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3 bedroom home yard , waiting for your touch. HUD CASE # 241-895289, home is 203k eligible, Go to HUDHOMESTORE for submission. SAGEACQ for more information. All disclosures.are in documents~ .! Equal housing opportunity.Call CSS and make your appointment today.

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Event: Nana Patekar, Shreyas Talpade, Paresh Rawal, Asrani and others were snapped on the sets of the film KAMAAL DHAMAAL MALAMAAL.
Guest List: Shreyas Talpade, Nana Patekar, Shailendra Singh, Paresh Rawal, Priyadarshan, Asrani
Bollywood badshah Shah Rukh Khan was snapped at lightbox. He's all set for the trailer screening of his forthcoming film RAEES.
Bollywood actress Shraddha Kapoor was snapped at Bandra.
Bollywood actress Dia Mirza was snapped at the inauguration of Dr.Batra's photo exhibition.
Bollywood actor Akshay Kumar was snapped on the sets of Yaaron Ki Baraat.
Bollywood actress Sushmita Sen was snapped at the inauguration of art show Masterstrokes 35.


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- Product Description
This Interactive Notebook may be used with any curriculum or textbook. Students will create 23 foldable booklets, all realted to the topic of U.S. Government. There are booklets on the location of and facts about the Capital, Executive Branch, Legislative Branch, Judicial Branch, Congress, Senate, House of Representatives, Presidency, How Laws are Made, Constitution, Supreme Court, Citizenship, National VS State Government, vocabulary, and more. Templates and instructions included.
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Knowledge Box Central is the premier lapbook producer thanks to Cyndi Kinney's incredible insight and application of learning styles. KBC's team of awesome writers and designers create these amazing tools for hands-on learning while having fun. KBC helps you with your child's learning by utilizing breakthrough techniques, like color psychology, and well known practices that enhance interest and retention.


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This community is for beginners and experts willing to share their Odoo knowledge. It's not a forum to discuss ideas, but a knowledge base of questions and their answers.
How to make file phyton can be editable in windows 7?
Hi, I have installed "openERP all in One 7 latest" on windows 7 Profesional, and I want to modify some file .py in "addon". But when I try to save the modified file there is a warning :
"Unable to save C:\Program File.. "
How can I save that file? thanks
Hi , your installation is in program file , where it is protected by default by windows so if you wish to edit your py file , you should use administrator right , RUN AS administrator for your editor , before you open the py file, hope that help.
hi, thanks for the answer, it's so helpful I had already tried and it works
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Company: WeiMin Industrial
X-Y Table:X-axis Table -> Ballscrew manual transmission. Stroke 110mm.Y-axis Table -> Ballscrew manual transmission. Stroke 110mm.WAFER stage: Using pneumatic Lift 0.66mm4"CHUCK: Vacuum adsorption method.Two sets of test pin adjustors. Contact result will be indicated by an LED light.With Microscope set.
Company: Langer EMV-Technik
The IC testing system is designed for the measuremet of EMC behavior of circuits (ICs) at specific radiated or conducted disturbance influences and for transmission measurements. The test IC is tested in operation. The ICE1 test environment generates the functional environment of the test ICs. The respective measuring task is done with the appropriate probe set. These sets are not included in the scope of delilvery.
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History Under the Influence looks at world leaders from 336 B.C. to the 21st Century and the effects drugs and alcohol had on their decision making while holding power. Their decisions were made during times of war and peace that impacted the lives of millions. John F. Kennedy acted in key moments during this presidency under the influence of amphetamines which had long lasting ramifications through the 20th century. His use of amphetamines is related to the building of the Berlin Wall and may have played a part in the Cuban Missile Crisis. Between 1941-1945, Adolf Hitler was prescribed more than 70 medications, including amphetamines and cocaine. Toward the end of his life and the end of the European theater of World War II, Hitler displayed physical symptoms that some relate to him suffering from Parkinson's disease. Others argue they're also symptoms of heavy amphetamine use. Germany's defeat in World War II was made by bad strategic planning on Hitler's part, which may have been fueled by drug use prescribed to him by his personal physician. Winston Churchill and Joseph Stalin were functioning alcoholics before, during and after World War II. Churchill has also been thought to have taken amphetamines during World War II to help him stay awake during long nights during the war. Stalin was responsible for the deaths of millions of Russians during the Great Purges. Some argue that his murderous decisions were fueled by his alcohol use, while others suggest he may have been clinically insane. Richard Nixon drank heavily and may have been under the influence of the drug Dilantin, which is an antiepileptic drug. Nixon was not epileptic but may have taken it for other reasons which may have seriously impacted his behavior... something had to account for his bizarre behavior that was observed by many in and around the White House. Word on the street is they even took the nuclear launch codes away from him without his knowledge. Ping-Pong Diplomacy hatched when Chinese Chairman Mao Zedong was in a barbiturate induced haze. Military mastermind Napoleon Bonaparte may have lost at Waterloo due to the effects of opiates on his thinking. His physicians prescribed the drug to him before the battle to relieve pain from which he suffered. Not a lot is known about the Kim family that rules North Korea, but word has trickled out that they may have a penchant for alcohol and there are hints they take narcotics and methamphetamines. North Korea is one of the most repressive counties in the world, and the Kim's appear to have little regard for the well-being of their citizens. And the list goes on... More than a year of research, writing and editing went into History Under the Influence, and it looks at a "dark little corner" of history that isn't often discussed. Many times an author of a biography will discuss a leader's substance abuse and move on without bringing it back up again and tying the effects on the person's mind while making decisions that impact their country or area of rule. History Under the Influence does that.
About British Academy Post-Doctoral Fellow Philip WoodI was one of the weird ones in college - on any given day you could have found me in the library doing research. I graduated with a degree in anthropology where I concentrated in archaeology and minored in history. Then as the glutton for punishment I am, I went back and got a second bachelor's degree in journalism, and for more than ten years I was a print journalist. People, culture and history have always fascinated me. While we were all taught that Columbus sailed the ocean blue in 1492, we weren't taught that he was a distant second to other seafaring peoples. History that is plainly there for people to see but not really examined for one reason or another is where I'm drawn. History Under the Influence, my first book, goes there. It looks at sides of world leaders we know are there, but for some reason we don't really discuss too much about their inebriations and the impacts it had on their decisions/policy making while holding their office. This is the sort of stuff I'm interested in, and this is the sort of stuff that makes history come alive.
Details Book
|British Academy Post-Doctoral Fellow Philip Wood
|Data Published
|26 April 2015
|Format Book
|PDF, Epub, DOCx, TXT
|Number of Pages
|144 pages
|Age +
|15 years
Reviews History Under the Influence
Margo Anderson Get eBook History Under the Influence
Finally I get this ebook, thanks for all these I can get now!
Lisa Doran Best website free download ebook
I was suspicious at first when i got redirected to the membership site. Now I'm really excited i found this online library....many thanks Kisses
Markus Jensen How to download History Under the Influence eBook?
I did not think that this would work, my best friend showed me this website, and it does! I get my most wanted eBook
Sandy Griffon to British Academy Post-Doctoral Fellow Philip Wood - thanks
wtf this great ebook for free?!
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My friends are so mad that they do not know how I have all the high quality ebook which they do not!
Tina Milan
It's very easy to get quality ebooks ;)
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Lukasz Czaru
so many fake sites. this is the first one which worked! Many thanks
Caroline Smith
wtffff i do not understand this!
Andrew Smith
Just select your click then download link, and complete an offer to start downloading the ebook. If there is a survey it only takes 5 minutes, try any survey which works for you.
Kevin Mason
lol it did not even take me 5 minutes at all! XD


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It will have 3 variations of Kaiser Game available. Right now only 1 Variation will be launched. Thanks for Visiting Web Kaiser, hope to see you again in the game, launch date Jan 29th, 2011.
We are looking for Kaiser players to Demo out the Online Kaiser Gameplay so please drop an email to : webkaiser -at the rate- webkaiser.comFeel free to Try the Online Kaiser Demo (there is no forced bid as in original kaiser , bidding goes till you can bid (12 max). Right now GUI system remains to be built for 2 more players, and a basic AI system will be build. But feel free to try the Online Kaiser with a twist.


