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"To People Who Want To Stop Suffering
From Pain And Other Debilitating
Conditions, But Don't Know How
To Get Started..."
If you're searching for the best acupuncture NYC, I'd like to welcome you to my website.
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De'Qi Health
Lida Ahmady is a New York State Licensed Acupuncturist & Board Certified Chinese Herbalist. She's the founder of De'Qi Health in NYC.
As an osteopathic physician— and resident in Obstetrics I have a grasp of healing on different levels. It is refreshing to have whole body practitioners who really look at every aspect of your life in order to make it better... I cannot say enough about the care and support I have gotten from Lida and Daniel over the years.
— K Provost
A Message From the Founder
Click the play button for a message from De'Qi Health
founder Lida Ahmady.
De'Qi Health in Manhattan
We're located on Broadway, between Houston and Prince in the heart of SoHo.
Licensed & Board Certified Acupuncturists.
Nutritional therapy and Chinese herbal medicine.
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The Staff at De'Qi Health
Lida Ahmady, L.Ac.
Lida Ahmady is a Licensed Acupuncturist and Board Certified Chinese Herbalist... Read more
Daniel Camburn, L.Ac.
Daniel Camburn is a Licensed and Board Certified Acupuncturist... Read more
Monique Rivera, L.Ac.
Daniel Camburn is a Licensed and Board Certified Acupuncturist... Read more
Click the image below to get The Free Report today.
Inside this Free Report, you'll find methods and concepts we've been recommending for years to people we treat, helping them to correct imbalances and health issues, and to even avoid them before they appear. We want to share a few things you can do on your own that will help you stay healthy and pain free. To get your copy of The Free Report, click here to download it now.


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Free personalized radio that
plays the music you love
Le Louvre
Features of This Tracktrance roots
four-on-the-floor beats
electronica influences
disco influences
unsyncopated ensemble rhythms
straight drum beats
a laid back male vocal
a male vocal
the use of chordal patterning
melodic part writing
a tight kick sound
a slow moving bass line
ambient synth textures
synth swoops
effected synths
a highly synthetic sonority
prevalent use of groove
and many other similarities identified in the Music Genome Project
These are just a few of the hundreds of attributes cataloged for this track by the Music Genome Project.show more
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It has something to do with The Louvre, the famous French museum. There are references to it, as well as the Mona Lisa.
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August – skipped writing
September – skipped writing
October – skipped writing
skipped writing: a note to myself, to stay connected.
I've been giving here this writing a wide berth – wye draaie geloop. I write the words skipped writing as a reminder – a note to myself, to stay connected, and to keep the relationship. A superficial part of the self condemns the blank dates, hisses failure, and splatters shame. The note to myself is a conscious call from deep – calling me to awareness (i have not written anything in 3 months) and calling me to action (i'm writing now). And how wonderworking the life that arises from this deep otherness being – it is as if I've not missed a moment of writing.
Always we begin again: it must be true.


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Scotts Valley, CA Scotts Valley Feed
YP - The Real Yellow PagesSM - helps you find the right local businesses to meet your specific needs. Search results are sorted by a combination of factors to give you a set of choices in response to your search criteria. These factors are similar to those you might use to determine which business to select from a local Yellow Pages directory, including proximity to where you are searching, expertise in the specific services or products you need, and comprehensive business information to help evaluate a business's suitability for you. "Preferred" listings, or those with featured website buttons, indicate YP advertisers who directly provide information about their businesses to help consumers make more informed buying decisions. YP advertisers receive higher placement in the default ordering of search results and may appear in sponsored listings on the top, side, or bottom of the search results page.
1. Scotts Valley Feed
5470 Scotts Valley DrScotts Valley, CA 95066
2. Corralitos Feed And Pet Supplies Inc
1486 Freedom BlvdWatsonville, CA 95076
3. Mary's Tack & Feed
Mary's Tack and Feed is a great place to go for equestrian needs. Mary's has been in business for decades -- providing excellent and reliable produc…
4. Westside Farm and Feed
817 Swift StSanta Cruz, CA 95060
From Business: test 1
5. Aptos Feed & Pet Supply
7765 Soquel DrAptos, CA 95003
6. Ramaekers Nutrition
3055 Stanley AveSanta Cruz, CA 95065
From Business: Ramaekers Nutrition develops patented natural veterinary products that provide immune system enhancement and support to help animals thrive. Founded by renowned a…
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576 Warnerville RdOakdale, CA 95361
From Business: For over 27 years we have offered our customers quality products & exceptional customer service. Conlin Supply, the ranch & home supply store, carries everything …
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1000 Cox RdAptos, CA 95003
10. Royal Oaks Feed & Tack
Royal Oaks Feed is great. They thrive on customer service. The staff is very friendly, knowledgeable and helpful. They carry a wide variety of fe…
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225 Salinas Rd Ste 4cRoyal Oaks, CA 95076
12. Aromas Feed & Ranch Supplies
320 Carpenteria RdAromas, CA 95004
From Business: Your local feed store that will meet your needs in: Pet feed, supplies & toys Hay, Alfalfa, Grass Hay, straw Livestock feeds, hardware & tack Fencing, livestock h…
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4410 Highway 101Aromas, CA 95004
From Business: 101 Livestock Supply Co. offers Livestock, powder, commercial, industrial, design, marketing, sales
14. J D Hay Sales
Serving the Scotts Valley Area.
15. Black Rails Equestrian Center - CLOSED
The best care and very clean.Arenas have the best footing and we enjoyed the facilities.Moved out of the area, or would have kept our 2 horses there…
16. Mountain Feed & Farm Supply
9550 Highway 9Ben Lomond, CA 95005
17. Corralitos Feed and Pet Supplies Inc
2895 Freedom BlvdWatsonville, CA 95076
18. General Feed & Seed Co.
1900 Commercial Way Ste BSanta Cruz, CA 95065
From Business: *Open 7 Days *Area's Largest Tack Shop * Please Visit Our Website For More Information * VISA, MASTERCARD, DISCOVER, & AMERICAN EXPRESS ACCEPTED
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From Business: Visit Hansen's Feed and Pet Supply in beautiful Corralitos California, (just a few blocks from the famous Corralitos Sausage Company!) 3200 sq. feet of quality pr…
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The owners Valerie and John are wonderful, very helpful! Support local Felton Businesses! Service is great! They are animal lovers and are especi…
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From Business: Quality Service - Competitive Prices - Premium Dog and Cat Food. Open Mon-Sat 9am-6:30; Sun 10am-5pm
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From Business: Roberts Market meshes our old world quality and charm with your modern lifestyle. Find deals on our fine meats, delicious deli products, fresh produce and/or exte…
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1841 Pruneridge AveSanta Clara, CA 95050
27. Feather Haven Mill
105 Leavesley Rd Bldg 2Gilroy, CA 95020
28. AlfaGrow
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29. L.A. Hearne Company
8525 Prunedale North RdPrunedale, CA 93907
From Business:
30. An-Jan Feed & Pet Supply
433 Vineyard Town CtrMorgan Hill, CA 95037


