of heart disease. Some may even surprise you! Here are 10 things you can do for a healthy heart.Read Full Story
Through your best diet and fitness efforts, you've managed to tone up and drop a dress size, but that muffin top bulging over your waistband simply won't budge. What gives? You may just need to incorporate belly-fat burning foods into your daily diet. Here are a few tasty foods that will burn belly fat and whittle your waist.Read Full Story
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I've read that badges like "Analytical" or "Beta" can no longer be earned. Shouldn't these badges be removed from the list?
What is meta? ×
Meta Stack Exchange is where users like you discuss bugs, features, and support issues that affect the software powering all 150 Stack Exchange communities.
As correctly mentioned by @hammar, these badges are still listed because users still have them. Badges are never revoked* or reversed. If these were removed then the next meta post would be:
Taken from the How to badges work meta FAQ post:
The Badge List is a list of badges that users can get or could have gotten previously. Since those two badges are can still be kept by users, they should still be shown on the list.


text:
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It's an interesting request and that's why we're here: solving those problems that three minutes on Google just can't. So, dear friends, what say you? Wish the soon-to-be-wed couple all the best by adding a helpful solution to the comment feed and spread a little joy.
"Hi guys. I'm getting married in a church with a weird split-hall design. The result is that half of the attendees won't be able to see the ceremony at all! I'm wondering if I could hook up my Canon Rebel T3i up to my 3rd-generation iPad and use it as a quick-and-dirty closed-circuit display? There's no WiFi in the location, so it has to be a wired solution too. Please help me!"
- Key specs
- Prices
- Discussions
- Type DSLR
- Lens mount Canon EF-S
- Resolution (effective) 18 megapixels
- Sensor size APS-C
- Image stabilization External (lens)
- Memory card SD (SDXC, SDHC)
- Dimensions 3.9 x 5.2 x 3.1 in
- Weight 18.2 oz
Apple iPad Air 2


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text:
Posts from Pets
Before & After: IKEA Doll Bed Does Double (& Triple!) Duty
Just for Fun: Purrrfect Pets
We know who's really running these households. There's no better way to finish off a long weekend than with a gleeful browse through some of our cutest pet pics. Scroll through these hammy animals and we guarantee that you'll leave lighter, happier and ready to have some fun.
My Small Home: Carrie's Small Space Solutions
I've lived in my current apartment for seven years and it's only in the past few years, with two children and a cat, that it's really begun to feel small. As the shape and size of our family changes, we make adjustments and create solutions to make the most of the space we do have. Here are a few examples from my own home of small space problems and how we've attempted to solve them - maybe there's an idea you can steal!
How To Teach Pets to Not Eat Cords
Pet owners know this scene all too well: you walk into a room and find your beloved pet eating your television cord, your phone charging cord, or some other important electronic cord which should not be gnawed. If this sounds familiar, worry not: here are three steps I've taken to train two dogs and two cats to leave cords alone:
Congrats Team Cat!
It's time to finally decide once and for all: are the Apartment Therapy readers ultimately cat people or dog people? You've been choosing your favorite cute cat and dog faces for days but now it's time to decide if you're #teamcat or #teamdog! After a long series of intense but adorable battles we're now down to only two fierce, furry competitors.
Pet Madness Day 10: The Elite 8 Continues!
The competition is heating up. Only eight contenders remain. Only four will advance. Your mission, if you choose to accept it: to pick which of these cuddly critters will move on to the next round of Pet Madness. The choices are tough — just look at those little faces! — but we know you're up for it.
Pet Madness Day 7: Sweet Sixteen Continues!
Apartment Therapy's Pet Madness: Cats vs Dogs
Pet Madness is halfway through its second round: The Sweet Sixteen! But none of these cute cats and dogs can rest on their (adorable) laurels, as there is still plenty of voting to be done to decide who will advance to the next round until there are only two left: one can and one dog in the final battle. Polls close at 9 PM ET tonight, so make your vote count!
10 Pet Beds You Won't Need to Hide
Living in a small space with a pet is definitely doable, and judging from the responses to our recent post, it's even doable with a big dog! One thing mentioned by a few readers, however, was the space taken up by the pet bed and its impact on the decor. When you're working with less than 800 square feet, there just isn't room to hide the pet bed, and making it work with your style becomes much more of a necessity. With that in mind, here are 10 stylish pet beds you won't need to hide.
How To Get Rid of Industrial Strength Smells: Pet Urine, Damp & Smoke
Some odors can be eliminated with a little natural soap and fresh air, while others require a full-scale assault. If your home is plagued by all-too-powerful smells, here's the arsenal you'll want at your disposal...
Rethink the Stink: 5 Odor Removing Products No Home Should Be Without
Apartment Therapy's Home Remedies
As nice as it would be to always keep a perfectly clean, perfectly smelling house — the truth is, bad odors happen. Whether it's smelly upholstery from a great thrift store find, a pet's potty training accident, or a party that needs a massive cleanup, funky smell are an unavoidable part of everyday life. With that in mind, here are the 5 products we'd recommend always having in the house to combat and remove odors.


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Uncle Bob's Self Storage provides storage units in Avon at 38390 Chester Road, Avon, OH, 44011. Rent Avon... more
VIP Property Management Co. offers services for residential and commercial properties both for lease and ... more
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If you have a dispute on your rental unit, you may need... more
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Finding an apartment to rent is a long process. Read on... more
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Property investing is one of the best ways to make a pr... more
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Renting out your home can be a great way to raise some ... more
How to Pick an Appropriate Pet for Your Home
Depending on what kind of home you have, you may find t... more
© 2015 Local Corporation - US Patent 7,231,405
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Practice, sexuality and gender - intersections in social work (Editorial)
Dunk-West, Priscilla and Hafford-Letchfield, Trish and Quinney, Anne (2009) Practice, sexuality and gender - intersections in social work (Editorial). Practice: Social Work in Action, 21 (1). pp. 1-3. ISSN 0950-3153
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Official URL: http://dx.doi.org/10.1080/09503150902745963
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|A. > School of Health and Education > Mental Health, Social Work and Interprofessional Learning
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Rocky Mountain National Park > Twin Sisters Peaks > Climber's Log
Twin Sisters Peaks Climber's Log
[ Sign the Climber's Log ]
|Michael Hoyt
|Perfect Morning Light
Date Climbed: Aug 24, 1997
|We hit the trail at 4:45 am so we'd have "perfect" light on Long's Peak. We did and it was great.
|Posted Nov 15, 2006 5:52 pm
|beautiful day, great views
|Was a beautiful clear day for a climb...little windy at the top but great views of Longs/Meeker. Scrambled to both peaks, were the only ones scrambling the taller of the two for some reason. Followed this by hiking to Ouzel Falls nearby...which were magnificent. Great day of hiking!
|Posted Nov 9, 2006 12:51 am
|Three Twins?
Date Climbed: Oct 7, 2006
|The sisters offered a nice view of Longs, etc., but the downscramble to the saddle with the peak (unnamed?) to the south and the scramble up to its summit was more enjoyable, more hands-on (rock) and offered a better view. Made the sisters, themselves, look like bland ol' humps in the ground.
|Posted Nov 3, 2006 9:53 pm
|Up former trail from W, visited all adjacent bumps
Date Climbed: Jul 16, 1985
|Posted Sep 25, 2006 6:06 pm
|Fun Hike
|Great views, easy hike, two summits, and marmots.
|Posted Sep 19, 2006 10:32 pm
|Will Davis
|Normal Route
|I've climbed Twin Sisters 6 or 7 times. I love it. It provides the best views of the Longs-Meeker-Lady Washington massif.
|Posted Sep 1, 2006 2:34 am
|Nice short hike to wonderful views
Date Climbed: Jul 23, 2006
|Left TH at 12:45, returned at 3:45 in a downpour. Tagged both summits. Saw a bunch of unprepared people headed up in an approaching storm.
|Posted Jul 24, 2006 4:39 pm
|two sisters, one day
Date Climbed: Apr 8, 2006
|summited both twin sisters. the southern one has a nice fin for great, short section of scrambling. lots of fun, you should try this one when you can't get out for a big trip.
|Posted Jun 30, 2006 11:22 pm
|Nice hike
Date Climbed: Jun 17, 2006
|A nice hike up to mark the beginning of the season.
|Posted Jun 22, 2006 7:25 pm
|Route Climbed: Twin Sisters Trail
Date Climbed: Aug 11, 2005
|A nice hike up to the top of both summits. Not too crowded and has nice views of Longs Peak and Mt. Meeker.
|Posted Apr 30, 2006 4:47 pm
|Twin Sisters Trailhead
Date Climbed: Dec 11, 2004
|This peak is fun and easy to do in the winter. The snow was hard packed so I didn't need my snowshoes. I was surprised to bump into quite a few people this day. Although this puppy isn't very high, the summit was windy and cold.
|Posted Mar 17, 2006 4:23 pm
|Mountain Jim
|Standard Route
Date Climbed: Jul 9, 1969
|Total ascents = 10. One of the better conditioning hikes in Rocky Mountain National Park.
|Posted Mar 17, 2006 4:54 am
|Both summits
Date Climbed: Aug 23, 2005
|Finally did both summits after years of just hiking to the 11,413 point to the west of the actual 11,428 summit. Then we scooted over to the southern summit which is even better!
|Posted Mar 3, 2006 4:29 pm
|Route: Twin Sisters Trail
|Not so sure on date...April 2005ish on a bluebird day, solo. A pleasant warmer-upper for winter ski-itized or hibernatized legs. Very icy at this time of year, bring something for traction! I had Yaktrax which did the trick. (can I get some points for making up new words? :)
|Posted Feb 27, 2006 5:20 am
|Route Climbed: trail Date Climbed: May 1998
|Nice, easy hike. Great views of Meeker-Longs-Lady Washington.
|Posted Jan 25, 2006 5:12 pm
|Route Climbed: Twin Sisters trail Date Climbed: August 1996
|An early morning start with a summit around 11:00am.
Fairly easy trail with nice views of Long's and the front range once you reach the ridge. Only a few people we encountered.
|Posted Jan 22, 2006 9:17 pm
|Route Climbed: Twin Sisters Trail Date Climbed: August 9, 2003
|Beautiful hike. Was not able to traverse to "South Sister" due to lightning.
|Posted Dec 30, 2005 12:43 pm
|Route Climbed: Lily Lake Date Climbed: July 16, 2005
|My first Colorado summit! I've been hooked ever since!
|Posted Oct 22, 2005 11:54 pm
|Route Climbed: Twin Sisters Trail Date Climbed: Many times!
|This is a great "starter hike" for anyone coming to the park from a lower elevation. Great one for the family as well. I love using this mountain for trail running or a sunrise hike. In late summer, you might even see some Bighorn sheep:)
|Posted Oct 8, 2005 11:13 pm
|Route Climbed: Twin Sisters Trail Date Climbed: July 9, 2005
|Easy day hike...very pleasant and throughout the majority of the climb you the Eastern face of Longs and Meekers are exposed and they are jaw-dropping...
|Posted Oct 5, 2005 9:36 pm