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Welcome to pds. Plastic and Dermatological Surgery is a leading plastic and dermatological service in the Midlands, developed by its Medical Director Mr Dalvi Humzah, a Consultant Plastic, Reconstructive and Aesthetic Surgeon.
He is fully registered with the General Medical Council (Registration No. 3296503) and holds a licence to practice medicine; his name appears on their Specialist Register for Plastic Surgery. He is a full member of the British Association of Plastic, Reconstructive and Aesthetic Surgeons (BAPRAS) which was formerly the British Association of Plastic Surgeons (BAPS).


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Border Papers volume 1: January 1585
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and his rowmes, Davie Dowgles for his rowmes, John Gledstones of Wyndeton hall,View result
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Parishes Broughton BROUGHTON Broughton parish (2,083 a.) lies some 2 miles south-west of Banbury and includes the townships of Broughton (975 a.) and North Newington (1,108 a.). 1 In 1592 Broughton was the larger township, containing 1,442 a.; 2...View result


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Cameron Diaz is sharing the screen with a host of Hollywood's leading men in her next several projects, but she appears to be bringing a consistent accessory to the set of her recent movies - her short shorts!
Cameron - and her lovely legs - were photographed walking through Heathrow Airport in London on Tuesday, alongside Colin Firth as the pair filmed a scene for their new big screen comedic caper, "Gambit."
PLAY IT NOW: Cameron Diaz Talks 'Bad Teacher,' Her Friendship With Drew Barrymore & Avoiding The London Paparazzi
Along with her daisy dukes, Cameron also donned a studded belt, cowboy hat, boots, black tank top and long suede jacket. Yee-haw!
The film, which began shooting earlier this month, is a remake of the 1967 film starring Michael Caine and Shirley MacLaine. It follows a British thief (played by Caine, and now Firth) who comes up with a fool-proof plan to steal an expensive statue from one of the world's richest men.
VIEW THE PHOTOS: There's Something About Cameron Diaz!
Cameron plays a lovely young woman roped into the heist by the thief because she resembles the tycoon's late wife.
The Coen brothers - Joel and Ethan - penned the remake's script.
However, fans won't have to wait for "Gambit" to hit theaters to catch Cam and her gorgeous gams on the big screen.
VIEW THE PHOTOS: Access' Top 10 Movies We Can't Wait For In 2011!
The bombshell also rocks a pair of short shorts in a car wash scene for her upcoming release, "Bad Teacher," co-starring Jason Segel and her real-life ex, Justin Timberlake.
The campus comedy is set for release on June 24. CLICK HERE for the trailer!
VIEW THE PHOTOS: Justin Timberlake: From The Stage To The Red Carpet!
But when it comes to taking care of her famous legs, Cameron said it takes a lot of hard work.
"My major motivation is just to feel strong and be healthy and live the most active life that I can because that's important to me," Cameron recently told Access Hollywood at CinemaCon in Las Vegas, where she was promoting "Bad Teacher."
"I do all kinds of exercises, everything from lifting weights to running," she revealed. "I like to be active. I really feel health is really important and we have to take care of our bodies and it's just something that I've been doing for a really long time."
Copyright 2011 by NBC Universal, Inc. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.


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Zoom in on images of the latest designer watches and luxury jewellery, plus unique wedding bands, unusual engagement rings, celebrities and more.
Like a miniature aquarium swimming with diamonds and fish, the Twenty-4® Haute Joaillerie Ref. 4909/110 "Aquatic Life" shows the world that Patek Philippe is at the top of its trade when it comes to the art of gem-setting.
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By Goher Iqbal Punn, Film Critic & Entertainment Analyst, Showbiz Bites
Piku 4th day box office collections (1st Monday) – the film showed that it was there to stay. On its 4th day in domestic market, the business came up nice and this is what is being expected from the film. Piku so far has been really nice with great word of mouth. Even the repeat audiences too are being reported at theaters. This all proves that the content, on which this film is based, is really catchy and interesting.
Piku 4th day box office collections in domestic market are 4.90 crore, which is really heart-hitting and heart-warming from all aspects. The stakeholders are much excited with the way the movie has been going on.
The film's so far business in Indian circuit has now landed at the whopping sum of 30.12 crore, which is superlative. It now seems that soon the film will touch the 50 crore mark. Come back to read more on this movie. Till then have fun with other posts such as Bhiaravi Goswami's cleavage show photos and Ranbir Kapoor's most favorite song.
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Please note all OUTLET sales are final. For more information, please visit our Shipping & Returns Policy page.


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|Date Listed
|London, ON, Canada
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If you are looking for someone qualified to do repairs on your house inside or outside. I am well established in the field. I have years of construction experience, big and small. I own my own tools for the job. So if there is anything I can assist with or do for you.
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Perpetual online auction-offers reviewed weekly. List price is contractual price. Tax/Assessment information has not been verified. Buyer or buyer's agent responsible for confirmation of information contained herein.
Features Multi Family
|Total Number of Units: 2
|Estimated Age: 1965
|Total Lot Square Feet: 0
|Unit 1 Parking: None
|Taxes: $4,415
|School District: Sun Prairie Area
|Short Sale/Foreclosure: Foreclosure
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Cute! Welcome to 732 Fenton Ave! Adorable 3 bedroom home in cute, quiet neighborhood. This super clean, move in ready home features a deck, shed, fenced in yard, living room and family room with fireplace, first floor laundry and large kitchen. All appliances stay. Room sizes are approximate. Why rent when you can own your own home for less!


text: Success of stem cell transplantation is in part determined by delivery of adequate numbers of hematopoietic stem and progenitor cells (HSPCs) to efficiently reconstitute the hematopoietic system in the recipient. A potential strategy to expand HSPCs and improve their engraftment is through modulation of marrow microenvironmental components that normally regulate HSPCs [1]. This strategy is feasible in the case, for example, of parathyroid hormone-mediated stimulation of marrow osteolineage cells [2–5]. One recently discovered microenvironmental factor that regulates HSPCs is prostaglandin E2 (PGE2). Prostaglandins are synthesized by many cell types in the marrow microenvironment, including osteoblastic cells [6, 7]. PGE2 and other metabolites in the prostaglandin pathway expand the HSPC pool through activation of the EP2 and EP4 receptors and thereby improve their repopulating ability [8–10]. While we have demonstrated that systemic administration of PGE2 in mice expands a subset of HSPCs with limited self-renewal [11], the mechanisms by which this occurs have not been defined. Moreover, while the effects of ex vivo PGE2 treatment have been explored both in murine models and non-human primates [8, 10, 12], it is unclear whether administration of PGE2 in vivo has beneficial effects on hematopoietic recovery. This issue has pragmatic implications since the long-acting PGE2 analog 16,16-dimethyl-PGE2 (dmPGE2) is well tolerated by patients [13, 14]. Therefore, in this manuscript we tested the hypothesis that in vivo PGE2 treatment may decrease apoptotic rates of HSPCs in both naïve mice and during hematopoietic stress.