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Advanced Search
Here you'll find articles covering 1-to-1 computing, BYOD, augmented and virtual reality and all things mobile! Topics range from strategies for managing devices to news and reviews about new hardware and software.
Laws in more than 20 states restrict or prohibit local governments from building their own broadband networks, according to a report released today by the Education Commission of the States.
While more than half of K–12 teachers say they use education technology in the classroom on a daily basis, with nine in 10 saying they do so at least weekly, only 15 percent of those teachers would give themselves an "A" in education technology skills, according to a recent University of Phoenix College of Education survey.
A security technology company has just updated its flagship product for schools. Sergeant Laboratories announced a new release of AristotleInsight::K12, which provides technology for managing students as they work on their computing devices.
Today, the State Educational Technology Directors Association released a report featuring new goals for internet and wide area network services.
Virtual reality (VR) is on the rise. Less than a quarter of educators (23 percent) have tried out VR in their schools so far, and most of that effort has been in science (52 percent) vs. history (29 percent), engineering (20 percent) or any other subject.
Apple unveiled the iPhone 7, 7 Plus and Apple Watch Series 2 on Wednesday. The products should be available starting Sept. 16.
Special education educators now have access to a math-learning app, as part of an online catalog of apps for students in special education.
Educational technologists: listen to the teachers; they are asking you to help them to be more effective in creating and using digital curricula. In this blog post, then, we define the five functions that a blended learning platform must support — and challenge the ed tech community to build such a platform!
With Generation Beyond's Mars Bus, students can take a virtual reality tour of Mars.
Shipments of wearable devices reached 22.5 million in the second quarter of 2016, according to the International Data Corporation's recent Worldwide Quarterly Wearable Device Tracker report.
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With the costs associated with a cyber attack rising and the vast number of children victimized by identity theft each year, it's imperative to develop a cybersecurity strategy for your school or district. See why cybersecurity is a growing issue amongst education leaders and how Cisco can help protect your school before, during and after a security breach.
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11 Goddard
Irvine CA 92618
Class cancel on Memorial Day
Orange County Hypnosis Center presents:
Quantum Meditation & Transformation
with Choury DeVelle
Every Monday from 7-8 p.m.
$10 for Non-members (Pay at the door)
Quantum Meditation is a guided meditation using the perfect combination of light hypnosis and meditation. Because many people yearn for the benefits of meditation but lack the discipline of being able to sit still for hours and hours. With light hypnosis you're able to reach a perfect state of relaxation much sooner and are therefore able to experience the amazing effects of meditation within minutes instead of hours. Meditation creates an environment in the physical body which actually facilitates harmony and improves every area of your life, for instance:
Mental Clarity: Meditation results in better memory and enhances your ability to focus and concentrate. This is crucial to better performance at work and/or in any sports or athletics in which you may be participating.
Positive Attitude: Confidence, calmness, and a true sense of well-being.
Maintaining Good Health: Other than physical exercise, meditation is one of the most powerful stress relievers and contributors to staying younger, healthier, stronger and more in control of your life.
About Choury
I learned 'the hard way' resentment is the tie which binds the victims to the victimizer after growing up in an abusive home. Almost everyone I know has something which holds them back from realizing their true potential. Old fears can manifest in sickness, self-sabotage, and even violence if a person truly feels threatened. What most people don't understand is roadblocks to success are old beliefs based on lack and limitation buried deep within the subconscious. Many times the victim does not even know how or why the beliefs got started. Standard psycho-therapy is one way to uncover and release old beliefs and fears. However, I believe the quickest, most effective way to let go of past resentments is through hypnosis during which I can directly and quickly access the subconscious mind and change the programming from fear, sickness, lack and limitation to courage, health, abundance and wealth compared to standard psycho-therapy. Once old beliefs are released, you will be free to live the life of your dreams.


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Breaking – Man Dies in Over Night Car Crash
A man has been killed in a road crash in north county Dublin overnight.
Three others were also injured during the incident, according to reports.
The crash happened on the Palmer Road in Rush at 11.45pm.
The Skerries road is currently closed between Palmer Road and the St Catherine's estate pending a technical examination of the scene by garda crash investigators.
DUBLIN: Skerries/Rush Rd (R128) closed btwn St. Catherine's Est & Palmer Rd following serious collision. Local diversions in place. theAA.ie
— AA Roadwatch (@aaroadwatch) February 2, 2017
Dublin Fire Brigade units from Swords, Skerries and Finglas attended the scene, according to Independent.ie.
Four ambulances were also reportedly at the scene.
The road will remain closed to traffic until further notice and diversions are in place.
More to follow…..


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e-Course + Mentoring Gift Certificate
e-Course + Mentoring Gift Certificate
This gift certificate entitles the recipient to one online photography course + mentoring with Laura Valenti (worth $350). The recipient can register for the e-course + mentoring option of their choice with their gift certificate code. The certificate does not expire.
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|Society & Culture
The latest news from the team behind BBC History Magazine - a popular History magazine. To find out more, visit www.historyextra.com
September 14th, 2012
Episode 72 of 325 episodes
Simon Jarrett discusses disability through history, while David Priestland talks about how occupational groups have fought for power over the centuries.
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In a time where we're all threatened by a rhetoric of hate from the people in power; A Gay And A NonGay challenges many of our differences head on and promises that no matter who you are, or what you're into (Bruce Springsteen or Britney), love is love and gay and nongays can be friends.

An independent podcast from James Barr (@imjamesbarr) and Dan Hudson (@DanHudson). Contact us on Twitter, IG or Facebook @gaynongay


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Welcome to my home page!
Jacqueline is a current Florida State Department of Education certified teacher with an ESOL (Teaching English to Speakers of Other Languages) endorsement. She also holds a permanent New York State Teacher's Certification. Having earned both her Bachelor of Arts Degree in Early Childhood Education and A Master of Science Degree in Children Early Childhood) born with Retarded Mental and Developmental Challenges she remains an active alumni of Brooklyn College, City University of New York.
In order to assist the community in New York City where she resided, she owned and managed JALM Pre-School Services until her relocation to Florida Education. She has consulted with several Early Childhood Education agencies.
Ms. Williams, as she prefers to be called, is a member of several professional organizations including the National Association For The Education of Young Children and she continues to advocate strongly for young children.
Spring Courses:
EDF 2005: Introduction to Education
EDF 2085: Diversity in Education
EEC 1000: Early Childhood Education
EEC 1001: Introduction to Early Childhood Education
EEX 2085: Families, Professionals and, Exceptionality
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Email: email@example.com


