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December 17, 1959
JEANNETTE H. JENNINGS, JOHN R. BACON, AND CONTINENTAL ILLINOIS NATIONAL BANK AND TRUST COMPANY OF CHICAGO, EXECUTORS OF THE ESTATE OF ODE D. JENNINGS, DECEASED, AND JEANNETTE H. JENNINGS, PLAINTIFFS-APPELLEESv.UNITED STATES OF AMERICA, DEFENDANT-APPELLANT.
Before HASTINGS, Chief Judge, and DUFFY and PARKINSON,*fn1 Circuit Judges.
HASTINGS, Chief Judge.
This case concerns the legal nature of certain payments made to Ode D. Jennings and Jeannette H. Jennings (taxpayers) by O.D. Jennings and Company, a corporation. Taxpayers claimed that such payments were merely the partial repayment of a series of loans made by them to the corporation and that they were non-taxable. The Commissioner of Internal Revenue contended that these payments were taxable dividend distributions under Section 115 of the Internal Revenue Code of 1939, 26 U.S.C.A. § 115. The Commissioner made a deficiency assessment which taxpayers paid and then filed claim for refund in the district court. The district court held that the amounts received by taxpayers were repayment of loans and that the deficiency taxes were erroneously assessed and ordered an appropriate refund with interest.From this decision the Government has appealed. Jeannette H. Jennings, John R. Bacon and Continental Illinois National Bank and Trust Company of Chicago, as executors of the estate of Ode D. Jennings, deceased, and Jeannette H. Jennings are appellees herein.
The ultimate issue before us is whether the advances in question constituted loans to the corporation or were additional capital investments by the taxpayers. That this question is not a new one is evidenced by the many decisions of this and other courts in delineating the various indicia as a guide in determining the intention of the parties in transactions involving closely-held corporations.
Without attempting again to evaluate these various holdings,*fn2 it is sufficient to say that they clearly point out that the intention of the parties is a major factor in determining the true nature of the relationship between the parties and the legal effect of the facts as found by the trial court. While no single test can provide the answer, Arlington Park Jockey Club, Inc. v. Sauber, 7 Cir., 1959, 262 F.2d 902, yet the courts have looked to, "among other factors, the book entries, the debt-equity ratio, the presence of an agreement to maintain proportionality between the advances in question and the acknowledged risk capital, and the expectation of repayment." Ortmayer v. C.I.R., 7 Cir., 1959, 265 F.2d 848, 854.
The following facts, amply supported by the record, are relevant to the issue at hand.
O.D. Jennings and Company (the corporation) is an Illinois corporation organized in 1923. At all times material to this case, all of the capital stock was owned by Ode D. and Jeannette H. Jennings (husband and wife), with the exception of nominal amounts owned by other officers and directors, which amounts varied slightly from time to time.
In the middle and late 1930's, the corporation found a great need for working capital. Beginning in 1935, and continuing through 1940, taxpayers made a series of cash loans, totalling $325,000, to the corporation to provide necessary working capital. These advances were evidenced by a series of interest-bearing promissory notes of the corporation. The first two had stated due dates (March 24, 1938), but the remaining sixteen were demand notes.There is no evidence of any repayment of the principal or interest on these notes prior to 1948.
On November 24, 1942, at a special meeting of the board of directors, it was agreed that because of wartime conditions, the corporation would be unable to repay the notes without depleting its working capital. Therefore, in a further attempt to preserve working capital, pursuant to a resolution of the board of directors, taxpayers were to surrender their notes to the corporation. It was agreed that the amount of the liability entry on the books of the corporation (Notes Payable) was to be transferred to a new net worth entry, "Contributed or Paid-in Surplus." It was also agreed that each of the remaining stockholders of the corporation would contribute a prorata amount to that account. The minutes expressly stated that such amounts shall "be repaid when the Board of Directors deems such action advisable."
Although the minutes announced that the notes would be surrendered and canceled, it appears from the taxpayer's exhibits in the record that the notes were not physically canceled on their face.
Attached to the minutes was a "memorandum" consisting of two short paragraphs citing among other things the factual situation in Weaver v. Commissioner of Internal Revenue, 9 Cir., 1932, 58 F.2d 755, in which the payment to stockholders out of an account entitled "contributed surplus" was held not taxable as a dividend. Taxpayer has urged that this "memorandum" and the attempts precisely to follow it in the transaction in question are strong evidence that the parties intended a continuing creditor relationship between taxpayers and the corporation. The minute book also indicates that on December 3, 1940, December 5, 1941, and November 24, 1942, taxpayer waived accrued interest on the notes in question.
During the period 1942 until 1946, the corporation engaged in war production. It enjoyed considerable success in the post-war period, and on October 18, 1948, the Board of Directors voted to repay partially each of those who had contributed to the account "Contributed or Paidin Surplus." At such time $5,000 was paid to Ode D. Jennings and $4,931.09 to Jeannette H. Jennings. On December 28, 1948, additional proportional repayments were made, including $49,999.99 to Ode D. Jennings and $49,311.30 to Jeannette H. Jennings. These payments totaled $109,242.38.
In the interim between 1942 and these repayments, one of the stockholders who held a nominal amount of stock, but who had contributed in proportion to the "Contributed or Paid-in Surplus" account and who had left the corporation, returned his share of stock to the corporate treasury; and his contribution to "Contributed or Paid-in Surplus" was returned to him.
In a joint income tax return for 1948, taxpayers did not include as income the $109,242.38 they had received from the corporation. On or about January 25, 1952, taxpayers received from the Internal Revenue Agent in Charge at Chicago, Illinois, the report of the Examining Revenue Agent, disclosing a net income of $152,315.12 and an income tax liability thereon of $79,169.02, resulting in a deficiency in income taxes of $64,398.10 for the year 1948. The Commissioner's position was that the 1948 payment was a taxable distribution of dividends. On June 24, 1952, taxpayers paid the deficiency together with interest of $12,457.94, a total of $76,856.04.