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August 22, 1968
Newman & Co., Societe Financiere De Transports et D'Entreprises Industrielles (Sofina) S.A., Societe Pour La Finance et L'Electricite, S.A., Plaintiffs,
United States of America, Defendant
Tenney, District Judge.
TENNEY, District Judge:
This is an action for refund of income tax withheld pursuant to section 1442 of the Internal Revenue Code of 1954, 68A Stat. 358 (amended Nov. 13, 1966). Jurisdiction is founded upon 28 U.S.C. [*] 1346(a)(1). The action was timely instituted and is a case of first impression. Plaintiffs and defendant have all moved for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure and have filed herein a joint statement pursuant to Rule 9(G) of the General Rules of this court, setting forth the material facts as to which there is no genuine issue to be tried. It seems clear that the only issue is one of law and that summary judgment is the appropriate remedy. A brief recital of the underlying facts, however, is necessary and may prove helpful.
During the period in question (1954-1958), plaintiffs Societe Financiere de Transports et d'Entreprises Industrielles (SOFINA), S.A. (hereinafter called "Sofina") and Societe pour la Finance et l'Electricite, S.A. (hereinafter called "Solec") were foreign corporations not engaged in a trade or business within the United States. Sofina was a Belgian corporation while Solec was a corporation organized under the laws of Luxembourg.
Solec and Sofina were the beneficial owners of the majority of stock in three United States corporations: American Intercontinental Trade Service Company (AMITAS), Inc. (hereinafter called "Amitas"), Sulectra, Inc. (hereinafter called "Sulectra"), and Belgian Services Corporation (hereinafter called "BSC"). This stock was registered in the name of Newman & Company (hereinafter called "Newman"), a domestic partnership which acted as nominee for Solec and Sofina.
At various times during the period 1954-1958, Amitas, Sulectra and BSC distributed appreciated securities in unrelated corporations to their corporate stockholders. Newman, in accordance with the provisions of section 1442 of the Internal Revenue Code of 1954, withheld tax at the appropriate rate on each dividend. However, the amount of tax withheld was computed based on the adjusted basis of the property distributed, i.e., $1,137,318.55. Upon audit, the Internal Revenue Service determined a deficiency (subsequently assessed) on the ground that Newman should have computed the withholding tax based on the fair market value of the appreciated securities at the time of distribution, i.e., $2,572,941.16.
Section 1442 provides for withholding of tax at a rate of 30 per cent (or less, if so provided by treaty) on items of income earned in the United States by foreign corporations not engaged in trade or business within the United States.
While sections 1442 and 1441 relate to the withholding of the tax, it is section 881 which imposes the tax on such corporations.
§ 881 [68A Stat. 282 (amended Nov. 13, 1966)]. Tax on foreign corporations not engaged in business in United States.
(a) Imposition of Tax.
In the case of every foreign corporation not engaged in trade or business within the United States, there is hereby imposed for each taxable year, in lieu of the taxes imposed by section 11, a tax of 30 percent of the amount received from sources within the United States as interest (except interest on deposits with persons carrying on the banking business), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income (including amounts described in section 631(b) and (c) which are considered to be gains from the sale or exchange of capital assets).
§ 1442 [68A Stat. 358 (amended Nov. 13, 1966)]. Withholding of tax on foreign corporations.
In the case of foreign corporations subject to taxation under this subtitle not engaged in trade or business within the United States, there shall be deducted and withheld at the source in the same manner and on the same items of income as is provided in section 1441 or section 1451 a tax equal to 30 percent thereof; except that, in the case of interest described in section 1451 (relating to tax-free covenant bonds), the deduction and withholding shall be at the rate specified therein.
Section 1441, defining the items of income on which withholding is to apply, reads as follows:
§ 1441 [68A Stat. 357 (amended Nov. 13, 1966)]. Withholding of tax on nonresident aliens.
(a) General rule.
Except as otherwise provided in subsection (c), all persons, in whatever capacity acting (including lessees or mortgagors of real or personal property, fiduciaries, employers, and all officers and employees of the United States) having the control, receipt, custody, disposal, or payment of any of the items of income specified in subsection (b) (to the extent that any of such items constitutes gross income from sources within the United States), of any nonresident alien individual, or of any partnership not engaged in trade or business within the United States and composed in whole or in part of nonresident aliens, shall (except in the cases provided for in section 1451 and except as otherwise provided in regulations prescribed by the Secretary or his delegate under section 874) deduct and withhold from such items a tax equal to 30 percent thereof.
(b) Income items.
The items of income referred to in subsection (a) are interest (except interest on deposits with persons carrying on the banking business paid to persons not engaged in business in the United States), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income, and amounts described in section 402(a)(2), section 403(a)(2), section 631(b) and (c), and section 1235, which are considered to be gains from the sale or exchange of capital assets.
Were the question limited to the interpretation of §§ 881, 1441 and 1442, little difficulty would be encountered, 881 imposing the tax and 1441 and 1442 encompassing the collection by means of withholding. The difficulty is that § 301, relating, among other things, to distributions of property by a corporation to a corporate distributee, permits the corporate distributee to treat as income either the fair market value of the property received or the adjusted cost basis of the distributing corporation, whichever is lower, whereas the withholding provision of § 1442 as defined by § 1441 would compel treatment of such a distribution as being made to a non-resident alien (rather than to a corporate distributee) and require withholding on the basis of the fair market value.
§ 301, which, together with § 881, forms part of Chapter I of the Revenue Act of 1954, provides as follows:
§ 301 [68A Stat. 84 (amended Nov. 13, 1966)]. Distributions of Property.
(a) In general.
Except as otherwise provided in this chapter, a distribution of property (as defined in section 317(a)) made by a corporation to a shareholder with respect to its stock shall be treated in the manner provided in subsection (c).
(b) Amount distributed.
(1) General rule.
For purposes of this section, the amount of any distribution shall be -
(A) Noncorporate distributees.
If the shareholder is not a corporation, the amount of money received, plus the fair market value of the other property received.
(B) Corporate distributees.
If the shareholder is a corporation, the amount of money received, plus whichever of the following is the lesser:
(i) the fair market value of the other property received; or
(ii) the adjusted basis (in the hands of the distributing corporation immediately before the distribution) of the other property received, increased in the amount of gain to the distributing corporation which is recognized under subsection (b) or (c) of section 311.
. . .
(3) Determination of fair market value.
For purposes of this section, fair market value shall be determined as of the date of the distribution.
(c) Amount taxable.
In the case of a distribution to which subsection (a) applies -
(1) Amount constituting dividend.
That portion of the distribution which is a dividend (as defined in section 316) shall be included in gross income.
(2) Amount applied against basis.
That portion of the distribution which is not a dividend shall be applied against and reduce the adjusted basis of the stock.
(3) Amount in excess of basis.
(A) In general.
Except as provided in subparagraph (B), that portion of the distribution which is not a dividend, to the extent that it exceeds the adjusted basis of the stock, shall be treated as gain from the sale or exchange of property.
(B) Distributions out of increase in value accrued before March 1, 1913.
That portion of the distribution which is not a dividend, to the extent that it exceeds the adjusted basis of the stock and to the extent that it is out of increase in value accrued before March 1, 1913, shall be exempt from tax.
(d) Basis.
The basis of property received in a distribution to which subsection (a) applies shall be -
(1) Noncorporate distributees.
If the shareholder is not a corporation, the fair market value of such property.
(2) Corporate distributees.
If the shareholder is a corporation, whichever of the following is the lesser:
(A) the fair market value of such property; or
(B) the adjusted basis (in the hands of the distributing corporation immediately before the distribution) of such property, increased in the amount of gain to the distributing corporation which is recognized under subsection (b) or (c) of section 311.
In Rev. Rul. 57-470, 1957-2 Cum. Bull. 608, the Internal Revenue Service held that:
" The 'gross amount' upon which withholding is required under section 1.1441-2 of the Income Tax Regulations [effecting the provisions of section 1441] is not determined under section 301(b)(1)(B) of the Code, since section 301(b)(1)(B) is not applicable to non-resident foreign corporations. Such dividends in kind are subject to withholding at full fair market value."
On the basis of Rev. Rul. 57-470, supra, the Commissioner assessed the tax in this case. The question is whether such assessment was illegal and erroneous. After full consideration, I find that it was not, and that the Commissioner acted properly.
§ 881 of the Internal Revenue Code of 1954 is the expression of Congress' intention and the underlying statutory authority to tax foreign corporations not engaged in a trade or business in the United States. Where such a foreign corporation earns income in this country, its sole contact with the United States is the income which it receives and once that income has left this country it has escaped the effective reach of the taxing authority, and any tax due is for all intents and purposes uncollectible. The only effective means is the withholding of tax at the American source of that income earned by the non-resident foreign corporation. As stated in 8A Mertens, Law of Federal Income Taxation, § 47B.01 (Rev. ed. 1964):
"Withholding of tax and payment of the tax at the source have proven invaluable in facilitating the proper collection of this revenue. It is the duty and obligation of the payor of income, under the withholding provisions, to collect the tax for the Government by deducting the proper amount and remitting only the balance to the non-resident recipient. The payor in most cases is the more responsible person, has no incentive to understate the income payable, and is constantly subject to the personal jurisdiction of the courts.
In the Internal Revenue Code of 1954, § 1442 provides the means of implementing § 881, that is, the collection procedure whereby the tax is withheld at the source. In actual fact, however, § 1442 does not in itself describe the items subject to tax nor does it provide the detailed mechanics of collection. Instead, it refers to § 1441 for these administrative provisions. By the same token, the regulations under § 1442 do not seek to spell out any of the details concerning that section but instead make reference to the regulation under § 1441 which deals with withholding of tax on non-resident aliens. Treas. Reg. § 1.1442-1. Such regulation is unequivocal in stating that where dividends are concerned tax must be withheld on the gross amount of the dividend, not on any net or otherwise reduced amount. The regulation states as follows:
"Income subject to withholding -
(a) Fixed or determinable annual or periodical income. (1) The gross amount of fixed or determinable annual or periodical income is subject to withholding. Section 1441(b) specifically includes in such income interest, dividends. . . "
Accordingly, it is apparent that the regulations carry out the intent of Congress to collect tax while it is feasible to do so and before it becomes uncollectible on the gross amount of the income
in question. Where the distribution is in cash there is, of course, no difficulty in ascertaining the "gross amount". Likewise, where the distribution is in property instead of cash, there is no difficulty for the measure of income is the fair market value of the property received. 2 Mertens, supra, at § 11.03. Therefore, the relevant regulation requires the taxation of dividends to foreign corporations not engaged in a trade or business in the United States at a fixed rate of the gross amount of the dividend received, i.e., the amount of cash or the property received (at its fair market value).
This is consistent with the Code itself since § 1442 provides for the withholding of the tax on such foreign corporations on the same items of income as provided in § 1441, which, under subparagraph (b) thereof include dividends. It seems clear that such dividends as are involved herein must be taxed at the fair market value under § 301(b)(1)(A) since the non-resident alien would come within the description of a non-corporate distributee.
Plaintiffs seek to graft § 301(b)(1)(B) onto §§ 881, 1442 and 1441 in complete disregard of the provisions of §§ 1442 and 1441 which dictate the applicability rather of § 301(b)(1)(A). In other words, they are attempting to apply § 301(b)(1)(B) to a situation to which it cannot apply and to which it was never intended to apply. On the face of the statute the provisions of § 301 can only apply when the distributee regardless of its legal status is also subject to taxation by the United States. To apply it to any other situation would render it meaningless. The section must be read as a whole. Thus § 301(b)(1)(B) must be read together with § 301(d) which provides that there be no increase in basis of appreciated property in the hands of a corporate distributee when it receives a distribution of such property. This is in accord with the Congressional scheme which prevents a corporation from stepping up its basis in property by distributing it to its subsidiary at very little tax cost while, at the same time, artificially creating a new basis, thereby increasing the depreciation deduction on the property or reducing the gain on its sale. See H.R. Rep. No. 1337, 83d Cong., 2d Sess. 34 (1954),U.S. Code Cong. & Admin. News, p. 4025.