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The media is always fretting that ginning up "white rage" will produce "backlash" — violence — against minority communities.
Okay, let's say I accept that's a possibility.
Is it not also a possibility that ginning up minority rage over agrievements, both those that can be characterized as possibly real as well of those of the #FakeNews contrived paranoia variety, can spur non-whites into their own "backlash" mode?
If not, why not? Are whites singularly evil in this world? Are they alone the only race capable of being whipped up into a hateful, violent lather by racial paranoia and racial grievances?
If it's dangerous for a strain of white identity politics to nurture a fear and hatred of "The Other" — different races — and that such a strain of grievance-mongering and paranoia may result in the murders or assaults of minorities, why is it (as the media and mediating institutions seem to believe) not dangerous at all for minority ethnic groups to gin up their own fear, paranoia, and hatred against whites or society in general?
Will the media or any government official ever address this, given the weekly assassinations of police, and the newest barbarism committed against OSU students due to one lunatic steeping in the hatreds of identity politics?
Ace, "Jim Geraghty: OSU Jihadi Proves That the Progressives' Victim Mentality Kills", Ace of Spades H.Q., 2016-11-30.
December 1, 2016
QotD: Victim mentality and "white rage"
November 18, 2016
Scott Alexander – "You are still crying wolf"
Donald Trump is President-elect, but he didn't get there by pandering to white supremacist and racist voters, but you'd never know that by how his campaign was reported in the media. Scott Alexander says that the media still hasn't learned its lesson and is still crying wolf:
Back in October 2015, I wrote that the media narrative of Trump as "the white power candidate" and "the first openly white supremacist candidate to have a shot at the Presidency in the modern era" were being fabricated out of thin air. I said that "the media narrative that Trump is doing some kind of special appeal-to-white-voters voodoo is unsupported by any polling data", and predicted that:
If Trump were the Republican nominee, he could probably count on equal or greater support from minorities as Romney or McCain before him.
Well, guess what? The votes are in, and Trump got greater support from minorities than Romney or McCain before him. You can read the Washington Post article, Trump Got More Votes From People Of Color Than Romney Did, or look at the raw data (source)
We see that of every racial group, the one where Trump made the smallest gains over Romney was white people. I want to repeat that: the group where Trump's message resonated least over what we would predict from a generic Republican was the white population.
Nor was there some surge in white turnout. I don't see official numbers yet, but by eyeballing what data we have it looks very much like whites turned out in lower numbers to vote in 2016 than they did in 2012, 2010, and so on.
Of course, the media quickly responded to all of this undeniable and freely available data with articles like White Flight From Reality: Inside The Racist Panic That Fueled Donald Trump's Victory and Make No Mistake: Donald Trump's Win Represents A Racist "Whitelash".
I stick to my thesis from October 2015. There is no evidence that Donald Trump is more racist than any past Republican candidate (or any other 70 year old white guy, for that matter). All this stuff about how he's "the candidate of the KKK" and "the vanguard of a new white supremacist movement" is made up. It's a catastrophic distraction from the dozens of other undeniable problems with Trump that could have convinced voters to abandon him. That it came to dominate the election cycle should be considered a horrifying indictment of our political discourse, in the same way that it would be a horrifying indictment of our political discourse if the entire Republican campaign had been based around the theory that Hillary Clinton was a secret Satanist. Yes, calling Romney a racist was crying wolf. But you are still crying wolf.
I avoided pushing this point any more since last October because I didn't want to look like I was supporting Trump, or accidentally convince anyone else to support Trump. But since we're past the point where that matters anymore, I want to present exactly why I think this is true.
I realize that all of this is going to make me sound like a crazy person and put me completely at odds with every respectable thinker in the media, but luckily, being a crazy person at odds with every respectable thinker in the media has been a pretty good ticket to predictive accuracy lately, so whatever.
October 24, 2016
The "logic" of hate crime legislation
Julie Burchill wonders why we enshrine in law the repulsive notion that some lives are more important than others:
I've always been somewhat bemused by the concept of 'hate crime' – a phrase which first came into use in the US in the 1980s and into practice in the UK in 1998. I must say that the idea that it is somehow worse to beat up or kill someone because you object to their race or religion, than because you're a nasty piece of work who felt like beating up or killing someone, strikes me as quite extraordinary – hateful, even, implying that some lives are worth more than others. Are we not all human, do we not all bleed? If we're murdered, do not those who love us grieve for us equally? Why, then, are attacks on some thought to be worse than attacks on others? Indeed, the book Hate Crimes: Criminal Law and Identity Politics claims that hate crime legislation may exacerbate conflict, upholding the idea that crimes are committed by members of groups rather than by individuals, thereby inflaming intolerance between different ethnic communities.
Nevertheless, in a dark twist on Alice In Wonderland's all-must-have-prizes shtick, gay people were added soon afterwards. Then, obviously realising that it was somewhat stupid to deem an attack on a big strapping man who was more than capable of standing up for himself worse than an attack on a frail, heterosexual OAP, the elderly were added in 2007 to the list of people who it's especially bad to attack or kill. This being the case, quite understandably the disabled were soon eligible to be victims of hate crime, too.
It's very easy for me to be offensive about anything, so I'll tread very carefully here. I do think that there is something particularly vile about picking on those with far less chance of fighting back and that those who do it should be dealt with particularly harshly. On the other hand, I don't think that 'hate' usually comes into attacks on the elderly and the disabled, or on children – simply the very unpleasant fact that sadists, cowards and bullies know they are easy targets. In fact, they probably like this about them.
It's also quite hard for me to understand how those who claim, and have their champions claim, to be the most chronic and vulnerable victims of hate crimes are Muslims. If you visited this country from another planet, all the ceaseless clatter about hate crimes of the Islamophobic kind might have you believing that a brace of Muslims a week were being butchered in the street due to the sheer molten hatred of the blood-thirsty Christian community. Whereas, in fact, Islamist terrorism kills eight times more Muslims than non-Muslims. In this country, three Muslims have been killed for being Muslims over the past three years – all by other Muslims.
October 21, 2016
October 4, 2016
September 14, 2016
"BLM seems to be stuck in a pointless do-loop of disruption and virtue-signalling"
Warren Meyer on the attention that the Black Lives Matter movement has drawn, and their apparent problem with deciding on or implementing the next steps:
Well, it appears that Black Lives Matter has moved on to climate activism, or whatever, but has mostly fallen off message on police accountability. Protests in the vague hope of ending racism by closing busy highways and airports and kneeling during the National Anthem are going to get nothing done — the solution to the problems that sparked the BLM movement are to be found in legislative efforts to create better police accountability measures and to roll back a number of egregious protections from accountability that exist in many union contracts. The solution is not to throw blanket hate on police officers, many or most of whom are doing a good job, but to recognize that when we give officers unique powers to use force, they need extra accountability to go with those powers. Today, most police have less accountability for their use of force than you and I do.
Unfortunately, doing that is hard. It is a tough legislative slog that has to go local city by local city, with few national-level shortcuts available. It faces opposition from Conservatives who tend to fetishize police, and from Liberals who are reluctant to challenge a public employees union. And it requires that BLM translate their energy from disruption and attention-grabbing (which they are very good at) to policy and legislation, which they have shown no facility for. They need to be working on model legislation and pushing that down to the local level. This original plan actually looked pretty good, but apparently it has been rejected and gets little or no attention.
As a result, BLM seems to be stuck in a pointless do-loop of disruption and virtue-signalling. I just want to scream at them, "OK, you have our attention — and many of us are sympathetic — what in the hell do you want done?" Unfortunately, their current lists of goals have almost nothing to do with police accountability and appear to be a laundry list of progressive talking points. It appears to be another radical organization that has been jacked by the Democratic establishment to push mainstream Democratic talking points.
Here is a good example, for a number of reasons. In the past, the officer likely would have been believed and the woman might have been convicted of something. I think this happens to people across the racial spectrum, but African-Americans have had a particularly hard time — given both racist perceptions and lack of good counsel — in these he-said-she-said cases with police. Not to mention that African-Americans — for a variety of reasons including racial profiling in things like New York's stop and frisk program to the tendency of poor black municipalities to fine the crap out of their citizens to generate revenue — come in contact with police disproportionately more often.
September 6, 2016
Could this be a winning strategy for Il Donalduce?
Jay Currie suggests a three-part plan that might bring about a Trump victory in November:
First, announce that a Trump administration will decriminalize marijuana.
Second, announce that every single person serving time for marijuana related offences is going to be pardoned on condition that they spend a three month intensive period in a pre-employment boot camp. And announce that, from the day Trump takes office, any criminal record for marijuana offences will be expunged as of right and right now.
Third, commit serious federal resources to creating paths to employment for the people who have either been in jail or who have had criminal records as a result of pot convictions.
You can picture Trump saying, "Let's bring our kids, and their fathers, home."
The last twenty years have been about incarcerating black people and Latinos for all sorts of crimes. Some of that is justified, but a lot of it has been felony marijuana arrests which should have been traffic tickets but got bumped because of priors, plea bargains and three strikes laws. It's time for that to stop.
People's children, husbands and wives have been sent to prison for a reason that an increasing number of states think is wrong. Washington, Colorado, Oregon and Alaska have legalized recreational pot and the federal government has gone along. Medical marijuana is legal in many other states. More states have either medical marijuana or recreational marijuana on the ballot in November.
The Donald does not have to say pot is a good thing. In fact, if he is smart he will say it is a bad thing and that he does not want any sensible American to use it; but it should not be a criminal thing because, if it is, there will be a disproportionate impact on black, Latino and poor white communities. That is just a fact.
August 20, 2016
"[S]tudio executives from the wage-gap capital of the world mansplain feminism"
Bre Payton wants Hollywood to start treating women as people:
Here's how I imagine the pitch meeting for Ocean's 8 went down in a smoky executive boardroom somewhere in Warner Bros.' studio office.
Balding Male Executive #1: Gee, Colombia Pictures got loudly applauded for that lousy 'Ghostbusters' reboot. We could really use some nice tweets from Lena Dunham.