text:
SpeakUp Magazine: Queen
Is your english still wimpy?
Monthly magazine offering articles, special topics and suggestions on a CD to strengthen your english.
Advertising Agency: Innova - All Around the Brand, Sao Paulo, Brazil
Creative Director / Art Director: Sergio Barros
Copywriter: Tiago Sanches
Illustrator: Diogo Oliveira
Published: September 2013


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Rain Bird Services Corp.'s new nonmanufacturer-specific certification program for experienced irrigators has earned the EPA's WaterSense label, which assures customers that certified contractors are knowledgeable in water-efficient installation principles. For more about the Rain Bird Certified Residential and Light Commercial Installer program, visit www.rainbirdservicescorporation.com.
Environmental Protection...
PUBLIC WORKS Staff
The American Concrete Pavement Association will host a webinar on the standards for...
ACI guide focuses on pavement construction to include paving techniques and time-proven...
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text:
I am looking for a C++ library that can tag ogg files easily meaning with a simple function like
write_ogg_tag("file.ogg", tag_data); // where tag_data contains artist, album ...
Is there a solution?
Also, do some of the solutions apply to MP3, FLAC, etc.? (ogg suffices, only asking because I'm curious)


text:
85 search results for The Entire History Of You
Toby Kebbell will don Dr. Doom's mask for 'Fantastic Four'
Type: Post | Date: Wednesday, Apr 2, 2014Josh Trank certainly isn't making the easy choices for this one
Robert Downey Jr. will produce a film based on an episode of Charlie Brooker's 'Black Mirror'
Type: Post | Date: Monday, Feb 11, 2013If you know who Charlie Brooker is, that's exciting news, indeed
Review: Brilliant British sci-fi drama 'Black Mirror' comes to Netflix
Type: Post | Date: Wednesday, Dec 10, 2014A "Twilight Zone" for this century casts an unflattering reflection on our love of technology
'The Good Dinosaur' trailer blithely shatters the space/time continuum
Type: Post | Date: Tuesday, Jun 2, 2015A "What If?" universe never looked so adorable.
'Ask Drew' deals with the Oculus Rift and Mad Max in a special Comic-Con episode
Type: Post | Date: Tuesday, Jul 29, 2014I can't believe we got this one finished without security stopping us
Silent Hill: Book of Memories
Type: Event | Date: Tuesday, Oct 16, 2012The "Silent Hill" series comes to the PS Vita with "Book of Memories."
Review: 'The Tribe' uses only sign language to tell a hard and haunting story
Type: Post | Date: Monday, Nov 10, 2014Love it or hate it, you'll never forget this one
The Great Debate: What Was the Best Film Year of the Past Half-Century?
Type: Article | Date: Monday, Apr 27, 2015How do the 90's match up to the 70's? Film writers take them on!
Type: Event | Date: Tuesday, Jan 26, 2010MAG is a first-person shooter in a persistent environment that allows you to play with 255 other players in a 128 vs. 128 battlefield, with real squadrons and squad leaders, providing one of the largest online gaming experiences to date.
Director Gareth Evans discusses breaking bones and blowing minds with 'The Raid 2'
Type: Post | Date: Saturday, Jan 25, 2014Watch me as I realize Evans pulled off the impossible for real in his film


text:
Picture: Jenny McCarthy Jenny McCarthy at the Michigan Avenue Magazine Fall 2012 Chicago, Illinois - 28.08.12
Actress/model Jenny McCarthy used the pay cheque from her first Playboy cover shoot to buy her struggling parents a new home.
The Scream 3 star grew up in a small house in a middle class Chicago, Illinois neighbourhood and the family often struggled to make ends meet.
So when MCCarthy got the chance to pose for the racy magazine in 1993 at the age of 21, she gladly accepted and used the combined $120,000 (Gbp75,000) pay-out to buy her mum and dad a new place.
During an interview on U.S. breakfast show Good Morning America on Tuesday (02Oct12), she said, "We grew up very, very poor... It was devastating in my childhood to watch my mum and dad struggle for food, and wonder where dinner was gonna come from...
"As time went on, I knew I was gonna bail them out some day. And when I posed for Playboy I went home and wrote a cheque out to pay all their bills and moved them into the suburbs."