Obviously, the distributee must be subject to taxation by the United States, for otherwise of what concern is it how a distribution is treated in the hands of the distributee if the latter is not within the scope of United States taxation?
Section 301 cannot apply to the plaintiffs Sofina and Solec who were not subject to domestic taxation other than through the provisions of §§ 881 and 1442 and who, when they sell the appreciated property received as a dividend, will not be subject to the United States Law and will pay no taxes.
Only if § 301 is read as excluding from its coverage foreign corporations not engaged in a trade or business within the United States is it consistent with §§ 1442 and 1441. Furthermore, if there is any ambiguity in the statute, then the Court must consider the word "corporation" as used in § 301 with reference to the other relevant portions of the Act, such as §§ 1442 and 1441.
"It would do violence to the rules of statutory construction or interpretation to single out and divorce a single phrase in a section without reference to the other portions of the Act and without reference to the manifest purpose of Congress. The legislative intent is to be determined 'not by taking the word or clause in question from its setting and viewing it apart, but by considering it in connection with the context, the general purposes of the statute in which it is found, the occasion and circumstances of its use, and other appropriate tests for the ascertainment of the legislative will.' Helvering v. Stockholms Enskilda Bank, 293 U.S. 84, 55 S. Ct. 50, 54, 79 L. Ed. 211. See, also: United States v. American Trucking Ass'n, 310 U.S. 534, 60 S. Ct. 1059, 84 L. Ed. 1345; Harrison v. Northern Trust Co., 317 U.S. 476, 63 S. Ct. 361, 87 L. Ed. 407." Mercantile-Commerce Bank & Trust Co. v. Commissioner, 165 F.2d 307, 310-11 (8th Cir.), cert. denied, 333 U.S. 868, 92 L. Ed. 1146, 68 S. Ct. 791 (1948). See also Emery v. Commissioner, 166 F.2d 27, 1 A.L.R.2d 409 (2d Cir. 1948).
Indeed, legislative history, a factor of prime importance in construing a statute where ambiguity exists, Commissioner of Internal Revenue v. Bilder, 369 U.S. 499, 8 L. Ed. 2d 65, 82 S. Ct. 881 (1962), would appear to support the Government's position herein.
Prior to the enactment of the Internal Revenue Code of 1954, no distinction was made when appreciated property was distributed by a corporation. Whether the recipient was a corporation or an individual, the fair market value of the property distributed was a dividend and subject to tax if there were sufficient earnings and profit in the distributing corporation (an issue not present herein). Internal Revenue Code of 1939, § 115(a), 53 Stat. 46.
Although the 1954 Code altered this situation, the legislative history of § 301(b)(1)(B) clearly demonstrates the intention of Congress not to exempt from taxation by the United States the appreciation in value of property distributed as a dividend but only to defer the tax on such appreciation.
The report of the House Ways & Means Committee which accompanied the bill clearly indicates what was intended by revision. H.R. Rep. No. 1337, 83d Cong., 2d Sess. 34 (1954). All Congress intended was the deferment of the tax until it was outside "the corporation solution". When the distributee corporation sold the property Congress intended that it be taxed on the gain just as the distributing corporation would have been taxed had it retained the property and ultimately the United States would collect a tax on the appreciation in value.
It is true, as stressed by the plaintiffs herein, that legislation was proposed in 1960 to amend § 301(b)(1) so as to deal explicitly with the situation here in question, together with the treatment of a distribution of property by a foreign corporation to a domestic corporation. H.R. 13106, 86th Cong., 2d Sess. (1960). The fact that the portion of the bill relating to a distribution by a foreign corporation was ultimately enacted in 1962 and is now § 301(b)(1)(C) is not as significant as plaintiffs would make it out to be. It can well be argued that enactment of that portion of the bill relating to a distribution by a foreign corporation shows Congressional recognition that § 301 dealt with situations where the distributee was subject to domestic taxation. It is of great significance, however, that in 1962 Congress reiterated its endorsement of tax deferral while profits are in the corporate solution, H.R. Rep. 1447, 87th Cong., 2d Sess. 26 (1962), an endorsement which is completely inconsistent with the notion that Congress at the same time silently acquiesced in an interpretation of § 301(b)(1)(B) which violates the corporate solution concept. Furthermore, since the instant case is concededly one of first impression, it hardly seems likely that the alleged tax avoidance loophole was considered a very significant one at that time.
Moreover, the legislative history of §§ 881 and 1442 clearly demonstrates that Congress intended to tax the gross amount of dividends paid to non-resident foreign corporations without regard to § 301(b)(1)(B).
In enacting the withholding provisions of the 1954 Code, Congress expressly stated that it intended to preserve the law as it existed under the 1939 Code without any substantive changes. S. Rep. No. 1622, 83rd Cong., 2nd Sess. 458 (1954). Accordingly, in interpreting the provisions of the 1954 Code, it is necessary to look to and be guided by the expressions of intention on the part of Congress which it made when the present system of taxing non-resident foreign corporations first came into being, namely, in the Revenue Act of 1936.
Prior to the Revenue Act of 1936, all foreign corporations (whether or not engaged in a trade or business in the United States) were subject to the same taxation as other domestic corporations. Fundamentally, taxes were levied on net taxable income as reflected in an annual return. In addition, there was a rudimentary system of withholding taxes on certain periodic payments made to corporations. However, this system proved inadequate where foreign corporations not engaged in a trade or business were involved, since so much of the provisions as required the filing of a return could not be enforced because the corporations involved were not within the jurisdiction of the United States.
Congress, accordingly, in 1936 eliminated the annual return concept for such corporations and substituted instead the system of taxing them at a flat rate on more kinds of periodic payments, which tax was to be withheld at the source.
The vehicle for such system was § 231(a) of the Revenue Act of 1936.
§ 231. Tax on foreign corporations.
(a) Nonresident Corporations. There shall be levied, collected, and paid for each taxable year, in lieu of the tax imposed by sections 13 and 14, upon the amount received by every foreign corporation not engaged in trade or business within the United States and not having an office or place of business therein, from sources within the United States as interest (except interest on deposits with persons carrying on the banking business), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income, a tax of 15 percentum of such amount, except that in the case of dividends the rate shall be 10 percentum, and except that in the case of corporations organized under the laws of a contiguous country such rate of 10 percentum with respect to dividends shall be reduced to such rate (not less than 5 percentum) as may be provided by treaty with such country.
The original bill passed in the House provided that non-resident aliens would be taxed on periodic payments received at a rate of 10 per cent (H.R. 12395, 74th Cong., 2d Sess. § 211(a)), whereas non-resident corporations were taxed at the rate of 15 per cent. (Id., § 231(b).)
The applicable sections of the Senate bill, which ultimately were incorporated in the Revenue Act of 1936, adopted the same general scheme of taxation of non-resident individuals and corporations, with the exception that dividends received by non-resident individuals were taxed at the same rate as those of foreign corporations not engaged in a trade or business here. As stated in the Senate Report:
" . . . Your committee concurs in the substance of these provisions [in the House bill] but recommends an amendment to section 231 of the House changing the rate of tax on such income, except for dividends, from 15 percent to 18 percent and in the case of dividends, fixing the rate at 5 percent in the case of corporations organized under the laws of a contiguous country and 10 percent in the case of other foreign corporations. For various reasons, it is believed the tax on dividends should be the same in the case of a corporate as in the case of an individual recipient. It should be noted that under the House bill corporate profits distributed to stockholders abroad may never have been taxed, while under the Finance Committee bill they would have been subject to at least the normal corporation tax." S. Rep. No. 2156, 74th Cong., 2d Sess. 23 (1936).
The significance of the last two sentences is clear. The Senate expressed two extremely important concepts in making the change, which concepts have been carried over to the Internal Revenue Code of 1954. The first was that the rate of tax on dividends received by a foreign corporation not engaged in a trade or business in the United States was to be the same as that imposed on a non-resident alien. An individual never could, and cannot now, treat as dividend income subject to tax anything less than the fair market value of the property distributed.
Secondly, the American corporation was required to have paid at least some tax on the profits which it was distributing to the non-resident foreign corporation or individual. Congress did not want the situation to arise where profits would be distributed to a non-resident foreign corporation, which profits had not been subjected already to the United States taxation while still in the hands of the American corporation, even though they would also be subjected to the withholding tax on dividends to foreign stockholders. This policy would be controverted if by invoking an unrelated section some of the profits would escape taxation in the United States.
At this point it becomes necessary to examine the relationship for tax purposes between a corporation and its stockholders. Under our system of taxation, when a corporation earns income it pays a tax on that income. When it distributes its profits after taxes to its stockholders as a dividend, the stockholders pay a tax on those dividends.
Where the corporation seeking to pay a dividend has acquired property which increased in value, it has two choices. It can sell the property for cash and distribute the cash as a dividend or it can simply distribute the property itself as a dividend. If the distributing corporation sells the property for cash, it would have to pay a tax on the profits before it makes a dividend payment to the stockholders.
On the other hand, unrealized profit from the increase in value of property has never been and is not now taxable. Thus, if the distributing corporation has acquired property which increases in value and distributes that property to its stockholders, the distributing corporation never has to pay a tax on the increase in value. The transaction is, however, a taxable event to the stockholders, who must pay a tax on the dividend measured by the fair market value of the property received, even though they have not sold the property. Thus, tax is collected on the profits, i.e., the increase in value of the property - at the time the dividend is paid - just as if the distributing corporation had sold the property for cash, paid tax on its profit, and then distributed the balance to its stockholders.
Where the stockholder is another "corporation", § 301(b)(1)(B) permits a deferral of tax on the profit, - i.e., the increase in value of the property - while it is in the corporate solution, that is, until such time as the stockholder corporation sells the property since it is a deferral, not a forgiveness of tax; the taxable incident to the stockholder is simply postponed. Under the system proposed by the plaintiffs, however, where a non-resident foreign corporation is the stockholder the tax on the profit would not be deferred, but rather it would be forever lost, since the non-resident distributee foreign corporation would not have to pay tax to the United States when it sells the property, nor would the domestic distributor corporation pay a tax at time of distribution.
Returning to the initial premise of Congress in passing the Revenue Act of 1936, namely, to eliminate a system whereby "corporate profits distributed to stockholders abroad may never have been taxed", but instead to insure that they will have been subjected to tax here, it seems clear that Congress never intended to permit any of the profits of a domestic corporation to escape taxation forever simply because they were unrealized when distributed to a foreign corporation as a dividend.
The intent of Congress concerning the withholding provisions as expressed in 1936 is applicable to the 1954 Code, and is completely consistent with the statutory history of § 301(b)(1)(B).
I conclude, therefore, that a foreign corporation not engaged in trade or business within the United States is not a corporate distributee entitled to the benefits of § 301(b)(1)(B) of the Internal Revenue Code of 1954.
Accordingly, plaintiffs' motion for summary judgment is denied and defendant's motion is granted.
Settle order on notice.
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Mendon, IL 62351
514 W Collins St Mendon, IL
101 N Warsaw St Ursa, IL
This is the place to go if you are just out looking for a small town down home family restaurant. Good food served with a smile. daily specials. and buffet with a variety of choice.. they also have Mic night and live bands5