Male Executive #2: You know she doesn't tweet anything herself, right?
Glasses-wearing Male Executive #3: We could just make another biopic about a queen. . .
Male Executive #2: I've got it! We'll pick a well-loved film and recast all the male leads with female actors.
Balding Male Executive #1: Brilliant! And we can pay them all less because they're ALL women.
Executive #2: I'll make some calls.
I'm not the only one who's sick of having studio executives from the wage-gap capital of the world mansplain feminism. As Amy Roberts points out, Hollywood seems to only be interested in throwing "cinematic slops" to women.
"In 2016, why is it that the movie industry feels as though it can only entrust a blockbuster movie to women as long as the film's story and characters are based on already successful male ones?" she writes.
She has a point — this is Hollywood — the place where women are consistently paid less than men, the town that forgets about women the second they turn 40, the place where it's hard for women to get roles any deeper than the shallow end of a kiddie pool, the city that hides its actresses of color.
June 24, 2016
"[W]hite activists [need to] stop casting Indigenous peoples as magical pixie enviro-pacifists"
Jonathan Kay on the problem with discussing First Nations people as if they are "Magical Aboriginals":
… the path toward reconciliation doesn't always run through Ottawa or Rome. Reconciliation also can take place at the level of friends, family members and neighbours. In a newly published collection of essays, In This Together, editor Danielle Metcalfe-Chenail brings together fifteen writers — some Indigenous, some not — who describe how this process has played out in their own lives. "[The authors] investigate their ancestors' roles in creating the country we live in today," Metcalfe-Chenail writes in her introduction. "They look at their own assumptions and experiences under a microscope in hopes that you will do the same."
In This Together is a poignant and well-intentioned book, and one that deserves to be bought and read. It is also informative and unsettling — though not always in the way the authors intend. Taken as a whole, the stories betray the extent to which guilt, sentimentality and ideological dogma have compromised the debate about Indigenous issues in this country.
In describing the stock "Magical Negro" who often appears in popular books and movies, Nnedi Okorafor-Mbachu once noted that this type of character typically is shown to be "wise, patient, and spiritually in touch, [c]loser to the earth." (Think of Morgan Freeman's portrayal of Ellis Boyd "Red" Redding in The Shawshank Redemption.) In This Together contains a menagerie of similarly magical-seeming Aboriginals who are "soft-spoken" and "insightful." A typical supporting character is the hard-luck Aboriginal child whose "entire face seemed to radiate a quiet knowing." Older characters speak in Yoda-like snippets such as "There is much loss — but all is not lost."
White characters in this book mostly are presented in the opposite way. They tend to be cruel, obese ("bulging," "fat, red-faced," "plump"), and soulless. Streetly goes even further, describing outsiders who come to Tofino as "faceless, meaningless" — as if they were robots. In a story about a First Nations woman with the dermatological condition vitiligo, Carol Shaben casts whiteness as an imperial disease — "an ever-expanding territory of white colonized the brown landscape of her skin." In matters of economics, whites often are depicted as amoral capitalist marauders ("quick to brand and claim ownership"), while Indigenous peoples are presented as inveterate communitarians — gentle birds who "soar above the land, take stock, perch without harming, settle without ownership, and be grateful without exploitation."
For decades, it has been a point of principle that Indigenous peoples in Canada must chart their own future without interference from outsiders. Our First Nations will have to make difficult decisions about what mix of traditional and modern elements they want in their society; and address wrenching questions about integration, relocation, language use, and education. Addressing these hard questions will be all the more difficult if Canada's leading thinkers — even those with the best of intentions, such as the authors of In This Together — build the project of reconciliation on a foundation of attractive myths.
It is our moral duty as a Canadians to acknowledge the full horror of what was done to Indigenous peoples. But we must not respond to this horror by seeking to conjure an Indigenous Eden of postcolonial imagination — a society that never truly existed in the first place.
May 26, 2016
Terry Teachout on silent movies
Ten years ago, Terry Teachout finally got around to watching D.W. Griffith's The Birth of a Nation, and found (to his relief) that it was just as offensively racist as everyone had always said. He also discovered that silent movies are becoming terra incognita even to those who love old movies:
None of this, however, interested me half so much as the fact that The Birth of a Nation progresses with the slow-motion solemnity of a funeral march. Even the title cards stay on the screen for three times as long as it takes to read them. Five minutes after the film started, I was squirming with impatience, and after another five minutes passed, I decided out of desperation to try an experiment: I cranked the film up to four times its normal playing speed and watched it that way. It was overly brisk in two or three spots, most notably the re-enactment of Lincoln's assassination (which turned out to be quite effective – it's the best scene in the whole film). For the most part, though, I found nearly all of The Birth of a Nation to be perfectly intelligible at the faster speed.
Putting aside for a moment the insurmountable problem of its content, it was the agonizingly slow pace of The Birth of a Nation that proved to be the biggest obstacle to my experiencing it as an objet d'art. Even after I sped it up, my mind continued to wander, and one of the things to which it wandered was my similar inability to extract aesthetic pleasure out of medieval art. With a few exceptions, medieval and early Renaissance art and music don't speak to me. The gap of sensibility is too wide for me to cross. I have a feeling that silent film – not just just The Birth of a Nation, but all of it – is no more accessible to most modern sensibilities. (The only silent movies I can watch with more than merely antiquarian interest are the comedies of Buster Keaton.) Nor do I think the problem is solely, or even primarily, that it's silent: I have no problem with plotless dance, for instance. It's that silent film "speaks" to me in an alien tongue, one I can only master in an intellectual way. That's not good enough for me when it comes to art, whose immediate appeal is not intellectual but visceral (though the intellect naturally enters into it).
As for The Birth of a Nation, I'm glad I saw it once. My card is now officially punched. On the other hand, I can't imagine voluntarily seeing it again, any more than I'd attend the premiere of an opera by Philip Glass other than at gunpoint. It is the quintessential example of a work of art that has fulfilled its historical purpose and can now be put aside permanently – and I don't give a damn about history, at least not in my capacity as an aesthete. I care only for the validity of the immediate experience.
[…] Thrill me and all is forgiven. Bore me and you've lost me. That's why I think it's now safe to file and forget The Birth of a Nation. Yes, it's still historically significant, and yes, it tells us something important about the way we once were. But it's boring — and thank God for that.
May 18, 2016
April 14, 2016
March 13, 2016
Artillery and Officer Training – Treatment of Colonial Troops I OUT OF THE TRENCHES
Published on 12 Mar 2016
Indy sits in the chair of wisdom again to answer your questions and this week we are talking about artillery training, the education for officers and NCOs and if colonial troops were used as first in trench warfare.
January 22, 2016
Top 10 Onion parodies on higher education
Yeah, I know it's a bit late in the year to still be publishing lame "top ten" roundups, but these are pretty funny:
1. Sex partner must say 'yes' every 10 minutes or it's rape, 10th graders taught in California
2. Princeton student say he's victim of microaggression over way he says 'Cool Whip'
3. Study urges people to accept those who 'identify as real vampires'
4. Professor: Harry Potter Helped Obama Get Elected
5. All-You-Can-Eat Taco Bars Deemed Offensive, Face Campus Extinction
6. Harvard Students Celebrate 'Incest-Fest' (tied with: Harvard University workshop to teach students how to have anal sex
7. Professors: Motorists more likely to run over black people than white people
8. Professor's Book Hails 'Apostle Barack,' Compares Him to Jesus
9. University axes homecoming 'king' and 'queen,' replaces it with gender-neutral 'royals'
10. Sexuality courses: Black dildos are proof of racism against African Americans
Update: Oh, wait. Sorry. These aren't actually headlines from the satirical website The Onion. They're all real headlines. My mistake.
December 20, 2015
When the police are afraid to investigate crimes
In the town of Rotherham, the local police have been effectively hiding a massive criminal conspiracy for fear of being accused of racism:
Fifteen years ago, when these crimes were just beginning, the Stephen Lawrence Inquiry into the conduct of the British police was made by Sir William Macpherson a High Court judge. The immediate occasion had been a murder in which the victim was black, the perpetrators white, and the behaviour of the investigating police lax and possibly prejudiced. The report accused the police – not just those involved in the case, but the entire police force of the country – of 'institutionalised racism'. This piece of sociological newspeak was, at the time, very popular with leftist sociologists. For it made an accusation which could not be refuted by anyone who had the misfortune to be accused of it.
However well you behaved, however scrupulously you treated people of different races and without regard to their ethnic identity or the colour of their skin, you would be guilty of 'institutionalised racism', simply on account of the institution to which you belonged and on behalf of which you were acting. Not surprisingly, sociologists and social workers, the vast majority of whom are professionally disposed to believe that middle class society is incurably racist, latched on to the expression. MacPherson too climbed onto the bandwagon since, at the time, it was the easiest and safest way to wash your hands in public, to say that I, at least, am not guilty of the only crime that is universally recognised and everywhere in evidence.
The result of this has been that police forces lean over backwards to avoid the accusation of racism, while social workers will hesitate to intervene in any case in which they could be accused of discriminating against ethnic minorities. Matters are made worse by the rise of militant Islam, which has added to the old crime of racism the new crime of 'Islamophobia'. No social worker today will risk being accused of this crime. In Rotherham a social worker would be mad, and a police officer barely less so, to set out to investigate cases of suspected sexual abuse, when the perpetrators are Asian Muslims and the victims ethnically English. Best to sweep it under the carpet, find ways of accusing the victims or their parents or the surrounding culture of institutionalised racism, and attending to more urgent matters such as the housing needs of recent immigrants, or the traffic offences committed by those racist middle classes.
Americans too are familiar with this syndrome. Political correctness among sociologists comes from socialist convictions and the tired old theories that produce them. But among ordinary people it comes from fear. The people of Rotherham know that it is unsafe for a girl to take a taxi-ride from someone with Asian features; they know that Pakistani Muslims often do not treat white girls with the respect that they treat girls from their own community. They know, and have known over fifteen years, that there are gangs of predators on the look-out for vulnerable girls, and that the gangs are for the most part Asian young men who see English society not as the community to which they belong, but as a sexual hunting ground. But they dare not express this knowledge, in either words or deed. Still less do they dare to do so if their job is that of social worker or police officer. Let slip the mere hint that Pakistani Muslims are more likely than indigenous Englishmen to commit sexual crimes and you will be branded as a racist and an Islamophobe, to be ostracised in the workplace and put henceforth under observation.