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prev next help
Updated May 2001
4.01 VOLUNTARY DISCLOSURE 4.01[1] Policy Respecting Voluntary Disclosure 4.01[2] Timeliness of Disclosure 4.01[3] Cooperation of Taxpayer 4.02 DUAL PROSECUTION AND SUCCESSIVE PROSECUTION 4.02[1] Applicability of Policy 4.02[2] Tax Prosecutions 4.02[3] Pretrial Diversion 4.03 INCARCERATED PERSONS 4.03[1] General 4.03[2] Prosecution of Incarcerated Persons 4.04 HEALTH POLICY 4.04[1] General Policy 4.04[2] Court Determination of Health Status 4.05 MENTAL INCOMPETENCY 4.05[1] Evaluation at Administrative Level 4.05[2] Insanity Defense Reform Act of 1984 4.06 SEARCH WARRANTS 4.06[1] Generally 4.06[2] Procedures Under Directive No. 52 4.07 APPEALS 4.08 REQUESTS FOR TRIAL ASSISTANCE 4.09 STATUS REPORTS 4.10 RETURN OF REPORTS AND EXHIBITS
|There are numerous policies governing the operation of the Department of Justice, many of which are set forth in the United States Attorneys' Manual (USAM). Some of these policies, as implemented by the Tax Division and not otherwise covered in this Manual, are discussed in the sections which follow.
4.01 VOLUNTARY DISCLOSURE 4.01[1] Policy Respecting Voluntary Disclosure Prior to 1952, it was the policy of the Treasury Department not to recommend criminal prosecution where a taxpayer voluntarily revealed his commission of a tax crime to an appropriate IRS official before any investigation of his affairs had commenced. Due to the controversy which ensued in the courts over what constituted a true "voluntary disclosure," and because it was difficult, "and sometimes impossible" to ascertain administratively whether the taxpayer had made a voluntary disclosure or had merely discovered he was under investigation, the Treasury Department abandoned this policy on January 10, 1952. Treasury Department Information Release No. S-2930, 1952 C.C.H., ¶ 6079. See United States v. Shotwell Manufacturing Co., 355 U.S. 233, 235 n.2 (1957). In 1961, the Internal Revenue Service adopted an "informal" policy regarding voluntary disclosure, under which it considered voluntary disclosure, along with other facts and circumstances, on a case-by-case basis in determining whether or not to recommend prosecution. See Statement of Commissioner Mortimer M. Caplin, News Release IR-432, Dec. 13, 1961; IRM Part IX, §9781- 342.14 and CCDM Part (31)134. In December 1992, the IRS clarified, but did not change, its "informal" policy, noting that, in the past, it had not generally recommended prosecution if the taxpayer: 1. Informed the IRS of the failure to file for one or more taxable years; 2. Had only legal source income; 3. Made the disclosure prior to being contacted by the IRS in the form of a telephone call, letter, or personal visit informing the taxpayer that he is under criminal investigation; 4. Filed a true and correct tax return or cooperated with the IRS in ascertaining his correct tax liability; and 5. Made full payment of amounts due, or in those situations where the taxpayer was unable to make full payment, made bona fide arrangements to pay. "Peterson [IRS Commissioner Shirley D. Peterson] Formalizes Practice of Not Prosecuting Non-Filers Who Come Forward." BNA Daily Tax Report (Dec. 7, 1992). See United States v. Knottnerus, 139 F.3d 558, 559-560 (7th Cir. 1998) (holding that prior visit by special agent disqualified defendant from voluntary disclosure program). However, the 1992 clarification by the Service created confusion as to the application of the voluntary disclosure policy with respect to nonfilers. See United States v. Tenzer, 127 F.3d 222, 226-28 (2d Cir. 1997), vacated in part and remanded on other grounds, 213 F.3d 34, 40-41 (2d Cir. 2000). Thus, in 1995, the Service reinstated its former voluntary disclosure practice, eliminated the language relative to nonfilers, and modified the triggering event example. Currently, the Service's voluntary disclosure practice is that a voluntary disclosure will be considered along with all other factors in a case in determining whether criminal prosecution will be recommended. Under the Service's practice, a voluntary disclosure occurs when the communication is: (1) truthful; (2) timely; (3) complete; and (4) the taxpayer shows a willingness to cooperate, and, in fact cooperates, with the Service in determining his or her tax liability. A disclosure is timely if received before: (1) the Service has initiated an inquiry that is likely to lead to the taxpayer and the taxpayer is reasonably thought to be aware of that activity; or (2) some event known by the taxpayer occurred which event is likely to cause an audit into the taxpayer's liabilities. The Service tests voluntariness by the following factors: (1) actual status of the Service's awareness of the taxpayer as to specific tax investigation potential; (2) taxpayer's knowledge or awareness of the Service's interest; and (3) taxpayer's fear of a "trigger" or "potential trigger" to make the Service aware of violations (where the disclosure is 'triggered' by an event which would have led the Service to the fraud, the disclosure is not considered to be voluntary). See United States v. Knottnerus, 139 F.3d at 559-560; United States v. Tenzer, 127 F.3d at 226-228. At present, the Department of Justice continues to give consideration to a "voluntary disclosure" on a case-by-case basis in determining whether to prosecute but such disclosure is not conclusive on the issue. See United States v. Hebel, 668 F.2d 995 (8th Cir. 1982). Specifically, the Tax Division considers the timeliness of the disclosure and whether the taxpayer fully cooperated with the Government in deciding whether a disclosure was voluntary. 4.01[2] Timeliness of Disclosure There are two elements to a voluntary disclosure: (1) it must be made timely and (2) the taxpayer must thereafter fully cooperate with the government. There has been considerable debate among practitioners as to the meaning of "timely." Some argue that the test for timeliness should be strictly objective, that is, a disclosure is timely if the disclosure is made before the taxpayer's return is selected by the Internal Revenue Service for audit regardless of the taxpayer's motivation for making the disclosure. Under this approach, a disclosure would not be timely if the return had been selected for audit, even if the taxpayer did not know that the return had already been selected for audit at the time of the disclosure. The objective test does have simplicity of application in its favor. On the other hand, if all of the circumstances are considered, then whether or not a return has been selected for audit at the time of disclosure is not necessarily conclusive. For example, if the disclosure followed closely upon an IRS inquiry directed to a third party which reasonably could be anticipated to lead to selection of the taxpayer's return for audit, then the disclosure reasonably could be described as "triggered," rather than as "voluntary." Although not yet subject to audit, the taxpayer was obviously attempting to place himself or herself in the best light possible after concluding that an audit was inevitable. United States v. McCormick, 67 F.2d 867, 868 (2d Cir. 1933). Conversely, if the taxpayer was in fact clearly unaware that his or her return had been selected for audit at the time of the disclosure and "triggering" circumstances are absent, then seemingly consideration should be given for having come forward voluntarily. Cf. United States v. Levy, 99 F. Supp. 529, 533 (D.Conn. 1951). Similarly, there may be situations where an audit is already in progress, and the taxpayer discloses a transaction that almost certainly would not have been found by the auditing agent. On a strictly objective test, the disclosure of the unknown transaction would not be a "timely disclosure" since the return was under audit. Because the objective test is essentially arbitrary, the Department has rejected it, and, instead, favors an "all events" test in assessing whether a disclosure was timely. That is, a disclosure is not timely if: 1. The IRS has already initiated an inquiry that is likely to lead to the taxpayer and the taxpayer is reasonably thought to be aware of that activity; or 2. Some event occurred before the disclosure which the taxpayer probably knew about and which event is likely to cause an audit into the taxpayer's liabilities, e.g., a newspaper article high-lighting commercial bribery in a particular industry or corruption in a governmental office. Cf. United States v. McCormick, 67 F.2d 867 (2d Cir. 1933). 4.01[3] Cooperation of Taxpayer If it is concluded that the disclosure was timely, a second point of inquiry is whether the taxpayer has fully cooperated with the IRS in ascertaining and paying the taxes owed. Thus, the Department's position on cooperation is that the taxpayer must make a full disclosure of all facts and cooperate with the Service in determining the proper amount of taxes owed. If the taxes are not paid because of a claim of inability to pay, then full and accurate disclosure must be made by the taxpayer of his financial position. At bottom, application of the "voluntary disclosure" policy is an exercise of prosecutorial discretion that does not, and legally could not, confer any legal rights on taxpayers. Whether there is or is not a voluntary disclosure is only a factor in evaluating a case, and even if there has been a voluntary disclosure, prosecution and conviction may still result. In short, a voluntary disclosure is not a bar to prosecution, but merely a factor to be considered. See United States v. Hebel, 668 F.2d 995 (8th Cir. 1982). See February 17, 1993, Tax Division memorandum on Tax Division Voluntary Disclosure Policy from Acting Assistant Attorney General James A. Bruton, Tax Division. A copy of this memorandum is contained in Section 3.00 of this Manual.
4.02 DUAL PROSECUTION AND SUCCESSIVE PROSECUTION 4.02[1] Applicability of Policy The dual and successive prosecution policy establishes guidelines for the exercise of discretion by appropriate officers of the Department of Justice in determining whether to bring a federal prosecution based on substantially the same act(s) or transactions involved in a prior state or federal proceeding. The purpose of this policy is to vindicate substantial federal interests through appropriate federal prosecutions, to protect persons charged with criminal conduct from the burdens associated with multiple prosecutions and punishmentsfor substantially the same act(s) or transaction(s), to promote efficient utilization of Department resources, and to promote coordination and cooperation between federal and state prosecutors. The policy "precludes the initiation or continuation of a federal prosecution, following a state or federal prosecution based on substantially the same act(s) or transaction(s) unless three substantive prerequisites are satisfied: first, the matter must involve a substantial federal interest; second, the prior prosecution must have left that interest demonstrably unvindicated; and third, applying the same test that is applicable to all federal prosecutions, the government must believe that the defendant's conduct constitutes a federal offense, and that the admissible evidence probably will be sufficient to obtain and sustain a conviction by an unbiased trier of fact." USAM 9-2.031. For an example of a dual prosecution, see Thompson v. United States, 444 U.S. 248 (1980). For examples of successive prosecution, see Rinaldi v. United States, 434 U.S. 22 (1977); Petite v. United States, 361 U.S. 529 (1960). Parenthetically, the Petite case has given its name to both components of the policy, i.e., the courts have used the "Petite Policy" interchangeably for both dual and successive prosecutions. Cf. Thompson, 444 U.S. at 249. The policy is set forth in detail in USAM, § 9-2.031. In order to prevent unwarranted dual or successive prosecutions, the policy requires that authorization be obtained from the appropriate Assistant Attorney General prior to initiating or continuing the federal prosecution. USAM, § 9-2.031. In criminal tax cases, this is the Assistant Attorney General, Tax Division. 28 C.F.R., §§ 0.70, 0.179. The United States will move to dismiss any prosecution governed by this policy in which prior approval was not obtained, unless the appropriate Assistant Attorney General retroactively approves it on the following grounds: first, that there are unusual or overriding circumstances justifying retroactive approval, and second, that the prosecution would have been approved had approval been sought in a timely fashion. Appropriate administrative action may be initiated against prosecutors who violate this policy. USAM, § 9-2.031. Requests for the authorization of dual or successive federal prosecutions are evaluated on a case-by-case basis by the appropriate Assistant Attorney General based on the factors set forth in USAM, § 9-2.031. A federal prosecution will not be authorized unless the state/prior federal proceeding left substantial federal interests demonstrably unvindicated. Even so, a dual or successive prosecution is not warranted unless a conviction is anticipated. If the state/prior federal proceeding resulted in a conviction, prosecution normally will not be authorized unless a substantially enhanced sentence in the subsequent federal prosecution is anticipated. 4.02[2] Tax Prosecutions> It can be argued that neither the dual nor the successive prosecution policy really applies to income tax prosecutions because even if the acts and transactions of the prior prosecution were the same income-producing activities, the tax crime did not take place until the following year when the fraudulent income tax return was filed or the failure to file happened. In other words, the failure to report income is not usually an element of the prior criminal proceeding, e.g., an embezzlement charge. Nevertheless, in the exercise of its prosecutorial discretion, the Tax Division adheres to the letter and spirit of these policies in conformity with USAM, § 9-2.031. Similarly, the dual and successive prosecution policy technically is not implicated when venue considerations precluded joinder of all the offenses in one judicial district, when the defendant opposed a single trial, or when the evidence was not obtained until after the earlier prosecution was commenced. As a practical matter, however, when a tax case is being evaluated before indictment, the better course is not to rely on these technical points to conclude that the dual and successive prosecution procedures need not be followed. Under its discussion of these policies, the United States Attorneys' Manual specifically states that prosecution will not be authorized unless a conviction is anticipated for the subsequent case, and it is thought that the second conviction will result in a substantially enhanced sentence. USAM, § 9-2.031. For example, assume that tax and non-tax charges arising out of the same transactions are brought, and venue precludes trying all of the charges in the same district. If the non-tax charges are tried first and result in a substantial sentence, then it is questionable whether the government should subsequently proceed with the tax charges if an enhanced sentence cannot be anticipated, unless the federal interest was not substantially vindicated by the earlier prosecution because of circumstances extraneous to the case. In the final analysis, when there is a question as to the applicability of the dual and successive prosecution policies, the procedures set forth in USAM, § 9-2.031 should be followed. If the facts are compelling in support of the conclusion that the federal interest has not been substantially vindicated, securing the Assistant Attorney General's authorization does not impose a substantial burden to processing a case through the Tax Division. Conversely, if it is determined that the subordinate reviewing attorney erred in not obtaining the authorization of the appropriate Assistant Attorney General, then there is a substantial danger that all the effort spent in securing a conviction will have gone for naught. 4.02[3] Pretrial Diversion> While no specific reference is made to pretrial diversion in the section of the United States Attorneys' Manual dealing with dual and successive prosecution, the safer course is to consider pretrial diversion as within the context of these two policies even though jeopardy has not attached in that situation. This approach comports with the Department's traditional policy of applying the policy in a common sense, non-technical fashion in order to effectuate its salutary objectives. USAM, § 9-22.000 does address the pretrial diversion program, but requires, among other things, prior Tax Division approval in all cases under its jurisdiction. The Tax Division's long-standing, strict policy is that criminal tax cases should not be disposed of under the Department's pretrial diversion program. This policy is stated in the transmittal letter that accompanies all criminal tax cases sent from the Tax Division to a United States Attorney's office. Accordingly, criminal tax defendants should not be given pretrial diversion treatment.