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25 Magical Macro-Photos Of Mushrooms That You Will Like
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Ten Surefire Ways to Get Promoted
Do you feel like you've hit the proverbial glass ceiling, promotion-wise? The reality is that advancing in an organization involves far more than just being extremely competent at your job. Politics will play a role, of course, but you'll gain an even more advantageous position by finding ways to make yourself more well-rounded and valuable to your entire company—as opposed to just being the resident tech whiz. Creating this edge inevitably involves taking part in interdepartmental meetings and projects and attending industry events. It requires you to seek out internal influencers and make a valid case that you are capable of taking on other tasks and responsibilities. And it also may require you to ditch your jeans-and-sneakers wardrobe for clothing that's more appropriate for business. For the following tips, we turned to professional resources such as Quintcareers.com and Your-career-change.com
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text: Had dinner at Splashes with my husband and daughter. We had a window table with a beautiful view of the ocean. Everything we ordered was exquisite, the service was excellent, and the view was superb. One of our favorite restaurants in Orange County. This restaurant is fit for us foodies! We will be back.


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An Introduction to the Analysis of the Tourette's Syndrome
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Category: Healthcare and Medicine
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Have you ever heard or seen a person scream out or jerk at random These people could have a disorder called Tourettes Syndrome This disorder is named after Georges Gilles de la Tourette in 1857 Tourette was a neuropsychiatrist who was amazed by Sister Jeanne des Angess illness when she was thrashing out at her friends relatives and random people and screaming out of the ordinary Tourette and a colleague wrote an analysis about this certain disease and found no records of any type of illness He then named this illness after himself after deciding it was the first recorded case This disease doesnt necessarily physically or mentally impair the person who is diagnosed but it just may cause excess embarrassment or any accidents that were not wished for Tourettes syndrome is typically found in any person mostly under the age of 18 This illness targets 3 to 4 times the amount of men than it does to women It is caused by a nervous disorder that sends signals to the brain involuntarily Even though you may not want to do a certain thing sometimes it may happen Screaming out is the most common symtpon of Tourettes followed my involuntary movements All of these involuntary actions are known as TICS About 3 out of every 100000 children may be diagnosed Although the basic cause of Tourettes is unknown evidence from genetic studies suggests that most cases of it are inherited Research suggests that there is an abnormality in the genes affecting the brains metabolism of neurotransmitters called dopamine serotonin and nor epinephrine Neurotransmitters are chemicals in the brain that carry signals from one nerve cell to another A person with Tourettes has about a 5050 chance of passing on the genes to one of his or her offspring However that genetic pass-down may not necessarily result in full Tourettes Instead it may result in a mild disorder obsessive-compulsive behavior or attention deficit disorder with few
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text: Guidone - For Shake 1965 (Parlophone) • Blues , Love, Latino • Year : 0 • On demand! (album available 128-320kbs)* 0 Label Facebook Twitter Google+ Pinterest Hide/Show Album Info Label : ParlophoneValue :This Lp is entitled " Guidone For Shake" obviously inspired by Beatles "For Sale" and was recorder in Greece by the Italian singer in 1965 for Parlophone.Guidone is one of many other foreign artists who used to visit Greece , usually during the summer and make appearences in the local clubs.During those visit they managed to leave some fine recordings behind.Sush examples are Ricardo Credi & Toni Pinneli,whose finest tracks shall be incuded in future releases.The Lp includes mostly shaking rhythms,very popular at this period to the Greek and Italian youngsters,as well as an impressive remake of "The house of the rising Sun" in the Italian version " La Casa Del Sole" watch out for it in afuture release.And of course the undoubtable clue of the Lp is Guidone's photo with the Beatles, in the back cover.P.s Big thanx Bon-Boy.P.ss Rip from Cd with out the last track "Pepermint Twist"Taste :Guidone - Fuori dal Mondo (??? ??? Charms)Guidone - Sha... La La La LaDownload Cd-rBy Electric Looser #tags The album code is : ODI187870 You may also like ... Ricardo Credi - Une Larme / Petrouchka 1965 (Philips) Ricardo ... VA - Italo Disco Hits Vol.110 (2014) VA - Italo ... The Beatles - Live In Paris 1965 The Beatles ... Italian Graffiti-Vol 7- by www.olldmusic.net Italian ... Italian Graffiti 1964-1965 Italian ... [SM] The Beatles - The Beatles Stereo Box Set (2009) [SM] The


