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However, he was quick to pass on all the credit to the forwards and the Worcester back row who produced an inspired display against the Bath's powerful line-up that included former England captain Lewis Moody, South African international Francois Louw and Scottish star Simon Taylor.
"It was a case of making sure we played for the whole 80 minutes," said Carlisle. "We knew we had it in us and all he boys are hugely happy with the result.
"It was a physical game and they have got a big back row. It was going to be a battle for us, but I thought out back row was top notch with their work rate and physicality.
"It always starts in the forwards and whether they can lay down a decent platform for us to play.
"When we had the ball on the front foot we know we can have an impact with the likes of Miles, Marcel and Errie. All the backs had a great game and Miles managed to finish off that try.
"Miles likes to run that line and I think I had a big boy in front of me so I knew Miles could get on the outside, it was just a case of giving him the ball and seeing what he had got."
Carlisle almost capped off a fine display with a try when he picked off a second half intercept only to be hauled down.
But he admitted he was just happy to be playing and getting a run in the side with so much competition for places.
"I knew I wasn't going to make it when I picked off the pass as when you have got Nick Abendanon chasing you down you are not going to get very far," he smiled. "Luckily Raz was in support and he managed to pick one off his toes.
"It's nice to get a run in the team and, as a ten, it is always good to get these games on the bounce so you can find your groove.
"I know I have got to play well with the likes of Danny (Gray) playing very well and Goodey (Andy Goode) who is highly experienced.
"They are biting at my heels and all three tens are training well, it's tough competition and you have got to improve.
"We now turn to Exeter Chiefs next week and they are obviously very good at home, but this result will give us confidence and we look forward to that trip."


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Two weeks ago, smokers started really feeling the latest cigarette price rise. The main brands, including Marlboro, Fortuna and Chesterfield, went up by between 20 and 25 cents, to almost 4.50 per pack, forcing many smokers to move over to roll-ups.
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The bargain is even greater for those who visit the Canary Islands. Taxes are much lower there and a pack of cigarettes costs between 1.60 and 2.60 euros depending on the brand. Visitors to Andorra benefit from the same tax savings, with cigarettes on sale at aroung 2.6 in the principality.
The European Commission is currently trying to introduce new laws to reduce tobacco consumption, including making all cigarette packets identical, with the brand name much smaller than the health warnings. The idea comes from Australia, where all cigarette packets will be olive green from December 1st onwards. The aim is to get rid of any glamorous associations people may have with smoking.