4.03 INCARCERATED PERSONS 4.03[1] General> Whenever a proposed tax defendant is incarcerated on other charges, an initial determination must be made as to whether the Department's policies on dual and successive prosecution (Petite Policy) are applicable. See 4.02, supra. If they are, the procedures for those policies are controlling and must be followed. If it is determined that there is no connection, direct or indirect, between the acts and transactions underlying the conviction(s) for which the proposed defendant is presently incarcerated and the contemplated tax- related prosecution, then other considerations nevertheless come into play in determining whether prosecution should be initiated or declined. These considerations are discussed in the section which follows. 4.03[2] Prosecution of Incarcerated Persons> Principles of Federal Prosecution, as reprinted in USAM, § 9-27.000, provides as follows (USAM, § 9-27.230): A. In determining whether prosecution should be declined because no substantial Federal interest would be served by prosecution, the attorney for the government should weigh all relevant considerations, including: 1. Federal law enforcement priorities; 2. The nature and seriousness of the offense; 3. The deterrent effect of prosecution; 4. The person's culpability in connection with the offense; 5. The person's history with respect to criminal activity; 6. The person's willingness to cooperate in the investigation or prosecution of others; and 7. The probable sentence or other consequences if the person is convicted. The above list of relevant considerations is not intended to be all- inclusive and in a given case one factor may deserve more weight than it might in another case. USAM, § 9-27.230, Subsection B. Principles of Federal Prosecution further emphasizes the weight to be given the probable sentence in the determination as to whether criminal proceedings should be instituted as follows (USAM, § 9-27.230(B)(8)): 8. The Probable Sentence In assessing the strength of the Federal interest in prosecution, the attorney for the government should consider the sentence, or other consequence, that is likely to be imposed if prosecution is successful, and whether such a sentence or other consequence would justify the time and effort of prosecution. If the offender is already subject to a substantial sentence, or is already incarcerated, as a result of a conviction for another offense, the prosecutor should weigh the likelihood that another conviction will result in a meaningful addition to his/her sentence, might otherwise have a deterrent effect, or is necessary to ensure that the offender's record accurately reflects the extent of his/her criminal conduct. * * * (I)f the person is on probation or parole as a result of an earlier conviction, the prosecutor should consider whether the public interest might better be served by instituting a proceeding for violation of probation or revocation of parole, than by commencing a new prosecution. The prosecutor should also be alert to the desirability of instituting prosecution to prevent the running of the statute of limitations and to preserve the availability of a basis for an adequate sentence if there appears to be a chance that an offender's prior conviction may be reversed on appeal or collateral attack. This concept is probably best understood by example. Assume that the contemplated tax defendant is presently incarcerated for the killing of his spouse, committed in the heat of passion without any income-producing ramifications, that all appellate stages have been exhausted, and that 10 years are left to be served on his sentence. If the tax case involves nothing more than the skimming of income from the proposed defendant's sole proprietorship, it would be pointless to institute a criminal tax case, for there is no reason to believe that, even if convicted, a meaningful additional sentence would be imposed. The specific deterrent value to be derived from that case would be marginal. Under this hypothetical, it would be a more efficient use of resources to resort to an "adequate non-criminal alternative to prosecution," e.g., "civil tax proceedings." Principles of Federal Prosecution, USAM, § 9-27.250, Subsection B. Conversely, if the tax crime was accomplished by a sophisticated scheme, such as promoting a widespread fraudulent tax shelter or refund scheme, prosecution could be appropriate even though the likelihood of an enhanced sentence for the tax crime would be remote. In that instance, the conviction for the tax crime could serve to deter other individuals from embarking on the same scheme. There will obviously be situations between these two extremes. For example, if only one year is left to be served on the nontax conviction, there may be a reason for concluding that the tax prosecution could result in a substantial, additional sentence. Another example is the submission of fraudulent returns claiming refunds by a prisoner with a long term yet to be served. A tax prosecution, as a practical matter, may not lengthen the actual time ultimately served, but it might deter other prisoners from adopting the scheme. The effect of present incarceration on the prosecution decision is to be made on a case-by-case basis. Incarceration, of itself, does not implicate any formal policy of the Department, and the personal authorization of the Assistant Attorney General is not a condition precedent to the institution of criminal proceedings simply because the proposed defendant is currently in jail. Incarceration, however, should alert the reviewing attorney to the possibility of the dual and successive prosecution policies being an issue.
4.04 HEALTH POLICY 4.04[1] General Policy On February 19, 1953, the Attorney General ordered the abandonment of the so-called "health policy" in criminal tax cases. Department of Justice Press Release, February 19, 1953. The Treasury Department had earlier rescinded its identical policy on December 11, 1951. The question of whether an individual could physically survive the stress and strain of a trial is, therefore, no longer a controlling consideration in deciding for or against a tax prosecution at the administrative level. The Department's position is that whether a taxpayer should or should not be tried because of health reasons is a matter which can best be decided by the trial court, rather than on an administrative basis. Only when it is clear beyond all doubt that a proposed defendant will never be able to stand trial because of a terminal physical condition is a case disposed of for reasons of health at the administrative level. 4.04[2] Court Determination of Health Status After the filing of an indictment or information, physical health questions should be left to the defendant to raise. The defense is customarily raised by way of a motion for continuance. The issues basically are whether the defendant is able to assist his counsel in his defense and/or whether the strain of a trial will pose a serious threat to the defendant's health. The United States Attorney should ensure that the health facts and the court's decision are made a matter of record. The following course is to be followed in this connection: (1) the special agent of the Internal Revenue Service should be asked to conduct a discrete investigation to determine the extent of the defendant's daily activities and to eliminate the possibility of malingering; (2) a request should be made of the court to have a court-appointed physician conduct an examination and, if possible, this should include a necessary period of observation in a hospital; and (3) there should be a hearing in open court to disclose for the record the results of (1) and (2) above and to enable the court to make a finding. The court's finding probably will not embrace a prognosis beyond the immediate necessity for a continuance. But if the record, as developed, makes it apparent that the defendant cannot ever stand trial, the United States Attorney should request authority from the Tax Division to dismiss the indictment or information. If the physical condition is only temporarily disabling, only a continuance should be permitted.
4.05 MENTAL INCOMPETENCY 4.05[1] Evaluation at Administrative Level In criminal tax cases, where the taxpayer is in a money-producing activity during the prosecution years, lack of mental responsibility defenses are highly questionable. Because of the nature of criminal tax cases, it would be rare for a case to be referred to the Tax Division for prosecution by the Internal Revenue Service where there is clear and convincing evidence of a mental defense calling for a decision not to prosecute at the administrative level. In the usual case where there are allegations of a mental disorder, the case is evaluated at the administrative level in the framework of whether there is guilt beyond a reasonable doubt and a reasonable probability of conviction. The net result is that except for cases where very serious mental disorders are obvious, the Tax Division takes the position that it is up to the court to determine whether a taxpayer is competent to stand trial. This determination should be made after an indictment has been returned or an information filed in accordance with the appropriate judicial procedures. See, in this connection, the discussion which follows in Section 4.05[2], Insanity Defense Reform Act of 1984. 4.05[2] Insanity Defense Reform Act of 1984 The Comprehensive Crime Control Act of 1984, Pub. L. No. 98-473, 98 Stat. 1837, made a significant series of changes in numerous areas of the federal criminal justice system. Chapter IV of the Act contains the Insanity Defense Reform Act of 1984, Pub. L. No. 98-473, 98 Stat. 1837, 2057, which governs, among other things, the insanity defense and the determination of mental competency to stand trial. Where applicable, the provisions of the Insanity Defense Reform Act can have a significant bearing on the administrative evaluation of criminal tax cases as well as on trial procedures. See USAM, § 9-9.000 and USAM, § 9- 18.000. Section 4241 of Title 18 governs procedures for the determination of competency to stand trial and related commitments of the defendant. Under Section 4241, if competency is perceived to be an issue by the prosecutor, by defense counsel, or by the court itself, a psychiatric examination may be ordered and a hearing is to be held on the defendant's competency to stand trial. See USAM, § 9-9.000 and USAM, § 9-18.000.
4.06 SEARCH WARRANTS 4.06[1] Generally Department of Justice policy formerly required that all search warrants in criminal tax cases be approved in advance by the Tax Division. This policy was based upon the premise that the law on search warrants was so unsettled that strict scrutiny was warranted. As case law concerning search and seizure developed, it became clear that, upon a showing of probable cause, the government could conduct reasonable searches for the purposes of obtaining documentary evidence establishing the commission of a crime. With case law becoming more settled, the Assistant Attorney General, Tax Division, by Directive No. 52 (January 2, 1986), which superseded an earlier 1984 Directive No. 49, delegated to certain personnel in United States Attorneys' offices the authority to approve the execution of certain limited Title 26 or tax-related Title 18 search warrants directed at offices, structures, premises, etc., of targets or subjects of the investigation. The existing authority delegated to United States Attorneys' offices and the authority reserved to the Tax Division contained in Tax Division Directive No. 52, is reproduced in Section 3.00 of this Manual. See also USAM, § 6-4.130. 4.06[2] Procedures Under Directive No. 52 In those instances where authority to approve a search warrant has been delegated to the United States Attorney's office, a direct request for a search warrant may be made by District Counsel, I.R.S., to the United States Attorney's office. Note, however, that in the United States Attorney's office, the only persons who can approve the application for a search warrant are the United States Attorney, the First Assistant United States Attorney, or the Chief of the Criminal Division in the office. This authority to approve cannot be delegated to anyone else in the office of the United States Attorney. The name and telephone number of the Assistant United States Attorney(s) in each office who, in addition to the United States Attorney, is authorized to approve search warrants under the delegated authority is to be forwarded to the Tax Division. The names will be retained in the Tax Division files, with a copy given to the Internal Revenue Service. Because the questions of privilege and status in the investigation remain sensitive legal issues, the Tax Division has delegated the authority to approve search warrants in tax cases only in those limited instances where the search warrant is directed at offices, structures, or premises owned, controlled, or under the dominion of the subject or target of a criminal investigation. The subject, or target, moreover, must not fall into the eight exempted categories listed in the delegation order (Directive No. 52, para. 4). The exempted categories, which include accountants, lawyers, physicians, public official/political candidates, members of the clergy, news media representatives, labor union officials, or officials of 501(c)(3) tax exempt organizations, are deemed to be of such a sensitive nature that prior approval of the Tax Division is still required before a search warrant is obtained. Aside from questions of strict legality, search warrants in tax investigations involve potential problems and issues intrinsic to tax cases. The concept of seizing personal or business books and records as the evidence or instrumentality of a crime is not as direct or simple as the seizure of contraband. These documents can contain information considered to be personal and confidential, and these very same documents, which, by their own nature, are not unusual, illegal, or dangerous, will be the evidence or the instrumentality of the crime to be charged. In addition to the controversial nature of such a seizure of documents, the requirement that the items to be seized must be named with specificity is more difficult to meet. In tax cases, the warrant must be specific, not only regarding the items to be seized and the place searched, but a specific time frame must also be stated, e.g., records for the years 1996 and 1997.
4.07 APPEALS The procedures and rules governing appeals are set forth in the USAM, § 2-1.000 et seq., and § 9-2.170, and should be reviewed and followed when handling a criminal tax or other appellate matter. Attention is called to the particular following procedures set forth in the USAM. In all cases resulting in adverse decisions, all recommendations for and against appeal, the filing of a petition for certiorari, and direct appeal to the Supreme Court must be authorized by the Solicitor General. This includes interlocutory appeals under 28 U.S.C., Sec. 1292(b) and litigation in state courts subject to review by a higher state court or by the United States Supreme Court. It also includes the filing of an amicus curiae brief, petitions seeking mandamus or other extraordinary relief, and the filing of a suggestion for a rehearing en banc. USAM, § 2-2.120 and § 9-2.170. The United States Attorney has the appellate responsibility for the handling of criminal tax cases in the courts of appeals that have been tried by the United States Attorney unless the Assistant Attorney General, Tax Division, elects that the Tax Division handle a particular category of cases or a case on appeal. USAM, § 2-3.100. The Tax Division, and specifically the Criminal Appeals & Tax Enforcement Policy Section (CATEPS), has the appellate responsibility for the handling of criminal tax cases that have been tried by personnel of the regional Criminal Enforcement Sections of the Tax Division. USAM, § 2-3.100. The need for immediate reporting of adverse decisions, whether at the trial level or the appellate level, is stressed in USAM, § 2-2.110 as follows: In any civil or criminal action before a United States District Court or a United States Court of Appeals, in which the United States is a litigant, and a decision is rendered adverse to the government's position, the U.S. Attorney must immediately transmit a copy of the decision to the appellate section of the division responsible for the case. To secure the necessary authority from the Solicitor General to appeal or not appeal a criminal tax case, the United States Attorney or the Chief of the appropriate regional Criminal Enforcement Section of the Tax Division "must promptly" make a report to the Chief, Criminal Appeals & Tax Enforcement Policy Section (CATEPS), Tax Division. See USAM, § 2-2.110, et seq. The Tax Division prefers that such reports be made promptly by telephone to the Chief of CATEPS at (202) 514-3011. Following receipt of an adverse decision, CATEPS solicits the views of the regional Criminal Enforcement Section of the Tax Division, the United States Attorney, and the Internal Revenue Service on appropriate further action. CATEPS then prepares a Tax Division memorandum for the Solicitor General which reflects the views and recommendation of the Tax Division, as well as the views of those solicited. In cases tried by Criminal Enforcement Section personnel of the Tax Division, the Tax Division prosecutor should confer with the United States Attorney with respect to the recommendation to be made by the Criminal Enforcement Section to CATEPS. USAM, § 2-3.100. For these and other issues relating to appeals in criminal tax cases, contact the Chief, CATEPS, Tax Division at (202) 514-3011.
4.08 REQUESTS FOR TRIAL ASSISTANCE While United States Attorneys usually have the initial responsibility for the trial of criminal tax cases, the Criminal Enforcement Sections of the Tax Division have staffs of highly qualified and specialized criminal tax trial attorneys who will prosecute or render assistance in the trial of criminal tax cases upon request. The assistance, for example, may be in the form of a senior Criminal Enforcement Section attorney of the Tax Division assuming all trial responsibilities of a particular case or in the form of a junior attorney of the Tax Division acting as co-counsel with an Assistant United States Attorney. If trial assistance is needed, the request should be in writing, stating the relevant reasons, and made well in advance of any court setting. Requests for assistance should be addressed to the Chief of the appropriate Criminal Enforcement Section, Tax Division, Department of Justice, Washington, D.C. 20530. Where time is a factor, the request may be by phone to the appropriate Chief. Such telephone requests should be confirmed in writing. See Section 1.02 of this Manual, supra.
4.09 STATUS REPORTS After criminal tax cases have been referred to a United States Attorney, it is essential that the Tax Division be kept advised of all developments. As the case progresses, the minimum information required for the records of the Tax Division is as follows: 1. A copy of the indictment returned (or no billed), or the information filed, which reflect the date of the return or filing, and the date of any no bill; 2. Date of arraignment and kind of plea; 3. Dates of trial; 4. Verdict and date verdict returned; 5. Date and terms of sentence; and 6. Date of appeal and appellate decision. It is important that information regarding developments in pending cases be provided to the Tax Division in a timely manner in order that the Department's files reflect the true case status and so that, upon completion of the criminal case, the case can be timely closed and returned to the Internal Revenue Service for the collection of any revenue due through civil disposition. USAM § 6-4.248.
4.10 RETURN OF REPORTS AND EXHIBITS Upon completion of a criminal tax prosecution by a final judgment and the conclusion of appellate procedures, the United States Attorney should return to witnesses their exhibits. All other grand jury material should be retained by the United States Attorney under secure conditions, in accordance with the requirement of maintaining the secrecy of grand jury material. Fed. R. Crim. P. Rule 6(e). All non-grand jury reports, exhibits, and other materials furnished by the Internal Revenue Service for use in the investigation or trial should be returned by certified mail, return receipt requested, to the appropriate District Director, Internal Revenue Service, Attention: Chief, Criminal Investigation Division, as directed in the Tax Division's letter authorizing prosecution, or as directed by Regional Counsel in cases directly referred to the United States Attorney.