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Digital Project Manager
A+E NetworksNew York, NY
Full Time Job
Digital Project Manager (Project)
Part of the International Digital team, the Digital Project Manager is responsible for day to day management, documentation and planning of digital projects for A E's International division.
Specific projects will vary and may include consumer or B2B websites, microsites, apps, OTT platforms, as well as video content and management tools. The Digital Project Manager will need to manage across a wide array of project participants including internal stakeholder (IT, Programming, Marketing, Social Media, Creative, Ad Sales, etc), International stakeholder (local market teams) and external vendors. The role provides management, reporting and continuous improvement of the International Digital team's resources and products and ensures alignment with departmental long-term goals.
He/She is the day-to-day point of contact for technical issues and product support for A E Networks' International Sales and Channel Partners.
• Work with IT Project Managers and Business Analysts where appropriate to plan any deliverables
• Manage key internal stakeholders and partners' expectations throughout any project or daily channel initiative through regular communications.
• Work with IT Project Managers and Testing teams to plan and manage the testing and required quality assurance of change.
• Work with thePlatform technical team, US and International Digital to create workflows and efficiencies for delivering content to Channel Partners and Sales
• Responsible for ensuring all projects are delivered against agreed scope
• Identifying key customer experience and business benefits with any new concepts, clearly agreeing the goals, objectives, and scope of a project or initiative
• Defining anticipated time and scope working with IT, Digital and International Teams and third party business suppliers for inclusion in business case or rationale
• Analyzing trends to determine and define appropriate customer experience for each channel
• Keeping abreast of industry trends, to ensure the channel stays ahead of the competition
• Ensure that live projects or initiatives meet proposed benefits and objectives as outlined in the business case, owning projects through to benefits measurement and delivery.
• In conjunction with IT and the International Digital Team provide on-going support of B2B web sites
• Implement regular progress reporting and communications to all business areas and business stakeholders detailing project progress, advising of any scope change and celebrating project successes
• Ensure operational effectiveness of websites (B2B)
• Delivery of short-form and mid-form content via thePlatform to Channel Partners
• Maintain thePlatform accounts for the B2B sites, SVOD products, Channel Partners and any and all APIs leveraged
• Work with thePlatform technical team and US Digital to maintain the health and organization of content within ALL International thePlatform accounts – B2B, Channel Partners, SVOD, International
• Full understanding of programming licensing agreements and Channel Partner restrictions as it applies to the delivery of short and mid-form content.
• Domain securitization
• Support vendor management and alignment with terms of service level agreement
• Provide point of escalation within business for issues that have arisen and have to be managed internally or with third party non-IT suppliers
• Ensure business monitoring of Website and other projects' performance
Qualification Requirements
• Proven Project Management experience in a B2C and/or B2B environment essential
• An understanding of usability, accessibility and analytics
• Strong technical aptitude.
• A thorough understanding of Digital product development – front-end development, integration with back-end systems
• Strong understanding of and experience with Video Media Services – thePlatform, Brightcove, YouTube
• Create, maintain and update detailed project plans that will drive expert schedule, resource and client/vendor management
• Strong understanding of and experience with CDNs – Akamai, Limelight, etc.
• Excellent interpersonal skills, with the ability to communicate at all levels within internal departments and external agencies and with the ability to explain complex elements in a simple way
• Highly organized, focused and committed to achieving goals
• Ability to work within deadlines on several initiatives simultaneously
• Strong team player, with the ability to manage and prioritize own work and be autonomous.
• Strong analytical skills - able to draw conclusions from data, management information and trends
Educational Requirements A total of 4-6 years digital project management experience is required. Other Skills and Knowledge Knowledge of the Media & Entertainment industry desirable but not essential.
Please note project assignment associates are engaged to provide service to A E Networks on a temporary basis in connection with a specific project. Project assignment associates are hired and employed through a third party vendor with a duration/tenure of no longer than twelve (12) months. Company Overview:
A E Networks is proud to be an Affirmative Action/Equal Opportunity Employer/Disabled/Veterans
Additional Information
At A E Networks, we are passionate about programming that brings human stories to life, knowing that it is in life itself that those stories originate. We are committed to empowering our people, strengthening our partnerships and engaging audiences across the globe. We're a global entertainment media company with six original brands: A&E®, HISTORY®, Lifetime®, H2®, FYI™ and LMN®. We reach 330 million people worldwide, can be found in eight out of 10 American homes and have 500 million digital users. The best part? We did it our way.
Marketing Innovations is focused on elevating and monetizing the A E Networks brands, intellectual property and talent. The group is comprised of three primary departments: Brand Partnerships Innovations, Consumer Products and the Creative Media Group.
A E Networks, LLC. is a joint venture of Disney-ABC Television Group and Hearst Corporation.


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Mississippi Sin Dep
Sandra Allen
You can find this recipe on line but this one was such a hit when I served it I stuck with it.
Featured Pinch Tips Video
Be the First
10 Min
1 Hr
- 8 oz
- cream cheese, room temperature
- 1 1/2 oz
- sour cream
- 2 c
- shredded cheddar cheese (co jack is amazing, too).
- 1/3 c
- chopped ham or ham spread
- 4 oz
- green chilies undrained
- 2 Tbsp
- chopped pickled jalapenos. i didn't use these and no one complained.
- 2 dash(es)
- worcestershire sauce
- 1/2 c
- finely chopped green onion stems
Directions Step-By-Step
1Preheat oven to 350 degrees.
In a bowl, mix the sour cream and cream cheese. Add all the rest, keeping in mind that the ingredients are pretty stiff so a spud masher or plunger type mixer will work better than a mixer.
2Pour into a casserole dish and bake for about 1 hour. Don't be too concerned if the top gets a bit golden it just adds to the flavor. However, if you want you can cover it in foil or with a baking dish lid to keep it consistent.
3Options: you can add some well drained crab or shrimp and make this a seafood delight, or add some cooked sausage and bacon for a country fare!!
Serve warm with crackers, chips, bread or a really big spoon!!
About this Recipe
Course/Dish: Cheese Appetizers
Main Ingredient: Dairy
Regional Style: American
Other Tag: Quick & Easy
Hashtag: #Mississippi Sin