The Government concedes that the findings of fact by the trial court have sufficient support in the record. It argues, however, that the court erred in concluding therefrom that the legal effect of such findings warranted the conclusion that the advances in question were loans and not contributions to capital in the light of many of the objective tests controlling such a determination.
However, the Government does not contend that the advances were contributions to equity capital ab initio. It admits that until the action of November 24, 1942, such sums were loans. It argues that the transfer on that date from the liability account to the special net worth account extingushed the debtor-creditor relationship and marked the beginning of a proprietary relationship. It cites a number of the standard indicia claimed to exist here in support of this contention.
We have held, on an issue similar to this, that the problem before us involves a "mixed question of law and fact" and that we may review "the legal effect of the facts as found by the trial court." Ortmayer v. C.I.R., 7 Cir., 1959, 265 F.2d 848, 854. See also, Bogardus v. Commissioner, 1937, 302 U.S. 34, 39, 58 S. Ct. 61, 82 L. Ed. 32; Helvering v. Tex-Penn Co., 1937, 300 U.S. 481, 491, 57 S. Ct. 569, 81 L. Ed. 755; Helvering v. Rankin, 1935, 295 U.S. 123, 131, 55 S. Ct. 732, 79 L. Ed. 1343. The facts in the instant case are not in dispute, and we are not called upon to determine whether they find sufficient support in the record or are clearly erroneous, as was the situation in Zeddies v. C.I.R., 7 Cir., 1959, 264 F.2d 120, 126.
We hold that the district court reached the correct result in this case on the basis of its findings. Support for this is found in the various corporate resolutions and minutes relating to this transaction; the acknowledged obligation of repayment; the undisguised attempt to follow the approved technique in the Weaver case (looked to here by us as evidence of intention of the parties rather than as a controlling legal precedent); and the significant fact that all parties agree that at the outset the advances were undeniably loans and not contributions to capital.
We have considered the other factors urged by the Government as indicating a contrary purpose and intent. However, in our consideration of the transaction as a whole, we must conclude that the post-1942 conduct of the parties did not effect a change in their debtor-creditor relationship.
We hold that the district court did not err in holding that the payments to taxpayers in question constituted the repayment of loans and that no part thereof is includible as taxable income. The decision of the district court is in all things
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The Message of Samuel Paperback
Personalities, potential, politics and power
by Mary J. Evans;
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The Message of Samuel
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Mary Evans engages with these books in the conviction that they are a vital part of God's Word, full of teaching that is dynamically relevant for all Christian believers. Exploring how we should interpret and respond to the stories today is both challenging and exciting. This accessible and stimulating study takes us into the narratives, creatively brings out their application and provides questions for further reflection.
The Message of Samuel by Mary J. Evans was published by Intervarsity Press in February 2004 and is our 15825th best seller. The ISBN for The Message of Samuel is 9780851112954.
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Romania and Slovenia have confirmed United States accusations that Iraq tried to buy equipment from them that could be used to build nuclear weapons. Secretary of State Colin L. Powell told the United Nations Security Council that in 1999 and 2000, Iraq had tried to buy from Slovenia, Romania, India and Russia gas centrifuge equipment that could be used to produce fuel for nuclear weapons. Iraq has denied the accusations. But the Romanian foreign minister, Mircea Geoana, confirmed such reports yesterday, adding that Iraq's attempts ''were blocked by collaboration between the Romanian and American secret services.'' Slovenian Foreign Minister Dimitrij Rupel told local television that Iraq had tried to buy nuclear equipment.Continue reading the main story
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John Rogan Stats | College Football at Sports-Reference.com
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John Rogan | IBDB: The official source for Broadway Information
The official source for Broadway information, statistics, dates, cast, crew and creative staff credits, roles and related facts
Lyndhurst Youth Soccer Club - (Lyndhurst, NJ) - powered by...
A youth sports organization offering soccer to children ages 6 to 14 ... Name Position Phone Profile EMail; John Rogan: President: 201-832-8927: Charles Lesny
Business Profiles
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Xing: John Rogan
customer support/marketing / Teramo / translations, traduzioni, localization, english, italian, translation agency, language service provider, translation agency Teramo, italian translations
Xing: John Rogan
Client Executive / Wilton
Researchgate: John Rogan
Luimneach, Ireland
John Rogan (Clark University, Worcester) on ResearchGate ...
John Rogan of Clark University, Worcester with expertise in Higher Education, Quantitative Social Research is on ResearchGate. Read 94 publications, and ...
Private Homepages
JOHN ROGAN PHOTOGRAPHY - Home
John Rogan Photography. Captures incredible Landscapes True Life Portraits Breathtaking Wedding and Event Photographs
John E. Rogan, MD - Internist in Middletown, CT | MD.com
Visit Dr. John E. Rogan, an internist in Middletown, CT. Are you Dr. Rogan? Sign up for MD.com.
John Rogan - YouTube
As a professor at CUNY, Dr. Kaku is often asked by students, "What does physics mean to me?" His answer is simple. Everything. All of the major technological advances ...
Air Quality Planning Unit | Ground-level Ozone | New England | US EPA
John Rogan (email@example.com) 617-918-1645: Best Workplaces For Commuters: Gary Rennie (firstname.lastname@example.com) 617-918-1525: Carbon Monoxide Programs
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John Rogan at Clark University - RateMyProfessors.com
Rating and reviews for Professor John Rogan from Clark University Worcester, MA United States.
Belfast Interpool League - John Rogan
Belfast Interpool League Team John Rogan Page. ... C, 09/05/16 08:00 PM, John Rogan, A - W, Darren Dempsey, Away walkover ...
John Rogan - Clegg Food Projects
John Rogan Construction Director. Having been involved in dozens of food industry projects, John's practical experience is a great benefit to food industry ...