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Young lacrosse enthusiasts learn the fundamentals of women's lacrosse in a fun environment.
Program runs April-May on weekends.
For the 2015 season, L.O. Parks & Recreation to offer
Girls Kindergarten Start-Up Program
Girls Grades 1-2 Skills & Scrimmages Program
Online Registration for 2015 is now closed. For late registration contact the Parks & Recreation Registrar at 503-675-2549.
Girls Lacrosse Grades K-2
- Grades 1-2 Skills and Scrimmages Program
- Grades Kindergarten Start Up Program
Girls Lacrosse Grades 3-8
To register for Grades 3-8 teams, visit www.loyl.org . Lake Oswego Youth Lacrosse (LOYL) offers spring season opportunities for Girls grades 3-8 and Boys Lacrosse for Grades 1-8. LOYL is a Community School Program. Community School Office, 503-534-2302.
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The Army
This chapter examines how the Army, the largest of the service branches, has confronted the challenge of recruiting a volunteer force. Over the course of the all-volunteer force (AVF), the Army has frequently made economic appeals, showcasing service as a path to economic security and upward mobility. Army recruiting ads have offered good jobs, technical training, and, increasingly, access to professional careers. Army recruiting materials in the second half of the AVF have sometimes forged links between civilian careers and militaristic imagery. In addition to promising the excitement of military action, these ads bring together more traditional forms of military masculinity with newer, business-world forms of masculinity that are gaining prominence in the larger culture. In this way, I would argue, the Army is making a bridge between the older forms of masculinity with which Army service had been associated and forms that are becoming hegemonic in the civilian world, a bridge that serves both to revitalize Army masculinity, making it seem more up-to-date, and to validate the business world as a source of status and prestige for young men.
The Army has also promised character development and personal transformation, developing a soldiering masculinity that involves young men testing and proving themselves. While this form of masculinity relies on the traditional warrior trope of facing a challenge and demonstrating strength and courage, and it involves displays of weaponry and other visual markers of warriorhood, the Army's version of soldiering masculinity is accessible and personified by "regular guys." As fits a military branch that needs to attract large numbers of recruits, in the Army, manhood seems to be a goal within reach of the average young man. The Army, more so than any other service, has also created many ads—especially those touting specific educational benefits— that could be read as gender neutral. In addition, the Army has used images of