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An event location to rent.
A Venue to learn - workshops and events.
For people who think that creativity needs a space to emerge, who seek to create long-lasting success and who believe that success requires the inspiration of others.
COKREA is a creative space, a market place for ideas, concepts and methodologies to unleash and discover your purpose with simple but truly effective methods.
A space how it should be. Spiced with the best ingredients to perform, a place that just feels great.
We live in a time of disruptive change. How to activate our capacity to lean into the emerging future may well be the most important challenge of our time.
How do we cultivate curiosity, compassion and courage in the face of prejudice, anger and fear?
We strive for genuine identity and self-realization, on the other hand we are forced to be creative but efficient, to act economically and professionally. Tough...
In order to master these challenges with ease and joy, we believe that success and change is better achieved in a creative and inspirational inviornment, where working is fun and where you feel at ease.
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For most of us the trigger to act, to overcome obstacles and to create something new is far easier to achieve in a collective effort and in a motivating setting.
This process is called COKREA-tion.


text: Brian Kunkleman Pottery for Uncommongoods Brian Kunkleman is an amazing artist who makes some great pieces for Uncommongoods. Last year, I got to tour his studio where he showed me the process to make his berry bowl. Here are some images from that shoot. Posted on June 17, 2017June 17, 2017 by emilydryden 0