Who's in charge - Sogeti
John Rogan. Michiel Boreel. Global Chief Technology Officer Michiel Boreel. Olivier Lepick Global Secretary General. Head of Legal, HR and Communication
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ratemyteachers: John Rogan
Quarryville, PA, Swift Middle School
classmates: John Rogan
St. Rose High School, Carbondale, PA, 1963-1967
classmates: John Rogan
Queen of Peace High School, North Arlington, NJ, 1983-1987
classmates: John Rogan
East Brunswick High School, East Brunswick, NJ, 1959-1963
Celebrities & Politicians
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IMDB Filmography: John Rogan
Actor, Intermission
Bad news
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legacy.com: John Rogan
John Rogan of Archbald died Friday at Abington Manor, Clarks Summit. He is survived by his wife of 44 years, Josephine Violanti Rogan, of Archbald. Born in Olyphant, son of the
legacy.com: John Rogan
John Rogan, 72 St. Cloud August 30, 1938 - May 31, 2011 Mass of Christian Burial will be at 10:30 AM on Monday, June 6, 2011 at the Church of St. Paul in St. Cloud, for John
legacy.com: John Rogan
John Rogan, 72, St. Cloud, died 05-31-2011. Arrangements: Williams Dingmann Family Funeral Home, St. Cloud. Vis. at church 4-8 p.m. Sun., June 5 & 1 hour prior to
Convict Records: John Rogan
John Rogan. John Rogan, one of 306 convicts transported on the Fortune and Alexander, January 1806. Name, Aliases & Gender ...
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John Rogan Family Tree - 100% Free Genealogy & Family History ...
Research John Rogan's Family Tree, We're 100% Free! Research John Rogan's family history and trace the Rogan family lineage back hundreds of years.
John Rogan II - HULL Web Site - MyHeritage
Citation text: John Rogan Gender: Male Birth: 1816 - Windsor Marriage: Spouse: Charlotte Rogan (born Bellamy) - Aug 1 1836 - Parramatta V1836188 90
John Rogan - Freepages - Ancestry.com
Birth MemoDates of birth for John Rogan vary as reported on located records. Most immigrants from poor families did not know their birthday or ...
John Rogan (1839 - 1921) - Genealogy
Genealogy for John Rogan (1839 - 1921) on Geni with over 100 million profiles of ancestors and living relatives. Page updated March 1, 2013.
john rogan on Scratch
john rogan on Scratch by john2clutch
Books & Literature
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The Biggest Snowball Ever! by John Rogan — Reviews, Discussion ...
The Biggest Snowball Ever! has 77 ratings and 12 reviews. Jessica said: The Biggest Snowball Ever!John RoganThis book is about children that go out to...
Catalog of Copyright Entries: Third series
ALONG ABOUT NOW; w 4 m Johnny Rogan (John Rogan) © John Rogan; 27Feb63; EU759358. ALWAYS A BRIDESMAID; w 4 m Mark Barkan k Pay 1963 13 ...
Color Of Law - Google Books Result
What they knew about John Rogan from previous testimony was twenty years old: that he had been a bad cop who liked to hurt people and did it frequently.
Cross-Gender Shakespeare and English National Identity: Wearing the ...
... Crowden Henry Bolingbroke: David Threlfall Thomas Mowbray: David Lyon Duchess of Gloucester: Paola Dionisotti The Lord Marshal: John Rogan Edward, ...
BBC - (none) - Words & Music - Happiness
Actor Simon Russell Beale curates a sequence of words and music on the theme of happiness. Emma Fielding and John Rogan read poems and texts by Wordsworth,...
Related Documents
File:John-Rogan.jpg - Wikimedia Commons
File:John-Rogan.jpg. No higher resolution available. John-Rogan.jpg (244 × 281 pixels, file size: 28 KB, MIME type: image/jpeg).
John Rogan, Marketing and customer care at Going green translations
View all of john rogan's Presentations.
Canon John ROGAN - Personal Appointments (free information from...
Free company information from Companies House including registered office address, filing history, accounts, annual return, officers, charges, business activity
Scientific Publications
dblp: John Rogan
List of computer science publications by John Rogan.
Agate Type: the rogans of sumner county, tennessee
... also named John Rogan). Bud Rogan never stopped growing during his life, eventually reaching the height of 8 feet, nine inches before his ...
Publications Authored by John Rogan - PubFacts
Publications Authored By John Rogan. 2015Oct. Tasks completed by nursing members of a teaching hospital Medical Emergency Team. Intensive Crit Care ...
Video & Audio
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Top 5 Tallest Man in the World - YouTube
▶ 1:29John Rogan is second tallest man in the world. John Rogan was born in 1868 and was died in 1905 in ...
John Rogan - Hudl
Check out John Rogan's Football highlights on Hudl. John Rogan goes to Mansfield Legacy High School in Mansfield, TX. John Rogan plays for the team ...
Top 10 Tallest People in the World ever !!! - YouTube
The tallest person in the World is Robert Wadlow The second tallest person in the World is John Rogan and The tallest woman is Trijntje Keever http://thetall...
The 30 Tallest People Ever - YouTube
Tallest people in history. Robert Wadlow John Rogan Trijntje Keeve Don Koehler Zeng Jinlia Sultan Kosen Väinö Myllyrinne Zhao Liang Gabriel Estêvão Monjane S...
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Gritty play about a loser is the 'perfect fit' for Father Ted star
11.01.2012 [Evening Standard] - When Tom got in touch I wanted to get involved straightaway. "When you do stand-up you go out feeling invincible, but you have to lose yourself when you go on stage in something like this." Port Authority also stars John Rogan and Andrew Nolan.
John Rogan: New Lingnan University Library
Spanning a period of more than 30 years, John Rogan has worked in libraries in a number of countries, principally Australia, but also Malaysia, England, ...
John Rogan - TV.com
John Rogan biography, pictures, credits,quotes and more...
Trees under multiple threats - News - telegram.com - Worcester, MA
The May 9 story in the Telegram & Gazette about the continuing, successful battle against the Asian Longhorned Beetle infestation in Worcester is a reminder...
Reports & Statements
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pinterest.com: John Rogan (ca. 1865-1905) was one of the tallest men reported since ...
Another picture of John Rogan (ca. 1865-1905), the second tallest man in history at 8′ 9″. He is noticeably heavier here than in later photos; he had a wasting ...