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The Finest Rock - The very best variety of today's rock along with a selection of the Finest Rock from the last 3+ decades! For anyone who wants to keep up with the best of today's music but still enjoys the songs they grew up with.
Your one stop station for the best classics rock, 80's 70's 60's and a flavor of Blues
Radio Roadkill
Totally Rock! Totally Classic! The best selection of Classic Rock, Classic Hard Rock, and more! Thanks for listening!
Playing 24/7 Classic Rock - This station is dedicated to all who have lost their lives living The Dream.
Massive Rock Radio brings you the latest in rock, metal and alternative music! You can send request or submit to songs to firstname.lastname@example.com for airplay consideration.
NO LOGIN REQUIRED! The Home of Forgotten Classics. DC Rock brings back all the songs classic rock radio has forgotten. Streaming live loud and proud!
Three Alarm Radio - What other name would you think is appropriate for a retired Firefighter of 31 years in the service.So,we play all the HOT hits of the past,present and future.As we say, Music For All Generations.Join us on Facebook. Facebook.com/Three
Reliving The Memories Of The 60'sThrough Music - The Animals thru The Zombies (1960-1969)
Greatest hits for great listeners!
Un primer intento de audioblog en vivo.
Classic Rock Radio - like you've never heard it before! Tune in now to hear hits, near hits, and lots and lots of deep, rarely heard album tracks from the 60s, 70s & 80s. You'll also hear tracks from new albums released by Classic Rock artists.
WBAC-FM features new music by new and upcoming bands as well as contemporary artist.
The best of today's hard rock,modern rock,and metal from the 90's to today.