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motorcyclistnoun [ C ]uk /ˈməʊ.təˌsaɪ.klɪst/ us /ˈmoʊ.t̬ɚˌsaɪ.klɪst/
› a person who rides a motorcycle
Thesaurus: synonyms and related words
(Definition of "motorcyclist" from the Cambridge Advanced Learner's Dictionary & Thesaurus © Cambridge University Press)
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a person who has spent a lot of their life doing yoga and studying the philosophy of yoga


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Question about Dishwashers
Posted by carol959 on
SOURCE: Dishwasher draining - Bosch SGV4313GB/17
This is generally because of a stuck diverter solenoid. The water goes to the pump and then is either sent to the wash arms or the drain. Also, check the drain.
Posted on Feb 11, 2008
SOURCE: Bosch SHX Dishwasher keeps beeping when it is finished.
If you wish to eliminate or reduce the volume of the end of cycle beep you can do so by powering off the unit and turning back on while holding the right button "Cancel/Reset". The beep has 3 volumes levels and silent, press the right "Cancel/Reset" button to cycle through the settings. Power the unit back off to save you setting.
Posted on May 19, 2009
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Now that the Federal Government has allowed the cold call solicitation of cell phones, and once again created a completely worthless item; The National Do Not Call Registry , once again we are forced to deal with the problem ourselves.
Some cell providers offer, for a fee of course, the ability to block specific numbers. Some high end phones have the same feature built in to their software.
For those of us still using basic phones or if like me you are just to cheap to pay for this kind of service there is a simple fix.
Most of even the basic phones allow you to set individual ring tones for your contacts. Using that feature, set the cold caller as a contact with junk or some other descriptive name, then choose the no ring option for the ring tone.
They can call all they like but you'll never hear it. And since like any other business their resources are limited they will eventually drop your number from their database. Then simply delete the contact if you need the space in your address book.


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Los Angeles Philharmonic
Dudamel Conducts Tchaikovsky
Audio not yet available
Tchaikovsky's Symphony No. 6 "Pathetique," an exquisite study in angst and suffering, was the centerpiece of the Los Angeles Philharmonic's final concert of its 2009-10. Tonight's broadcast features that work and the Dvorák Cello Concerto, a work that was begun a year after the "Pathetique." Joining music director Gustavo Dudamel is Alisa Weilerstein, the dynamic young cellist who recently performed for President Obama in the East Room of the White House.
Program Details:
Conductor: Gustavo Dudamel
Cello: Alisa Weilerstein
Dvorak - Cello Concerto
Peter Illyich Tchaikovsky - Symphony No. 6 "Pathetique"


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101+ Best Whatsapp DP Images With Popular Quotes Of All Times
Few meaningful lines said by famous people, which actually have values and describe every single word in depth becomes popular quotes. By using these famous quotes, we create love Whatsapp status, life status, famous Whatsapp status and share them in our groups. We sometimes put theses quotes on attractive images and keep them as DP for Whatsapp.
But, no matter whatever quotes we choose, we make sure the quotes have some meaning. Nowadays, people use Whatsapp and facebook to show others that what they are feeling.
If they are travelling, they post travel images. If they are sad, they post sad Whatsapp status and if they are in love, they put love Whatsapp DP.
They feel blessed if their life is smooth and happy. To make people aware that they are happy, they share best life images on Whatsapp DP and groups with happy quotes. But, before posting all these images they go on the internet and do some research. They try to find the most popular quotes related to their status and copy paste those them on their covers. They share the best images on groups.
Today, here we have collected most popular quotes with Images for Whatsapp DP. Do share and comment which one is your favourite.
Have A Look At 101+ Best Whatsapp DP Images With Popular Quotes Of All Times Here –
Best Whatsapp DP Images With Famous Quotes
DP For Whatsapp With Friendship Images with Quotes
DP For Whatsapp With Inspirational Images with Quotes
DP For Whatsapp With Life Images with Quotes
DP For Whatsapp With Love Images with Quotes
Also Check –101+ Unique DP For Whatsapp In Hindi And English
65+ Latest Inspirational Images For Whatsapp DP


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August 19, 2013
To meet other lovely amazing plant powered people.
See above and below.
- health and wellness - yoga - cooking - hiking - global gender equality
Very much so.
Just moved here from Portland, OR. Been working on community health and environmental issues for years and have been meat-free since childhood.
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The Kharkiv administration building was occupied by pro-Russian demonstrators on April 6. Police say they regained control early on April 8 without firing gunshots, although they say the activists injured three officers with gunshots.
Late on April 7, a small group of pro-Russian separatists proclaimed the Peoples' Republic of Kharkiv, independent of the rule of the central Ukrainian government Kyiv. They announced they were going to hold a referendum on Kharkiv Oblast joining Russia and sought support from former President Viktor Yanukovych and Russian authorities.
Earlier this week, a group of separatists proclaimed the same in Donetsk Oblast, but the decision was promptly canceled on April 8.