Wikipedia: John William Rogan – Wikipedia
John William Rogan (* 16. Februar 1865 in Hendersonville, Tennessee; † 12. September 1905 ... März 2015. Biografie und Familiengeschichte von John Rogan, wie von der kompilierten University of South Florida Heritage Projekt Africana.
John Rogan, "The Negro Giant" | Travalanche
This post is one of a series honoring Black History Month. John Rogan (ca. 1865-1905) was one of the tallest men reported since the beginning ...
Google Groups: GC Working Again
27.08.2002: John Rogan ... soa help Good Point! "Lee Tetz"
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John Rogan - Citas de Google Académico
J Rogan, J Miller, D Stow, J Franklin, L Levien, C Fischer. Photogrammetric Engineering & Remote Sensing 69 (7), 793-804, 2003. 140, 2003. Remote sensing ...
John Rogan Profile - Metacritic
Reviews and scores for films involving John Rogan.
Actor John Rogan in conversation with Jonathan Harden
One of the country's most prolific disabled actors, John Rogan talks to Jonathan Harden for the latest episode of the UK's #1 acting podcast.
Customer Experience: John Rogan, IMSCAN • DFS - Document ...
Customer Experience: John Rogan, IMSCAN. Site Admin | August 24th, 2015. IMSCAN is a leading provider of Document Management and Business Process ...
John ROGAN | National Anzac Centre
You are here. Convoy searchJohn ROGAN. John ROGAN. First name. John. Surname. ROGAN. Regiment number. 381. Unit. 2nd Light Horse Regiment, ...
John Rogan - Alchetron, The Free Social Encyclopedia
Cause of death Ankylosis Name John Rogan, Weight 175 lb (79 kg) Height 2.68 m. John Rogan wwwthetallestmancomimagesjohnwilliamroganjohn.
John Rogan - FoSci SIG DatabaseFoSci SIG Database - ESP KTN
John Rogan. Business Change Officer, Home Office CAST. Stakeholder: Home Office Centre for Applied Science and Technology Challenge: Is it possible to ...
John Rogan - Ottawa Real Estate & MLS® Listings | Houses, Condos ...
"My father worked until he was 86 – I'll bet I last longer!" John Rogan began his Real Estate career in 1967 with W.H. Bosley Real Estate in Toronto. Ten years ...
John Rogan - The 1788 - 1820 Pioneer Association
THE 1788 - 1820 PIONEER ASSOCIATION INC. THE PEOPLE IN THE LIFE AND TIMES OF LACHLAN AND ELIZABETH MACQUARIE John Rogan Born: c1780 ...
John Rogan - The Richard Stone Partnership
CV. John Rogan. Theatre. Television & Film. Radio & Voice. Skills. artist profile. John Rogan. THEATRE includes: 2015, RULES FOR LIVING, Francis, Marianne ...
John Rogan | Tinkercad
Tinkercad user John Rogan. ... 3D printed, 19. John Rogan's Things. ChanelJohn. John Rogan a day ago. Get started with Tinkercad. Registering an account is ...
John Rogan, Real Estate Agent - Walnut Creek, CA - Coldwell Banker ...
John Rogan is a Coldwell Banker Residential Brokerage real estate agent serving Walnut Creek, CA and the surrounding areas.
The Honest Actors' Podcast » Blog Archive » 1.12 - John Rogan
John Rogan. Recorded at his home on 03.06.15 (Running Time: 32 mins). Want to contribute? Subscribe and leave a rating on iTunes, send a ...
After John Rogan - Phillip Maisel
After John Rogan 2011. Stack of National Geographics, 8 feet 9 inches tall. John Rogan is known as the second tallest man ever recorded. He was born in ...
Information Wanted :: Search results for: John Rogan
MISSING PERSON'S INFORMATION. Name: John Rogan. Gender: Male. Age: Earlier Name Used: Alias: Description: Other: ...
Michael John Rogan, MD | Geisinger
Visit Geisinger.org for information on Michael John Rogan, MD. Find contact information, medical education, affiliated hospitals and more.
John Rogan 1780–1830 - Australian Royalty: A family tree of colonial ...
Text: John was tried and convicted at thge General Quarter Sessions of the Peace for the Borough of Liverpool on 15 Jan 1805. Since records ...
5 Largest Giants in History! | History Rundown
John Rogan. John Rogan, the second tallest person to ever live, was born in Tennessee, between years 1865 and 1868(exact year unknown).
Boar's Head Inn Construction - Albemarle Charlottesville Historical ...
Description: Boar's Head Inn construction. Pictured are John Rogan with two others. Part of the Rip Payne Collection. Photo unidentified and undated by Payne.
John's star-struck whirlwind of fame - Hartlepool Mail
JOHN Rogan's life sounds like the plot of a Hollywood film.
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text:
"Honest Compliments" haha. Only in LA...
ps I'm not used to seeing Ty Segall sitting down for a set. This should be an interesting show on Thursday...
"Honest Compliments" haha. Only in LA...
ps I'm not used to seeing Ty Segall sitting down for a set. This should be an interesting show on Thursday...
i went to holy ghost when mbv did the "5 minute break". i meant to go back but i was having so much fun i never did. so what exactly happened after that? did they play with just the stage amps?
Originally Posted by menikmati
I'm locking this fucker.
Yo la Tengo and Flume stole the show for me yesterday. I definitely can't do these festivals like I used to, but it was an enjoyable weekend. Deerhunter was tops.
Review: Powerful surprises at every turn at FYF Fest 2013
Performers and 20,000-plus fans are wonderfully unpredictable as the left-of-center FYF Fest overtakes L.A. State Historic Park for a mini-Coachella-like festival.
By Randall Roberts, Los Angeles Times Pop Music Critic
5:00 AM PDT, August 26, 2013
Those looking for evidence that the 10th annual FYF Fest had hit a Saturday afternoon peak found it during songwriter Ty Segall's set. As he and his band pushed a hard-strummed acoustic guitar-driven song, the crowd up front danced frantically.