text: FAQs (click question to view answers) I am not staying at the hotel. Where can I park for the event? What is the layout of the event and seating arrangements? What is the dress code? What is the age minimum for this event? What is the typical makeup of attendees? Do I need to bring anything with me?


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Obama's Push for Arms Pact Tests Ability to Set Foreign Policy
President Barack Obama is doubling down on his push for Senate ratification of a nuclear arms treaty this year in a bid to strengthen relations with Russia and preserve his own standing as a world leader.
Obama will raise the treaty at a meeting today with congressional leaders, and he may make a public statement to increase pressure on wavering senators, a White House official said. The administration also will intensify its warnings about the global repercussions if the treaty fails, said the official, who asked for anonymity to discuss internal strategy.
The president needs at least nine Senate Republicans to ensure ratification of the Strategic Arms Reduction Treaty this year -- his top national security priority, he has said -- and he is facing resistance from lawmakers led by Arizona Republican Jon Kyl. Indiana Senator Richard Lugar is the only Republican who has bucked his party's leadership to urge support for the treaty.
Obama's failure to get the 67 Senate votes he needs "would be seen as a weakening of his authority as the head of our government responsible for foreign policy," said William Cohen, a former Republican senator who served as Defense secretary under Democratic President Bill Clinton. "It will look to the Russians" and many NATO allies as an "inability to conduct foreign policy."
Senate Republicans "could decide that they would rather wound Obama and, in the process, wound the country" by not ratifying the treaty this year, he said. "It's their decision."
Asked to assess the treaty's chances, Cohen said, "It is going to be pretty uphill."
More Challenges
A Senate loss would add to the global challenges that Obama must confront in the next two years. He already is diminished at home by his Democratic Party's setbacks in the midterm congressional elections and burdened abroad by the weight of trillion-dollar budget deficits, a sluggish economy and a war in Afghanistan stretching toward its second decade.
The White House also is seeking to minimize diplomatic damage from the leaking of more than 250,000 embassy cables -- an action that Secretary of State Hillary Clinton said "undermines our efforts to work with other countries."
Obama's attempts to win ratification of the START agreement may be undercut by tensions over North Korea's shelling of a South Korean island.
"There's always the danger that the Senate's attention gets diverted by a crisis," said Sharon Squassoni, the director of the proliferation program at the Center for Strategic and International Studies in Washington.
If the debate is pushed into next year, Obama would need to get even more Republican votes, since the Democrats will have six fewer senators in the 112th Congress.
'Concrete Progress'
Ben Rhodes, a White House deputy national security adviser, said Obama remains strong internationally. "There is not another leader who approaches his respect and authority," he said.
"We've made concrete progress on key issues in recent weeks like finalizing an agreement on Iraqi government formation and cementing a deeper partnership with India," Rhodes said. "And we believe we're making good progress in breaking the Taliban's momentum in Afghanistan."
Still, progress on the START pact has stalled, and Obama, who has made a new relationship with Russia a focus of his foreign policy, calls it "a national security imperative."
The treaty, which would replace one that expired last December, would reduce deployed strategic warheads to 1,550 on each side and require on-site inspections for both the U.S. and Russia.
No Urgency
Kyl rejects the notion that there's any urgency to approve the treaty. He said the Senate has "higher-priority items" to deal with, such as whether to extend the Bush-era tax cuts. And he laid the blame for the delay on Senate Majority Leader Harry Reid, a Nevada Democrat.
Reid "can bring the START treaty up anytime he wants to, but he has a different agenda," Kyl said Nov. 28 on NBC's "Meet the Press." "He wants to do the Dream Act in order to appeal to certain segments of the Hispanic community. The 'don't ask, don't tell' policy to appeal to the gay and lesbian community."
Kyl and Senator Bob Corker of Tennessee circulated a memo to their Republican colleagues last week, detailing concerns over what they said was the administration's inadequate plan to modernize the nuclear arsenal and maintain nuclear-weapons plants and laboratories.
Uncommitted to Vote
Corker and Johnny Isakson, a Georgia Republican, voted for the ratification resolution that was approved by the Foreign Relations Committee in September. So far, they haven't publicly committed to supporting the treaty if the full Senate votes on it.
The Republican objections, coupled with a closing Senate window, have raised the stakes for the White House.
"They have to go all in; they cannot afford to lose this," said Bill Galston, a former domestic policy adviser to President Clinton who is now an analyst at the Brookings Institution in Washington.
Lugar, the ranking Republican on the Senate Foreign Relations Committee, is urging lawmakers to support the treaty. He says START is needed to resume inspections of Russia's nuclear arsenal.
"This is not a casual affair," he told MSNBC on Nov. 20. "We do not have verification of the Russian nuclear posture right now."
Upgrading the Arsenal
In November, Obama offered an additional $4.1 billion to his $81 billion plan to upgrade the U.S. nuclear arsenal. That could benefit companies like San Francisco-based Bechtel Group Inc. and lead to thousands of jobs at facilities in New Mexico and Tennessee. Senator Susan Collins, a Maine Republican, called that money "a step in the right direction."
That offer may expire at the end of the year, giving senators like Corker a choice: Support Obama's nuclear arms-reduction treaty or risk losing money for home-state projects.
While the START agreement may present the most immediate test of Obama's ability to control foreign policy, it's not the only one.
In meetings timed to coincide with the Group of 20 summit in Seoul earlier this month, Obama and South Korean President Lee Myung-Bak failed to reach agreement on a free-trade accord between the two nations.
And in the Middle East, Obama is struggling to resolve a dispute between Israeli and Palestinian leaders over Israeli settlement construction that has stalled peace negotiations.
Popular Overseas
"The question is to what extent Obama can persist in the kind of pressure he's put on Israel in the past, and the Israeli government has figured out he can't go very far," said Dan Schueftan, deputy director of Haifa University's National Security Studies Center.
Still, Obama has succeeded in changing foreign opinions of America and is still viewed much more favorably than the president he replaced, George W. Bush. While not as popular abroad as when he was first elected, Obama maintains a reservoir of goodwill internationally, except in many Muslim countries.
Majorities or pluralities of people in 16 of 22 nations said they are confident that Obama will do the right thing in world affairs, according to a June 2010 survey by the Pew Research Center's Global Attitudes Project.
By contrast, the public in only three of the countries surveyed by Pew during Bush's final year in office expressed confidence in him. In each of the Muslim countries, Bush's popularity was lower than Obama's current standing.


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William O. Clark 92 of Abingdon, IL formally of Alexis, IL passed away Tuesday June 23, 2015, 7:30 pm at the Care Center of Abingdon.
Galusha, Irvin
Irvin Galusha, 93, of rural Little York, IL died at 7:50 a.m. Sunday, June 21, 2015 at his home.
Rodgers, Evelyn
Evelyn Rodgers, 86, of Roseville, IL passed away Wednesday June 24, 2015, 10:15 pm at the Roseville Rehab and Healthcare Center Roseville, IL.


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I was out with a nice model to shoot a couple of rolls (HP5 @ 400 and Delta 3200 @ 12500).
We had great fun and I am going in the darkroom to make some prints tomorrow. Right now, I havne't set up my entire darkroom but I can develop the film at home which gives me more time for printing when I am in the darkroom facilities I borrow.
Nice to be out shooting again...