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Striking interior - all rectangles. Good food from small menu. Service was somewhat cold. Good value.
Excellent service, asked our preferred drinks by supervisor, Callum wearing the tartan trousers, and he made us our own original cocktails. Perfect way to end a date night! Thank you too all the staff working tonight, Kieran and jake🍾🍾 will definitely be back!! Xx
Friend and I took advantage of the email from The Bruach offering 20% off meals for week ending,if I remember correctly on Monday 14/11/16. I have always loved the food at The Bruach, the staff and the atmosphere. On Friday 11th a warm welcome as we were escorted upstairs to the dining area, menus and drinks delivered we chose starters...
Sunday lunch at Bruach - tasty burgers. Good service also. The atmosphere on a Sunday afternoon is nice and chilled, no loud music, and so easy to sit around and chat.
Best cocktails I've had in dundee. Food was top notch as well as the service. Will be coming back. Recommend to anyone looking for a big city bar in a small town.
Called in for a drink, very friendly staff, good ambience and decor. Will call in again St time in Broughty Ferry
There was seven in our party. We may have well been on two tables as it was impossible to have a conversation as the music on a Saturday night was too loud. It wasn't even as if we were late diners as our table was at 7pm.
I really don't understand why the dinner menu is smaller than the lunch...
Cold, fatty, inedible steaks. The cod was very small, cold and the accompanying sauce had dried and congealed to the plate. The waitress was unpleasant and rude. The whole experience was a joke! Do not go to this place.
The steaks ordered were fatty and cold. When we complained we were offered to have the extra £7.50 charge removed. We had to ask to have the removed from the bill completely as they were totally inedible. The cod loin was tiny - a starter really - and I had to order chips on the side - was advised to...
We went as a party of 6 adults on the recommendation of my son who lives near Dundee. On a Sunday evening it was pretty quiet but at least the menu is extended by about double on the main courses. There were plenty of clearly indicated Gluten free options for my Gluten intolerant daughter. Good choice of wines, beers and...
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Hello I am celiac and arrive Dundee thus eve about 9pm will you be open then please? A starving woman at Dublin airport. Thanks Janet
Where's Petwr Walsh?! My sister and me came back for cocktails he said he works every Saturday but he wasn't in and someone said he was fired. That is such a shame he was the best barman we've been served by he did my cousins cocktail class. Is he still a barman if so where does he work?
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Please feel free to contact a Connecticut Home Mortgage, Licensed Mortgage Banker for help or questions about our mortgage programs.
Above rates are based upon the following assumptions: 20% down payment, 30 days prepaid interest, $1187.95 in finance charges, $875.00 Attorney fee, 740 credit score and a 25 day rate lock. Rates will vary depending upon the actual down payment and resultant Loan to Value Ratio, and points and fees charged for each individual transaction. Conforming loans are based on a loan amount of $417,000.00, Agency Jumbo loans on a loan amount of $700,000.00** and Jumbo Loans on a loan amount of $1,000,000.00. Rates are subject to change without prior notice and may vary based upon the terms of each individual loan, actual loan amount, income verification results, receipt of an acceptable property appraisal, debt-to-income ratios, credit history and credit scores. The above rates may change or not be available at loan commitment or closing if the interest rate was not locked in or the interest rate lock expired.
** In Fairfield County; FNMA and FHLMC limits are based on county median housing prices. For other county limits please talk with a CTHM loan officer.


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STAMFORD - A Stamford man is facing charges for allegedly taking more than $90,000 from his elderly parents.
Matthew Diamond was arrested Tuesday.
Police say a family member called police to tell them that Diamond forced his parents to give him money and their credit cards.
The father is now deceased.


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Untold Stories of Video Game Remasters – the Good, Bad, and Ugly
In today's video, we discuss something subjective – are video game remasters good or bad? And...
Just as we speculated that Hideo Kojima's presence at this year's E3 was no coincidence, and Kojima revealed its upcoming game Death Standing at Sony's E3 press conference.
And now Hideo Kojima is drinking the Konami Tears in a new image shared by none other than Norman Reedus.
Shortly after the reveal of Kojima's Death Standing, Norman Reedus uploaded a Photoshop picture of Hideo Kojima drinking from a cup with Words "Konami Tears".
No doubt Norman Reedus did this in aftermath of what happened between Kojima and Konami and the cancellation of the Silent Hill game in which Norman Reedus was to play the protagonist.
I don't know why but every time I look at this image it makes me happy, and I feel that Konami definitely deserves it for cancelling the Silent Hill game and disrespecting Hideo Kojima.
Hideo kojima revealed its upcoming game Death Standing with a short trailer featuring none other than Norman Reedus. In the trailer you can see a naked Norman Reedus crying and clutching a baby that vanishes out of thin air, in the middle of a completely unsettling environment.
If you have seen the trailer than you know that it gives a feeling of sadness and sorrow, which seems to be the perfect response to the trailer.
You must be thinking that since Kojima revealed its game at Sony's E3 conference, then its bound to be a PlayStation 4 exclusive. However, Death Standing is not a PlayStation 4 exclusive but it is conformed that Death Standing will also be available for PC as well.
What do you think of the Hideo Kojima's image drinking Konami Tears? Let us know in the comments.


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new procedure to treat scoliosis
Until now, treating scoliosis involved inserting screws and a metal rod along a patients spine. The procedure can be painful, recovery can take up to nine months and patients often lose mobility.
Dr. Firoz Miyanji is the first doctor in Canada to introduce an alternative treatment known as vertebral body tethering. Instead of using a metal rod, doctors insert a rope that allows some flexibility of the spine.
If you look over time, 18 months later you can see that the spine is straightened without actually fusing that area of the spine, Miyanji said.
Last October, 12-year-old Misiak qualified for the surgery at BC Childrens Hospital.
Over nine hours, a specialized team of doctors and nurses deflated her lung and inserted the tether.
Within two days, Misiak was walking. Within a month she could swim and play music again.
I felt 10 times taller, and I felt my posture was very good, she said.
I thought I was going to have to look after her lying on her bed, mother Stacey Misiak said. We literally had to hold her back from activities. She was ready to go.
Misiak is one of 30 patients at BC Childrens Hospital who have had their spines tethered.
Since the procedure, Misiaks curve is almost gone and shes grown more than two inches.
Shes even planning a trip to play music in New York.
It changed my life so much, she said. Now I feel like a whole new person.


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Office 365 - Technical Overview for the IT Professional
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text: Natural Numbers - Natural Numbers In Dub (2014) • World Music International • Year : • On demand! (album available 128-320kbs)* 0 Label Facebook Twitter Google+ Pinterest Hide/Show Album Info Artist: Natural NumbersTitle Of Album: Natural Numbers In DubYear Of Release: 2014Label: Stones Throw RecordsGenre: Reggae, DubQuality: 320 KbpsTotal Time: 38:12 minTotal Size: 101 MBTracklist:1. Theme for King Richard2. Unconditional Dub3. Dubble Trouble4. Nairobi Dub5. Dub and Blind6. Ride the High Dub7. Pressurizer8. Dub in the City9. One Duppy, Two Duppy, Three Duppy10. Salida DubNatural Numbers is the new dub project from producer Tom Chasteen, co-founder of Los Angeles' Dub Club, who has released several records under the Dub Club name. This new musical creation draws inspiration from African, Middle Eastern and Country sounds as well as Reggae. Natural Numbers in Dub is dub music in the classic Jamaican sense: original recordings of an all-star band, deconstructed and pieced back together with echo and reverb in real time on the mixing board. Buy Premium From My Links To Get Resumable Support,Max Speed & Support MeDownload ( Uploadable )http://www.uploadable.ch/file/9H3CqQGbmyRH/tzf57.Natural.Numbers..Natural.Numbers.In.Dub.2014.rarDownload ( Uploaded )http://uploaded.net/file/mk9gahk7/tzf57.Natural.Numbers..Natural.Numbers.In.Dub.2014.rarDownload ( Rapidgator )http://rapidgator.net/file/44be6f0bbb572902dd713ae12ee737b5/tzf57.Natural.Numbers..Natural.Numbers.In.Dub.2014.rar.htmlDownload ( Oboom )https://www.oboom.com/6SCRK8PC/tzf57.Natural.Numbers..Natural.Numbers.In.Dub.2014.rar #tags The album code is : ODI4380917 You may also like ... Energun - The Theory Of Small Numbers (2014) Energun - ... Numbers - Three (2014) Numbers - ... Magic Numbers,The - Those the Brokes (ff) Magic ... Magic Numbers,The - Magic Numbers (ff) Magic ... F.R._David-Numbers-2009-BFHMP3 F.R._David-N ... Maral Salmassi - Natural Fun Maral