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Each year around million tons of construction and demolition waste is gathered throughout the globe. After the end of their serviceable life as a building, pavement or other construction work the remaining materials can be recycled by diminishing the material amount which is land filled.
Demolition Waste Removal
DKI Demolition 6346 Orchard Lake Rd Ste #16 West Bloomfield, Mi 48322
An Archaeology of Urban Transformations: Lara Almarcegui's Works
Experimental architectural claddings, still under development, result from a variety of waste materials that would otherwise be landfilled. Image Courtesy of Stonecycling:
The Psychology of Spending Money: Infographic | savingtools.com
Iceberg Trading Post / Alexandre Braleret
Screen Shot 2013-04-30 at 4.21.18 PM.png (1819×1287)
Oh so beautiful! A chair by John Booth constructed from found and recycled wood from old unwanted furniture items.


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Gayle Benson Visits the Academy
Academy of Our Lady welcomed Mrs. Gayle Benson, owner of the New Orleans Saints and the New Orleans Pelicans to the school.
Mrs. Benson shared her personal journey as a Catholic, a student, a professional, a business owner, and a married woman. She challenged the students to remain faithful to the values learned at the school and to allow God to work in their lives so as to discern his plan for them.
The audience was happy to know that Mrs. Benson grew up in Algiers on the Westbank, and attended Holy Name of Mary school—the school some of the students themselves attended. At the end of her presentation, Mrs. Benson took questions from the students.
Sr. Michelle Geiger, Principal, introduces Mrs. Benson to the student body.
Academy Welcomes Gayle Benson 02: Sr. Carmen Pena, Sharon Rodi, and Sr. Michelle Geiger with Mrs. Gayle Benson.


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Listing ID: 217000303
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Listing Price: $1,499,000
Status: Active
Bedrooms: 4
Full Baths: 4
Partial Baths: 2
Total Baths: 4
Square Feet: 7,000
Acres: 0.830
Magnificent New Construction built by Pertona Building Company. This spectacular home will include over 5000 sq. ft. of exceptional living space; featuring four bedrooms, four full baths, two half...
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Hannibal Industries is proud to be part of QVC's giant expansion in Ontario, California which will handle up to 20 percent of the company's distribution, covering the entire western region of the United States. This warehouse will employ up to 1,000 people and is a leading-edge facility built with the industry's leading racking system by Hannibal Industries.
Since its initial release in 2012, TubeRack has successfully been installed globally, endured its first-ever impact test, formed strategic partnerships to develop a new racking product and has expanded into new industries.
TubeRack's modular design is engineered to be more impact resistant, to reduce product shedding in the case of an impact or seismic event, offers better tolerances, and more efficient shipping. The system's dual-moment frame allows flexibility both front-to-back and side-to-side giving it the ability to withstand impacts and seismic activity.
This new facility is expected to fill the racks starting this week and become a fully functioning distribution center before the holiday shopping season begins. The company has never had a West Coast distribution center, with the last one opening in South Carolina in 2007.


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Monetizer platform: What it isAs a software developer, you must opheffen aware about the various monetizing platforms. These platforms offer ample opportunities to the developers to earn an extra buck remote their hard work. They can do so by bundling software. Through this method, they can gain anted for every instate by the user. Sounds cool?!! Read on for more information on these money- making platforms. How it works:The platform offered is pretty simple to understand. The process is quite easy. All that the software developer has to do is bundle their software with the software of the advertiser. When the developer installs the user's software, the user is displayed with an offer to install the advertiser's software as well. It is mostly in the nascency of toolbars. The offer is displayed in the middle of the installer process. The user can sanctioned or decline the offer. If they accept the offer, the advertiser's software gets installed and the publishing developer gets paid for it. Every time a user installs the advertiser's software, the developer gets paid for it. One of the best software of this sort is Installmonetizer. Benefits of using installmonetizer platform:The monetizing platforms offer numerable advantages to everybody involved in the process. The software developers, promoters et cetera advertisers and consumers, all stand to benefit from it. Apart from this, the platform also offers to monetize:Various content sitesDownloading portalsUnique distinctive software productsAffiliate programs, pages and platformsThe platform plus provides the users with the options to customize the look, control the offers and generate the live reports. The tribune is even optimized for the conversions, and nought for the payouts. This results in more revenues and fatter payouts. The real time reports and updates & a user friendly – environment adds to its popularity.Benefits for the software developers:The concept about this platform is relatively new and the payouts are very high. It provides the highest fill rates. There is more success in customer retention and downloads. The developers also get to work with the global advertisers. The process of bundling is easy and can be ended in 10 minutes' worth of coding. Benefits for the software advertisers:The software promoters and advertiser's can boot from the various advantages that the process has to offer. The first and banner is that they travel access to the cleanest install networks. The developers make an extra effort to keep the process spyware free and malware free. The doubts about it spreading harmful viruses and stealing data can be put to rest. Next, the advertisers get to increase their client base by having access to the global users. They get quality global installs through the publishers that work in almost all of the countries in the world. Another benefit is that they work beside the high quality distribution channels that offer very emulous rates. This also provided a economize effective and popular means to promote alternative launch a new or less popular product. Benefits for the consumers:The customers get aware of the many products that they did not know of earlier. They are spoilt for choices. So, if you are a software developer, you can make use of this platform to make some extra money without much effort.
Month: March 2017
Book for the Cheap Indian Safari Holidays from Australia
Aussies are known for their adventurous nature and especially for their love of safari holidays. If you are one such blazing traveler who would like to enjoy wild safaris later India should afsluiting your next traveling destination. From feeding Kangaroos to feeding Elephants, from Crocodile harvesting in Aussie to the Tiger reserves in the tropical forest of India, from water buffalos of Australia to watching rhinos in India, you can hedonistic the extremes when you book for Indian safari holidays from Australia online!Enjoy at Tropical Forests, 500 Sanctuaries and 99 Hereditary ParksYou must believe that India has a great diversity in its geographical location alongside different types of forests in its different regions. The northern goal is snowy et sequens mountainous while the west is a dessert region in India. The royal tigers, lions, rhinos, exclusively packages to the tusker reserves, bird watching with thousands like rare bird species, black buck safaris, and also you can enjoy when you book for your safari holidays in India. The safari travel packages are available from 6 days and you retain the privilege to extend it for about 17 days. The safaris cover the edifying and wildlife high points of India like the following:* Ranthambore tiger exploration region* India's biggest national park Corbett* Trekking at the snowy eastern Himalayas* Asiatic lion safaris at the Gir national park* Safari at the Himalayan kingdom of Nepal like the Chitwan and Bardia* Safari in the Kanha and the Sunderban region* Tiger and elephant reserves of the south admire the Periyar national stop and more.Book OnlineTo faction the most memorable Indian safari holidays from Australia you can visit the websites of the Australian international tour operators. Make sure you locate a travel operator who offers you exclusive packages that covers group important safari destinations of India. Few travel companies also offer customized tour parcel options that will allow you save more time and money by just visiting the destination of your choice. Say for example, if you wish to visit the jungles homing Asiatic Lions then you can check for a excursion container from Australia to the Gir Forest region concerning India lies in its Western part. To make your travel booking online most inexpensive and assist you can compare your holiday quotes online to ensure that the travel company you have chosen is offering you the cheapest service for maximum comfort and safety.