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Video: Intel® 6Gb/s RAID controllers features, benefits, and technical specs outlined.
Introducing Jasper Forest: the newest addition to the Intel® Xeon® processor family.
Intel® Server Board S2600JF animated overview showcasing specifications, features, and benefits.
Offering versatility and expansion for small- to medium-sized businesses' evolving needs.
Intel® ONP for servers is designed to make it easier to test and deploy SDN and NFV solutions.
DMA coalescing and built-in intelligence enables increased performance per watt and consolidation.


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Respond to Review of Maoz Vegetarian - Saint-Andre des Arts
by vegankiwi
Review: This place was great to fuel up before an afternoon of sightseeing. You can get falafels in pita bread for a few euros and load it up with all the toppings, like olives, carrots, tomatoes, pickles and chilli sauce. There's not much seating so we went and ate ours in the view of the Notre Dame - bliss. It can get quite busy and chaotic so don't expect silver service, but when it's filling, tasty and cheap, what more do you need?
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Location: BotswanaAlbum: African & MiscellaneousAnimal Harvested or Shoot Type: African & Miscellaneous
My 51 inch Kudu bull taken with Mathews Safari Custom.
I took this 51 inch kudu bull in Botswana-Africa. We were hunting on Grudys game ranch. I was hunting a watering hole that was used by several large Kudu bulls.
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Welcome to the Friday end of the week edition of the broadcast. Coming up today, Rob & Lisa will take a look at the new movies at 6:40 with Leonard Maltin. At 7:10, it's "What to do with the Kids?". Then at 8:10, we talk with Roni the Master Gardener from "The Gardener's Choice" on Route 53 in Pembroke.
WATD Local Weather
Who We're Talking To
Karen MacNeil, from Napa Valley, joins Rob and Lisa to discuss the updated edition of her book The Wine Bible and shares tips for your holiday festivities. Visit our Audio Archives page to hear the interview!
The South Shore's Morning News
Get the top stories of the morning every 30 minutes beginning at 5:00 a.m.!
Hear the traffic and weather together every 10 minutes on the "9's"!
That's at :09,:19,:29,:39,:49, and :59 minutes past the hour.
Be in the know on business news at :16 past the hour!
And hear all your high school sports updates at :22 and :52 past the hour!
The Daily Schedule
TIME FEATURE 5:43 am Celebrity Birthdays 5:46 am Entertainment Tonight Radio Minute 5:55 am This Date in History 7:17 am Digital Pro Kim Komando 7:45 am Ed Perry with the good, the bad and the really, really stupid
Kim Komando airs weekdays at 7:17 a.m.


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Acceptability and Ascorbic Acid Content of Frozen Rhode Island Vegetables
Rhode Island Agricultural Experiment Station, 1948 - Frozen vegetables - 24 pages
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ascorbic acid content ascorbic acid retention ascorbic acid value Assistant Research Professor Associate Research Professor beans and spinach Blanching Frozen Boil 21/2 minutes Boil 3 minutes boiling water boiling-water blanch broccoli bush beans Carmelcross cent Cooked After Frozen cooked frozen product cooked vegetables cooking the frozen Diehl drained enzymes FENToN first flavor Food Res Frozen 3 months frozen and stored frozen foods frozen storage frozen vegetables Golden Cross Bantam growing seasons Head of Department Held Overnight home-type freezer inactivate Jour Kentucky Wonder Losses of Vitamin method of blanching Milliliters minutes Boil minutes Steam months 4 months off-flavor original ascorbic acid packaging packs Palatability and Ascorbic palatability ratings Peas PH.D pole beans Raw Blanching Retention of Ascorbic Rhode Island scalding significant snap beans Spancross spinach retained Steam 5 minutes steam blanching Summer Savoy Sweet Corn Table Tendergreen TRESSLER variation vegetables frozen Vitamin C Content


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About Us
Established in 1823, Munson Machinery is a world-leading manufacturer of dry bulk mixing, blending and size reduction equipment. Munson offers 17 high-performance equipment lines, each with numerous models to meet specialized requirements in the chemical, pharmaceutical, nutritional, and food/dairy industries.
Munson engineers each machine to suit individual batch or continuous processing requirements and has unparalleled experience solving the most complex bulk solids processing challenges -- and every machine is built to last.
Mixing and blending equipment for dry or moist solids or slurries/pastes includes:
- Rotary Batch Mixers
- Vee-Cone Blenders
- Ribbon/Paddle/Plow Blenders
- Cylindrical Plow Blenders
- Fluidized Bed Mixers
- Rotary Continuous Mixers
- High Intensity Blenders
Size reduction machinery includes:
- Pin Mills
- Screen Classifying Cutters
- Attrition Mills
- Lump Breakers
- Rotary Knife Cutters
- Hammer Mills
- Shredders


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San Francisco Urban Hike: Hills and Hidden Gems
- 3-hour urban jungle hiking tour in San Francisco
- Discover the city's wild side as you hike along hidden trails to off-the-beaten path locales
- Surround yourself in hidden forests full of lush plants, trees and flowers
- Tackle San Francisco's famous hills including Kite Hill and Tank Hill
- Hike up to the summit of Twin Peaks for sweeping city views
- Walk through a forest behind Sutro Tower and slide down the Seward Street Slides
- Learn interesting facts about San Francisco from your guide
Why Our Insiders Chose This Tour
There's a lot more to San Francisco than Fisherman's Wharf. On this urban hike, you'll get to explore the quaint alleys, quirky locales and hidden forest trails offering some of the best views of San Francisco you can get without having wings.
Recent Photos of This Tour
What You Can Expect
Customer Reviews
September 2015
Excellent tour! Just go you won't regret it!
June 2015
This tour was amazing!
May 2015
This trip was very good and very physical and I had been walking quite a bit. I'm sorry I forgot to tip my guide in my haste to get a cab at the end of my trip. I called Alex and told her I could tip on my credit card but got no response. Anyway she was great and I liked the tour a lot.
March 2015
Excellent walking tour. Views were fantastic and got better the higher we climbed.
December 2014
Great Hike, Alex is very knowledgeable and fun! My husband and I both really loved it and would recommend it..
October 2014
We enjoyed the tour very much and saw some parts if the city that most tourists don't get to see , our guide Alex was very knowledgeable and we hope to do more tours in he future.
October 2014
This was a really good tour with an excellent guide (Alexandra). We had a good group where everyone mixed well, which made it really enjoyable. I would recommend this tour to anyone.
September 2014
This tour was amazing!
July 2014
My husband and I really enjoyed this tour. I highly recommend it.
January 2014
I can't get over how much fun I had on this tour. I visit San Francisco about twice a year and love doing all the touristy stuff, but this tour was different, it made me feel like a total insider. The view from Twin Peaks was amazing, but my absolute favorite part was walking through the eucalyptus forest. I've already recommend this tour to friends and family and I extend the same recommendation to anyone considering to book this tour. A special thanks to our guide (sorry I forgot your name) for making this such a great experience!


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Private Landlord Tenant Checks
Do you want to reduce the risks of renting out your property?
As a private landlord, completing background checks on your prospective tenants is essential in enabling you to reduce the risks you take when letting your property. Completing thorough background checks informs your decision making process, helping to ensure that you protect your property investment and reduce rental income losses.
Experian provides two levels of tenant check reports that private landlords can use to screen new tenants; the instant report and the comprehensive report.
What are the benefits of using Experian?
- Ability to log in anytime, 24 hours a day, to view the status of a report
- Be safe in the knowledge that you have access to one of the UK's largest and most reliable databases of screening information
- Reduce your risk by learning how much rent your tenants can afford before completing property applications
- Receive ongoing support for Tenant Verifier via Experian's customer helpline and account management teams
- Only £15 for an instant report and £25 for a comprehensive report (price excludes VAT)
What's the process?
You will need to register (with your details, not the tenant's) via the button above in order to use these services. Once registration is complete, you will then need to provide us with your prospective tenant's first name, last name and email address. We will then contact the tenant for consent and to obtain the rest of the required details to complete the checks. Upon completion you will receive a report showing the results of the check.


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WP Splash Image is a plugin for WordPress to display picture, video or html code with a lightbox effect at the opening of the blog.
Requires: 3.3 or higher
Compatible up to: 4.2.5
Last Updated: 4 months ago
Active Installs: 6,000+
0 of 2 support threads in the last two months have been resolved.
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