Suddenly, a pair of pants flew up from the pit, floated in the air, legs akimbo, then drifted back into the crowd. Up they flew again, and you had to wonder about the potentially trouser-less participant below. Was he or she so lost in the moment that the pants just had to go? Judging by the enthusiasm, I'd wager yes.
Whether pants and human were ever reunited is unknown. But the hits, however underground they may have been, just kept on coming this past weekend at Los Angeles State Historic Park in Chinatown.
PHOTOS: FYF Fest 2013
A shaggy-headed Mikal Cronin delivered catchy, acid-drenched rock to the gathered masses Saturday afternoon. Across the pitch on another stage, Brooklyn rap duo the Underachievers sampled the Rolling Stones' "Gimme Shelter." The veteran L.A. punks in Flag tore through Black Flag's "Gimme Gimme Gimme," singer Keith Morris bellowing the chorus.
As more than 20,000 underground rock, soul, folk, punk, house, hip-hop, techno and experimental electronic music fans baked in the sun and then chilled under the stars, TV on the Radio offered hard new material — huge guitar anthems that echoed off the warehouse walls. Los Angeles beat producer Nosaj Thing delivered thick, scatterbrained synthetic rhythms and sampled Kendrick Lamar's L.A. anthem "Bitch Don't Kill My Vibe." Mesmerizing guitar rock band Deerhunter's lead singer, Bradford Cox, sang with his head enveloped in a creepy-looking scarf.
Each was memorable in its own way, part of a music event whose tastes are as wonderfully unpredictable as the music swirling within shuffle-generation brains. An event geared to the tastes of the left-of-center music fans, FYF offered a virtually seamless and aesthetically varied two-day festival. The pit during San Francisco garage punk band Thee Oh Sees was swirling, crowd-surfing chaos — but so was the sweaty center of the dance tent when Horse Meat Disco dropped the classic synth-disco jam "Funkytown" by Lipps Inc.
FYF Fest: The Sunday artists to see, hour by hour
Four stages, dozens of food trucks and merchants spread over an easily traversable plot of acreage, FYF Fest has been called a mini-Coachella, which is somewhat accurate. The fests share an aesthetic — indie rock, punk, dance music and hip-hop — and many of the bigger bands at FYF, including the Yeah Yeah Yeahs, My Bloody Valentine, MGMT, Dan Deacon, TV on the Radio and Devendra Banhart, have also performed in Indio. This event is much more manageable, for obvious reasons, and as such it's much more relaxing.
But despite the smaller scale, the surprises arrived with equal power.
Magnificent soul singer Charles Bradley and his band poured every ounce of sweat into their late Saturday afternoon performance. Wearing maroon pants, vest and a sheer black shirt, the sixtysomething Floridian roared through the sunshine, his Screamin' Jay Hawkins-suggestive yowls and Otis Redding-esque pleadings echoing across the park. A commanding performer, Bradley should offer lessons to many of the young singers around the festival. He foot-shuffled, he thrust his pelvis, he gesticulated with his arms while offering big-boned soul and blues. He was impossible to ignore.
Jonathan Richman performed an early Sunday set under a hot sun, singing an ode to suffering that seemed apt. Wet with sweat from dancing, the Boston iconoclast sang about the necessity of pain. "When we refuse to suffer, when we refuse to feel, your life becomes a bore, and you're suffering even more," he sang.
Later that afternoon, young singer-songwriter Mac DeMarco delivered a rousing set of smart songs that had his growing fan base screaming along. His "Ode to Viceroy" was a love song to his favorite cigarette. One fan honored the sentiment by smoking — while crowd surfing.
PHOTOS: FYF Fest 2013
But on a bigger scale, what the FYF Fest has accomplished goes further than merely throwing a great outdoor music party. When the festival moved from a duct-taped, DIY gathering occurring (in the early years, just barely) in Echo Park to L.A. State Historic Park, the producers saw land perfect for a festival. They were the pioneers of that plot and helped lay the foundation for other music festivals to use the land for large-scale events. With the downtown Los Angeles skyline as a backdrop and a yellow moon hanging low in the sky, evidence that this is a perfect use of the land surrounded us.
And though in years past, FYF suffered from growing pains — long lines, artists not having adequate preshow accommodations — these hiccups have passed. Though the site was crowded, the vibe remained calm, easy and, well, nice.
For example, during a break in Torrance hard-core punk band Joyce Manor's tough Saturday set, unfortunately shortened by technical difficulties, a moshing fan screamed up from the pit that he'd lost his phone. As technicians worked on a powerless amp, singer-guitarist Barry Johnson asked to crowd to keep an eye out. Ha. Yeah, right.
A few minutes later, though, as the band tore through scream-along punk and the fans slammed and crowd-surfed, a single arm shot up from the mess, holding a Samsung. Crisis averted — though whether the phone survived the stomping feet is another issue.
Whiskey Sour
2 oz blended whiskey
Juice of 1/2 lemon
1/2 tsp powdered sugar
1 cherry
1/2 slice lemon
Shake blended whiskey, juice of lemon, and powdered sugar with ice and strain into a whiskey sour glass. Decorate with the half-slice of lemon, top with the cherry, and serve.
Awesome day 2 - not a huge MBV fan, so glad I skipped out on what sounds like it was a rough performance. The Miranda stage was awesome all day, caught Baroness, Les Savy Fav and Touche Amore - all sounded great on that stage. Flume was a surprise, and Pional was vibey (glad I made it for this). Kurt's set sounded pretty good from the beer garden as well. Everyone else think Day 2 was much better for general overcrowding + the bathroom lines?
anyone knows the setlist for MBV? did they play their regular 17 song set? which songs had technical difficulties? thanks!
They did not play close to the 17 songs...they only had 1 hr and 15mis, and at least 5 mins of that was them off stage fixing shit. The sound first cut out in Only Shallow, and then again in the following song, so then they stopped, "fixed it", and came back with "Wonder 2" with some shitty blown sound. But then kicked into Soon, and it sounded better after that. The ending of You Made Me Realize was amazing though of course.