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March 17, 2010
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Revenue Ruling 79-34 1979-2 C.B. 233
Rev. Rul. 79-34 1979-2 C.B. 233; 1979 IRB LEXIS 190, * Revenue Ruling 79-349 Rev. Rul. 79-349; 1979-2 C.B. 233; 1979 IRB LEXIS 190 July 1979 [*1] SUBJECT MATTER: Section 512.-Unrelated Business Taxable Income APPLICABLE SECTIONS: 26 CFR 1.512 (b)-1: Modifications. (Also Sections 401, 511, 513; 1.401-1, 1.511-2, 1.513-1.) TEXT: Unrelated income; interest and service fees on mortgage loans. Interest income earned by an exempt employees trust from mortgage loans, which form a significant portion of the trusts' assets, does not enter into the computation of unrelated business taxable income under section 512 of the Code. Service fee receipts earned by the trust in connection with such loans, however, do enter into the computation. Advice has been requested whether an exempt employees' trust has "unrelated business taxable income" within the meaning of section 512 of the Internal Revenue Code under the circumstances described below. An exempt employees' trust described in section 401 (a) of the Code continually holds a substantial number of mortgage loans. These loans form a significant portion of the total assets of the trust. The trust has consistently derived interest income and service fees from such loans in amounts constituting a significant percentage of the income of the trust during the past four years. Each year the trust receives several hundred loan applications from [*2] corporations, firms, partnerships, and individuals from all over the United States. While the trust does not otherwise advertise this activity, it does erect billboards on construction sites which show that it has financed the project. Further, the trust is well known as a lender in the mortgage industry. Loan applications are screened by a steering committee consisting of attorneys, accountants, appraisers and other personnel employed by the trust. The lending activities are conducted on a year-round basis and the loans made are competitive with those made by commercial institutions. The service fee receipts represent earnest money deposits and prepaid service fees equal to one percent of the principal amount of each loan for legal, closing, appraisal, and accounting costs related to the loan. There is no acquisition indebtedness (as defined in section 514 (c) of the Code) with respect to the trust's assets. Section 511 of the Code imposes a tax on the unrelated business taxable income of certain exempt organizations, including exempt employees' trusts described in section 401 (a). Section 512 (a) of the Code states that, except as otherwise provided therein, the term "unrelated business [*3] taxable income" means the gross income derived by an organization from any unrelated trade or business (as defined in section 513) regularly carried on by it, less the allowed deductions which are directly connected with the carrying on of such trade or business, both computed with the modifications provided in section 512 (b). Section 512 (b) of the Code excludes interest income from the computation of unrelated business taxable income. Section 513 (b) of the Code states that the term "unrelated trade or business" means, in the case of a trust described in section 401 (a), any trade or business regularly carried on by such trust. For the purpose of section 513 the term "trade or business" generally includes any activity carried on for the production of income from the sale of goods or performance of services. See section 1.513-1 (b) of the regulations. Section 1.513-1 (c) (1) of the regulations states that, in determining whether trade or business from which a particular amount of gross income derives is "regularly carried on," within the meaning of section 512 of the Code, regard must be had to the frequency and continuity with which the activities productive of the income are conducted [*4] and the manner in which they are pursued. This requirement must be applied in light of the purpose of the unrelated business income tax to place exempt organization business activities upon the same tax basis as the nonexempt business endeavors with which they compete. Hence, for example, specific business activities of an exempt organization will ordinarily be deemed to be "regularly carried on" if they manifest a frequency and continuity, and are pursued in a manner generally similar to comparable commercial activities of nonexempt organizations. In this case, the volume of loan activity and manner in which the trust organizes and maintains its mortgage loan operations are comparable to these same activities by banks, savings and loan associations, insurance companies, and similar commercial institutions which compete for mortgage loan business for a profit. Based on the standards set out in the foregoing regulations, this mortgage loan activity constitutes trade or business regularly carried on by the trust within the meaning of section 513 of the Code. Subject to certain exceptions not present in this case, however, section 512 (b) (1) of the Code and section 1.512 (b)-1 (a) of the regulations [*5] exclude interest income from the computation of unrelated business taxable income. Interest paid on loans made by the exempt employees', trust is interest within the meaning of section 512 (b) (1) and therefore is excluded from the computation of unrelated business taxable income. The service fees receipts described above, however, are not interest. Rev. Rul. 69-188, 1969-1 C.B. 54, sets forth certain criteria for use in determining whether a debtor-creditor relationship exists for the purposes of treating as interest a "loan processing fee" (points) paid by a mortgagor-borrower as compensation to a lender solely for the use or forbearance of money. The Revenue Ruling holds that where the taxpayer is able to establish that the fee is paid as compensation to the lender solely for the use or forbearance of money, the fee is considered to be interest. It is not necessary that the parties to a transaction label a payment made for the use of money as interest for it to be treated as interest. Rev. Rul. 69-188 provides that, in order for such fees to be treated as interest, however, the fees must not be paid for any specific services that have been performed or will be performed in connection [*6] with the loan. For example, interest would not include separate charges made for investigating the prospective borrower and his security, closing costs of the loan and papers drawn in connection therewith, or fees paid to a third party for servicing and collecting that particular loan. Also, even where service charges are not stated separately on the borrower's account, interest would not include amounts attributable to such services. See Rev. Rul. 67-297, 1967-2 C.B. 87. The service fees are attributable to specific services (i.e., legal, closing, appraisal, and accounting costs) performed in connection with each loan and are not paid as compensation to the trust solely for the use or forbearance of money. Therefore, such fees do not constitute interest and are not excluded from the computation of unrelated business taxable income under section 512 (b) (1) of the Code. Accordingly, the interest earned by the trust in this case from its mortgage loan business does not enter into the computation of unrelated business taxable income, but the service fee receipts earned by the trust in this case do enter into the computation of unrelated business taxable income.


text: And Here We Are ! Feb 28, 2016 Well here we are and we are very excited to have our first post before we launch our website, just in time before we embark on our trip to Milan for Mifur 2016 excited ! Share 0 Tweet +1 Leave a comment Name Email Message Please note, comments must be approved before they are published