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A reasonable person who accepts the historical fact that Abraham Lincoln is nothing more than a figment of historical imagination. There is not a SHRED of his actual existence.
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In best seller Elin Hilderbrand's first Christmas novel, a family gathers on Nantucket for a holiday filled with surprises.
As Christmas approaches, Kelley is looking forward to getting the family together for some quality time at the inn. But when he walks in on Mitzi kissing Santa Claus (or the guy who's playing Santa at the inn's annual party), utter chaos descends. With the three older children each reeling in their own dramas and Bart unreachable in Afghanistan, it might be up to Kelley's ex-wife, nightly news anchor Margaret Quinn, to save Christmas at the Winter Street Inn.
Before the mulled cider is gone, the delightfully dysfunctional Quinn family will survive a love triangle, an unplanned pregnancy, a federal crime, a small house fire, many shots of whiskey, and endless rounds of Christmas caroling, in this heart-warming novel about coming home for the holidays.
©2014 Elin Hilderbrand (P)2014 Hachette Audio
"Another great read by Ms. Hilderbrand!"
loved it! Well read, reader put me in the scene and helped me feel the personality of each character.
Love listening to audiobooks. I have been with audible since 2008, either here or with another account! I love audible!
"Loved it"
Great book, loved the characters and story. Loved the Christmas time of year in the book.
Reader, Reviewer, and BOOKIN' WITH BINGO BLOG OWNER
"Hilderbrand Gives Fans a Holiday Treat!"
Best selling author Elin Hilderbrand's WINTER STREET is a delightful holiday novel that is just the gift readers should give themselves, and each other. WINTER STREET is Hilderbrand's first Christmas novel and takes place in Nantucket, a favorite setting of hers. It is there that readers meet the Quinn family and are quickly caught up in the lives of this loving, compassionate, but also wacky family that just might resemble people readers really know. Each character is fully realized thanks to Hilderbrand's expertise, thus drawing readers quickly in to all of their lives. I thought I really knew these people, and that kept me listening. I hated for the story to end.
WINTER STREET is the name of a charming inn that the Quinn family has run for years. With father Kelley and stepmother Mitzi currently in charge, we are drawn in as Christmas approaches to see if all the children will come home for the annual festivities. Hilderbrand writes about each integral protagonist with great detail so we quickly begin to understand what makes them tick and what part they play in the Quinn family.
Learning about what Kelley is like and how he and Mitzi got together calls for his first wife, and the "children's" mother, to also be introduced. Margaret Quinn is a celebrity as she deals with her job as news anchor for CBS. Her career is very important to her, keeping her busy with travel and it is the reason her relationship with Kelley ended. She does, however, love her children very much and we see how each of these now grown children feels about her. Because of her schedule, it was mutually decided that Kelley would have custody of Patrick, Kevin, and Ava. While Margaret doesn't remarry, Kelley does and so Mitzi enters the picture and we find out just why she is often known to be rather ditzy. She and Kelley have a son together, Bart, who just isn't much of an academic but rather a party boy. Bart winds up enlisting in the Marines after high school, and is deployed to Afghanistan.
Patrick is the eldest of the Quinn offspring and is married with three boys. He is the golden child and someone it is hard to live up to if you are a younger siblings. However, Patrick shows he also isn't perfect and arrives for Christmas minus his family thanks to the trouble he finds himself in. Siblings Kevin and Ava both still live at the inn but have their jobs and own lives. Once divorced, Kevin swears off women but finds new love that he falls hard for and is trying to keep this secret from the rest of the family. As the youngest, Ava seems to be the most balanced and is a schoolteacher who is trying to keep her own relationship of two years alive.
As Christmas nears, the annual Christmas Eve party at the Inn is almost here and the whole island looks forward to it. Everyone who is supposed to help with this yearly event, however, seems to be coming apart at the wrong time! Just as quickly as a wobbly Christmas tree can fall over and ruin a holiday, so does the Quinn family start to fall apart. Each one of them plays off the other and as one problem seems solved, another one arises. This is where the family really must pull together or each of their lives will never be the same.
I have to say that I loved all the characters including the ones I disliked, if you know what I mean. If Erin Hilderbrand could grant me a holiday wish, it would be to make the Quinn family return each Christmas so we can have their delightful story continue. A fast read because I personally didn't want to stop listening and hope those of you lucky enough to get your hands on a copy will enjoy this holiday treat as much as I did.
"Not her best....."
I normally love Elin's books and was anxious to listen to this one. I almost bought the series, but am glad I didn't as the storyline is weak and unbelievable.
"Not a happy holiday book"
Do NOT read this if you're looking for a happy holiday read! Geez, now I'm totally depressed. I would've loved it if we could've had an actual closed-loop ending. Instead I feel like we are left hanging. BOO.
"Interesting family drowns in drinking"
Elin Hilderbrand chose Christmas to tell the story of one family and almost managed to include most of society's current issues: infidelity, illegal immigrant pregnant out of wedlock, insider trading, lying, cheating, greed, same sex partners, AIDS, Afghanistan war, drugs, infidelity again. ALL family members and friends turn to good ole' alcohol to drown their sorrows, lift their spirits, share their joy- anything calls for drinking until most pass out in a stupor. But they pray. It is as hypocritical as a story can be, trash and maybe they can all go to AA together in the next book. Do people live this way? Really.
"Brings me to Nantucket"
Loved this! I want to stay there! Elin always makes me feel as though she's right there with me.
"Too predictable"
Rich people, weak characters. Sad my book club chose this. Wasted time. Guess if you want poorly voiced, mindless books, you're in luck here.
"Why the need to bash Lindsay Lohan??"
It's pretty humdrum, really. But I was cooking, cleaning, and getting gifts together, so did not require big drama. I wouldn't go out of my way to recommend it, no.
First one
Hard to say; there are more unlikable characters than need be. Margaret is too perfect. Kelly is sort of a dope, and a 'guy.' No one could really love Mitzi, as portrayed by the author. Ava is maddening for most of the story. Everyone else, including 'Golden Boy' Patrick (who can ever like a GB?), is more or less background.
It passed the time, and was not UNpleasant
I really do take exception to Ms Hilderbrand's unnecessary attach on the beleaguered Lindsay Lohan. This, as her couple of Kings of Leon mentions, seem like a desperate attempt to be current. Backfired in the case of KoL, as they seem to have fizzled out already. This is always a risk for an author trying to appeal to a young, hip audience. Ugh.
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Best route map between Exton, PA and Harrisburg, PA. This route take about 77 Miles.
The distance and estimated time is placed on the right depending on the status of the road.
, 05:01
You view route of Exton, PA and Harrisburg, PA, this
is a short route and it takes
about 77 or 124. May
be you want to know how
long does it take? Average, It takes about 1 hour 20 mins.
Now, if need to talk about details of Exton, PA and Harrisburg, PA;
Firstly about Exton, PA, Coordinate is 40.0325893, -75.6274595, weather is and (). Population about 4609 and
about 2123. May be you need
this information, Area code of Exton, PA is 610.
Secondly about Harrisburg, PA, Coordinate is 40.2731989, -76.8866745, weather is and (). Population
about 49081 and households
about 20346. May be you need
this information, Area code of Harrisburg, PA is 717.
* Weather information on route, provide by Open Weather Map.
* The total population living within the city limits, using the latest US census 2014 population estimates. The
total number of households within the city limits using the latest 5 year estimates from the American Community
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