We had to get the rocking-est award for Deerhunter bangin the rail towards the left of the stage amidst generally stationary folk, though some rockers came late in the set next to us seeking out action. So excited. Great songs (played a fave 'Revival', which early eighties new romantic bands would have killed to write/perform) and good looking lads.
Grips: Twenty minute line to use the head was fucked up. Food was pretty shite and/or unavailable.
The pilgrimage is not perfected save by copulation with the camel.
Shame about all the issues during MBV... kind of left the festival on a down note. Sunday was really unimpressive to me. It looked great on paper, but everything I saw was just "okay," no stand outs. Saturday was pretty damned good though... Breeders were good, as was Charles Bradley. I wished I'd seen more of Horse Meat Disco, because they were fantastic for the portion of the set that I saw. A couple of surprises for me - SMD with Bicep was far, far better than I was expecting (I've seen SMD DJ sets and thought they were overhyped... so I'm gonna give credit to Bicep ) Kept trying to leave because I was tired, then they'd drop another great track. The standout of the weekend was Deerhunter though. I was originally planning on going to see Delorean, because I've seen Deerhunter a couple of times before, and am so glad friends talked me into seeing Deerhunter instead. I'm in awe of how good they were. They've become the band I must see each time they tour...
You guys are so weird. I see NO talk about Chk Chk Chks Amazing performance. So much energy. You could tell they were feeding off the crowd. Awesome set list. very heavy on new material and it all sounded so good. Such a great set!
Superfan will be in front of the Fonda masturbating furiously to a photo of him taking a photo of a band. Set is from 8:05 to approximately 8:05:15. Guest list only.
Upcoming Shows: Spamalot (7/31), HARD (8/1) 2001 Space Odyssey with LA Phil (8/12), Opeth (10/18), TOOL (10/31), Coachella 2016 (WK1), David Gilmour (Wherever I need to go)
By the way, I dont know what bathroom phone issues everyone was having on Saturday. Sunday had neither of those issues.
Did anyone end up seeing Omar Souleyman? I waited for like 15 minutes and he never went on, so I just went home.
Superfan will be in front of the Fonda masturbating furiously to a photo of him taking a photo of a band. Set is from 8:05 to approximately 8:05:15. Guest list only.
Upcoming Shows: Spamalot (7/31), HARD (8/1) 2001 Space Odyssey with LA Phil (8/12), Opeth (10/18), TOOL (10/31), Coachella 2016 (WK1), David Gilmour (Wherever I need to go)
I don't know why, but my wife and I decided to skip yesterday and just stay home... Coming from Long Beach, partly taking the Metro, just seems like such a chore. I feel bad that we bought a two day pass and only went to one, but at least we got to see some good stuff on Saturday. I had another friend who skipped yesterday as well...
How awful was MGMT...?
Fri: LCD Soundsystem, M83, Underworld, the Kills, FOALS, the Last Shadow Puppets, Joey Bada$$, BORNS, Miami Horror
Sat: Guns N' Roses, Ice Cube, CHVRCHES, Courtney Barnett, Run the Jewels, the Arcs, Gary Clark Jr., Silversun Pickups, Lush, Moon Taxi, DMA's
Sun: Major Lazer, Flume, Rancid, Miike Snow, Edward Sharp, Matt & Kim, Cold War Kids, Wolf Alice, Anderson Paak, Joywave, the Heavy, Meg Myers
omar souleyman was tons of fun. guedita, delorean was snoozy so you didnt miss anything.
The festival was lots of fun, the VIP was worth it just for no bathroom lines, no food and booze lines and decent sight lines of some stages.
The MBV issues brought back flashbacks of Radiohead at Outside Lands.
This was a thoroughly enjoyable festival, despite the unfortunate sound issues during MBV. "Big" festival that still feels small enough to the point where I could get close to the stage, a crowd that by and large is there for the music and actually listening to the music, fun times with boardies. I thought it was strange that we weren't allowed to bring sealed water bottles INTO the VIP section.
Superfan will be in front of the Fonda masturbating furiously to a photo of him taking a photo of a band. Set is from 8:05 to approximately 8:05:15. Guest list only.
Upcoming Shows: Spamalot (7/31), HARD (8/1) 2001 Space Odyssey with LA Phil (8/12), Opeth (10/18), TOOL (10/31), Coachella 2016 (WK1), David Gilmour (Wherever I need to go)
Superfan will be in front of the Fonda masturbating furiously to a photo of him taking a photo of a band. Set is from 8:05 to approximately 8:05:15. Guest list only.
Upcoming Shows: Spamalot (7/31), HARD (8/1) 2001 Space Odyssey with LA Phil (8/12), Opeth (10/18), TOOL (10/31), Coachella 2016 (WK1), David Gilmour (Wherever I need to go)
Yeah they sounded really great I thought. Dull on stage with no movement but lots of bands are like that. Good setlist (though im sure most of the festival crowd could have done without Siberian Breaks in full) with a bunch of 1st album picks outside of the obvious ones along to ridiculously over the top psych visuals. And they actually PLAYED Kids for the first time in years instead of just piping it in and dancing around like ass clowns. Was actually very very happy about their set given the low low expectations.
Superfan will be in front of the Fonda masturbating furiously to a photo of him taking a photo of a band. Set is from 8:05 to approximately 8:05:15. Guest list only.
Upcoming Shows: Spamalot (7/31), HARD (8/1) 2001 Space Odyssey with LA Phil (8/12), Opeth (10/18), TOOL (10/31), Coachella 2016 (WK1), David Gilmour (Wherever I need to go)
He sold his soul for a shot at fame
Catchphrase and wigs and the jokes are lame...
Omar Souleyman was pretty cool. Only walked into that tent because of the schedule void for us, and it was a fun, energetic set. He played past his time, which was nice. I didn't realize he was a late start. I was bummed about missing flume earlier :/
It's only "stuff" so it's not that big a deal (other than the inconvenience and expense of getting a new phone), though I did lose some good photos, including one with my son and the singer of the Orwells. It just sucks to be reminded that even a great music festival is not immune to the shitty people that live among us.
That is crazy and unfortunate, especially happening so close to the stage. Jack-off for sure.
!!! was good, but I didn't feel their set was worth raving about -- way less energy than the other times I've seen them -- but I guess I'm biased because I don't like their new album that much and wish they'd have played more from Louden Up Now and Myth Takes, which IMO are much more fun live than most of the stuff they played.
Omar Souleyman went on went on about 20 minutes late, I think. (I ended up skipping him). Was so beat that I couldn't make myself go into the tent, ended up sitting at the very back of MGMT. They were surprisingly OK. I hadn't seen them since a few shows in 2008, when they were absolutely awful live each time.
I have to say that this was just a superb festival, Saturday especially. I arrived at 2.30 and moved from stage to stage and not pausing until Charles Bradley finished. Great sets all the way around on Saturday, but sticking out were Mikal Cronin, Bradley, Roky Erikson, Deerhunter and Thee Oh Sees.
Sunday was not quite as good but the Orwells and Les Savy Fav stood out for me. Kurt Vile, Beach House and Yo La Tengo were also solid sets. I caught only a few songs of Mac Demarco and Washed Out, but got to hear the main "hits" from each and both sounded good.
My biggest takeaway from the weekend (other than my phone) was how well-curated this lineup was. You had ear-pleasing strumming guitar rock, synthy dream-pop, soul from the soul and some psychedelic quasi-punk (how's that for a genre), among other things.
As an old classic rock dude, I relished the return of the front man - Charles Bradley, Tim Harrington of Les Savy Fav, Bradford Cox and the dude from the Orwells (who gave all new meaning to "jock rock")
Logistically, the food and beer lines were manageable and entry was vastly improved. It looks like the finally got stage placement right. There was very little sound-bleed and the sight-lines were excellent. They also did a much better job controlling the dust, even with the breeze in the late PM. The only negative was the bathrooms on Saturday. You would think that any concert promoter would have an easy-to-execute algorithm of how many bathrooms are needed for a certain number of people. Credit to them, though, for adding 60 toilets the next day.
Overall, very well done and enjoyable.
We had a great weekend. Really liked the crowd; it felt like everyone was there to listen, and was respectful of one another. We had to have been one of the few older couples there, but we never felt out of place. Bathroom situation was weird, until we figured out that there was never a wait in the beer gardens. Dust cloud could no doubt be seen from space. Food choices were not stellar, but awesome fish tacos from the food truck by the Samantha tent. Somehow did not see a single one of you (well, possibly cansei der sexme if he is no longer a baby-faced giant but is now a bearded giant).
My pick in the never-heard-them-before-but-now-a-fan category: METZ. The drummer is fantastic.


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Part-Time Assistant Volunteer Coordinator/Special Projects
Posted on October 12, 2016
Job | Bryn Mawr, PA, US
ElderNet of Lower Merion and Narberth
We are hiring!
About us
ElderNet advocates for increased quality services to elderly and disabled adults. Through our dedicated volunteers and collaborative efforts with local civic and religious organizations, national foundations, businesses, and other social service agencies, ElderNet works to fill the gaps in services for frail elderly and disabled individuals in Lower Merion and Narberth.
ElderNet provides dependable volunteer services that improve access to medical care, ease isolation, and offer practical help with shopping, banking, and home repairs. When older or disabled adults can no longer live safely in their homes, ElderNet provides information on alternative living facilities that are most equipped to assist those in need of additional care.
Additionally, ElderNet operates the Ada Mutch Community Resource Center and Food Pantry where low income residents of Lower Merion and Narberth can access income assistance with our social worker, see a nurse for blood pressure checks and flu shots, as well as choose two grocery bags of food pantry items every other week.
Volunteering , Human services , Disability , Poverty and hunger , Health and medicine , Seniors and retirement , Bala Cynwyd , Gladwyne , Ardmore , Lower Merion , , , , , , More
Contact information
Government ID number: 23-2005485
Email: Log in to view email addresses.
Phone: 610-545-0706
9 South Bryn Mawr Avenue, Bryn Mawr, PA, 19010, US


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Eagle Scout Bumper Sticker$1.9913 1/2" x 2 3/4" sticker will last for years. Learn More
Im Proud of My Eagle Scouts - Bumper Sticker$1.9914 1/2" x 2 3/4" durable vinyl sticker is screen printed with fade-resistant inks. Perfect for Scoutmasters and families with more than one Eagle Scout! Learn More
Cub Scouts® Tattoos―5-packOriginal Price:$4.99 Current Price: $1.98Easy to apply and loads of fun! Temporary skin stickers are made of surgical tape, so they're safe for skin. Includes five stickers: three paw prints (one blue, one yellow, and one blue/yellow tie-dye) and two stickers that read "Cub Scouts" in blue/yellow tie-dye. Learn More
50-Miler Domed DecalOriginal Price:$2.49 Current Price: $1.9850-Miler artwork is embossed on Mylar, printed in transparent inks, and capped with a polyurethane dome to create a beautiful 3-D effect. Measures 2 3/4" x 2 1/4". Learn More


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Lyrics Depot is your source of lyrics to Here Today Gone Late Today by Frenzal Rhomb. Please check back for more Frenzal Rhomb lyrics.
Here Today Gone Late Today Lyrics
Artist: Frenzal Rhomb
Album: Not So Tough Now
Good to know that you've been had
Time to tell you that your life's so bad
You show no difference between camps
Not looking forward to those morning cramps
Here today gone late today
You're one fascinating type
It's so amazing how you read between the lines
The t.v. shows you what to do
But it can't tell you what it thinks of you
The politics you can replace
With looking for the truth in melrose place
Now you know that it's the best
To find the answers in central park west
Frenzal Rhomb Lyrics
Frenzal Rhomb Not So Tough Now Lyrics
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Home > Holokai Kayak Adventure
Located on the windward coast of Oahu, Holokai Kayak and Snorkel Adventure resides in Kaneohe Bay home to Oahu's only barrier reef and the famous sunken island sandbar. We are the one and only eco-friendly educational adventure outfitter in Kaneohe. 100% of proceeds go to our not-for-profit local child care company, Kama'aina Kids. We offer a multitude of adventures from kayaking and snorkeling Coconut Island (Gilligan's Island!) to a semi-private hobie catamaran sailing adventure to the Sunken Island Sandbar with sea turtles and manta rays on the way! We would love to help cultivate a unique and memorable Hawaiian experience for you and your family!
Enjoy a guided eco-tour with our certified instructors. Your journey will take you to the protected waters of Kaneohe Bay, which is an ideal place for kayakers of all skill levels.
The 3 hour adventure begins with thorough instruction by our certified guides at He'eia State Park. Journey to Kaneohe Bay which is protected by Oahu's only Barrier Reef.
The 3 hour adventure begins at He'eia State Park where the participants will have time to learn the feel and balance of standing on a board in flat water.


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Air Méditerranée
Air Méditerranée airline vector logo. Air Méditerranée is a low cost airline based in Le Fauga, France. The airline started operations in 1997. It was established and started operations in 1997. Air Méditerranée operates passenger, cargo and chartered flights mainly from Charles de Gaulle Airport.
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Details of this Paper
Abnormal Psychology: Historical and Modern Perspectives
Question;1);In psychology, if the term;?abnormal? means ?away from normal,? what problem;does this definition present when;categorizing someone as being ?abnormal??;A) It does not measure standard deviations.;B) It does not assume that deviation on both sides of average is;negative.;C) It does not assume abnormality is negative.;D) It does not allow for positive deviations.;2) The term;?deviance? implies;A) looking;different.;B) behaving differently.;C) having;a mental illness.;D) engaging;in criminal wrongdoing.;3) Gerry is a;night watchman who has worked at the same company for 25 years. He is described;as very shy and withdrawn around others. While this behavior is not problematic;at work, his relatives find him ?weird? and tend to shun him at family;gatherings. Despite encouragement by his immediate family to mingle, Gerry;hardly speaks to others at these events. According to the ?goodness-of-fit?;concept, Gerry?s behavior would;A) not;be viewed as a problem at family gatherings.;B) not be viewed as a problem at work but would;be viewed as a problem at family gatherings.;C) not;be viewed as a problem at all.;D) only;be viewed as a problem if it caused difficulty for his immediate family.;4) Which of the;following terms is defined as the shared behavioral patterns and lifestyles;that differentiate one group of people from another?;A) race;B) ethnicity;C) culture;D) group;expectations;5) Which statement;below is TRUE of the original definition of a culture-bound illness?;A) It;is less severe than other forms of mental illness.;B) The;abnormal behavior is specific to a particular location or group.;C) It;is usually found only in children.;D) The;behavior usually requires hospitalization in the home culture.;6) The case of James Eagan Holmes described in your text;highlights the;A) shift;from eccentricity to behaving dangerously.;B) stereotyping;of a person with mental illness.;C) importance;of early intervention in culture-bound illnesses.;D) influence;of the media on defining abnormal behavior.;7) Juan is a;freshman at a local university. He gets up at the same time each day and;follows the same pattern: showering and shaving, dressing, and checking his;backpack for required books, notebooks, and pens. Early in the first semester;this behavior took approximately 30 minutes. As the semester progressed, Juan;spent more and more time checking and rechecking his backpack to make sure he;had everything he needed. Toward the end of the semester, Juan was always late;for his first class because of his ?thoroughness.? A psychologist might;conclude that Juan?s behavior is;A) typical;for a conscientious student.;B) dysfunctional;even if not distressful.;C) not;abnormal because it does not cause problems for others.;D) normal;according to the ?goodness-of-fit? model.
Paper#54987 | Written in 18-Jul-2015Price : $22


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"We would all like to vote for the best man but he is never a candidate." - Frank McKinney "Kin" Hubbard
HTS costs up to $300 a month to operate. We need your help!
Now for IPv6 ^.^
hi .. how to hack a website? plss teach me thanks a lot


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Join Nafisa Sharriff and the West African Dance Family for Free Classes every Monday and Wednesday evening from 6pm – 8pm at Countee Cullen/PS 194. located on 144th Street between Adam Clayton Powell and Frederick Douglas Blvds in Harlem, NY.
Summer Hours: 5pm – 7pm (July and August only).
Nafisa Sharriff is a Master Teacher and Choreographer of Traditional West African Folklore from the Old Malian Empire. She is the recipient of the 1996 Ethnic Dance Award and numerous Community Service commemorations. Throughout her illustrious career Nafisa performed with Stevie Wonder, Whitney Houston, Spike Lee, TC Carson, C&C Music Factory, The Chuck Davis Dance Company & The Kairaba West African Dance Company. Her television credits include performances on the Richard Pryor Show, Dance Black America & Positively Black.
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Strathspey Guest House Bourton-on-the-Water
Strathspey Lansdowne, Bourton-on-the-Water, United Kingdom Show Map
Check in from 15h / Check out prior to 10h
Strathspey Guest House Bourton-on-the-Water: Find photos, reviews, information, amenities and compare prices for 3 stars hotels in Bourton-on-the-Water, United Kingdom.
Situated within the scenic countryside of Bourton-on-the-Water, Strathspey Guest House Bourton-on-the-Water provides comfortable accommodation and a wide range of facilities, such as a garden and parking. It is located just a short stroll from a number of popular bars, clubs and restaurants.
Hotel description
The guest house features rooms equipped with a hair dryer, plus all the necessities to ensure an enjoyable stay.
A satisfying breakfast is available for purchase, and there are numerous restaurants and eateries close by. Each evening, guests are welcome to relax in the comfortable lounge bar.
Bourton-on-the-Water's well-known attractions and landmarks are within close proximity to Strathspey Guest House Bourton-on-the-Water, with the Cotswold Motoring Museum just a brief walk away. It also provides an ideal location to explore Lower Slaughter and Cheltenham.
Hotel features
Pet Friendly, Bar / Lounge, Hair Dryer, TV
Availability and Prices
Booking Site
Room Type
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