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Touchstone: A Journal of Mere Christianity
"A Circle of Love" first appeared in the July/August 2010 issue of Touchstone.
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A Circle of Love
My wife Kathie and I married too late to start a family of our own, but we are blessed to have a spiritual extended family of parents and children. These include my daughter from a previous marriage and her adopted daughter, and families that come to Kathie's children's library. There is also a special group of families that we have vacationed with every summer for many years, usually at two rented houses on a California coastal beach near Santa Cruz.
When we are with this group at the beach location, I am the most contented of family men. The last time we were together there, in July 2009, we had all the regulars, including teenagers who had been toddlers when the tradition of going to the beach began. It is enchanting that our teenagers, who are expected to be in a naturally rebellious season of life, are devoted to the tradition and want the gathering to be the same each year in every detail, as when we first began. The last time we assembled this group, there was a new baby with the impressive biblical name of Obadiah. His great cuteness made him the center of attention for everyone.
Enjoying the proceedings, my contentment overflowed so much that I announced, as if I knew all about it, that heaven is a community of believers united by love. If I am correct in this, we do not have to wait to see what heaven is like, because we have been getting a taste of it in our summer gatherings. I am thus convinced that the best life is the one that contains the greatest amount of love, both received and given, no matter what troubles that life may also contain.
Deep Discouragement
If I had a preliminary taste of heaven last summer at the beach house, I subsequently had an exposure to some of the more depressing features of earthly existence. On December 4, 2009, I was taken by ambulance to the hospital, in a crisis caused by a common condition of aging men, unrelated to my previous two strokes. Although that crisis was quickly resolved, another, more serious one came up while I was recovering in rehab. This time I had major surgery, followed by a series of infections that made it uncertain when I would ever get out.
The experience of a long hospital stay, including a lengthy period of recovery from surgery, left me deeply discouraged. I had no desire to eat, was not interested in reading, lost my voice, and began wishing for an early and quick death because it seemed to me that my active life had come to an end. I had a number of visitors, the most important, perhaps, being a man we know from Kathie's children's library. He pastors a small community church and heard of my wish for death. He reminded me that I am in God's hands and that my lifespan is determined by him.
The situation didn't seem to be getting better when I finally was released to go home after two months, because I kept falling and Kathie had to keep getting help to lift me up. I was concerned that I was becoming a burden and was still more interested in dying than living.
The Fruits of Love
Now that I have been home for more than two months, my appetite and voice have returned, and I have regained my interest in reading books and finding worthwhile news stories on the Internet. Despite my pessimism, I have worked hard at physical therapy, and my therapists are impressed at how much strength I am gaining. With their help, I have progressed from using a cumbersome walker to walking with a simple cane. I hope to be walking unassisted soon. I will need all the strength I can develop to be ready for some follow-up surgeries.
When I was in the hospital, Kathie brought me cards and letters almost every day from the wide-flung community of Intelligent Designers. I didn't always appreciate them at the time because I was so low, mentally and spiritually as well as physically. Since I have been home, it has given me great pleasure to read through these and remember that my circle of loving people extends far beyond those who live locally. My morale was further boosted when Touchstone editors Jim Kushiner and Fr. Pat Reardon, with three of their friends, paid a visit to our Berkeley home.
I am learning that the path to a good quality of life lies in doing the right thing during the day at hand, and leaving the future to God, as Jesus advised. If that is possible for me, it is because I am surrounded by loving people, beginning with my wife. It is hard to stay discouraged when I receive and return such love on a daily basis.
Phillip E. Johnson is Professor of Law (emeritus) at the University of California at Berkeley. He is the author of Darwin on Trial, The Wedge of Truth, The Right Questions (InterVarsity Press), and other books challenging the naturalistic assumptions that dominate modern culture. He is a contributing editor of Touchstone.
☞ Touchstone is made possible by donor support.
"A Circle of Love" first appeared in the July/August 2010 issue of Touchstone. If you enjoyed this article, you'll find more of the same in every issue. Support the work of Touchstone by subscribing today!
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The Loach Forum Archives (2)
Flame has been blocked
Posted By: Jeff Shafer - Webmaster <email@example.com>
Date: Thursday, 20 January 2000, at 6:30 p.m.
Hi everyone,
Flame was back on the board this afternoon, and, among other things, posted under Dave Guest's name. I know it was Flame because I matched this new IP address with about five of his earlier postings. Anyway, the posts have been removed, and Flame has been banned from AquaWeb. All of his attempts to access the forum should just route him to the Web Forum Policy page. :-) If, however, he has access to another ISP and starts posting, could everyone email me ASAP, so I can block that ISP as well?
Thanks, and sorry for the trouble.
Messages In This Thread


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began with an ad ran in a local newspaper by current owner
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The Eee PC's tiny keyboard is its biggest drawback. All of my test subjects struggled with its Chiclet-sized keys. Touch typing is extremely difficult. But my own, unorthodox hunt-and-peck method served me adequately, and before long I could maintain a rapid rate with few errors. If you can, definitely try it yourself before you buy (and note that some Eee PC models now come with larger keyboards).
I did like the Eee PC 901's hotkeys for applications and power-saving functions, and its iPhone-like multi-touch trackpad made zooming and scrolling easier -- though the trackpad functions weren't as responsive as they could be.
By comparison, the Mini-Note's keyboard raises no eyebrows. HP claims that it's 92 percent of standard size, and that feels about right. The silver keys are comfortable and have good travel, and most users should take to them without difficulty. The trade-off is that the Mini-Note's chassis is wider than the Eee PC's by more than an inch.
Tiny screens could also be a problem for some users. Of the two devices I tried, the HP 2133's screen had higher resolution, but that just made fonts harder to read. At the same 8.9-inch size, the Eee PC's screen seemed crisper, brighter, and more legible overall. I also appreciated the keyboard hotkey that flips the Eee PC's screen sideways for reading documents in portrait mode.
For presentations, however, the screens are a non-issue. Both devices also include standard audio jacks and a VGA port, making them practically ideal for PowerPoint.
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The Eee PC's SSDs (solid-state drives) are one of its more intriguing features, but in practice I found them to be a mixed bag. Asus boasts of fast boot-up times, but the SSDs definitely write more slowly than traditional hard disks. When downloading large files, for example, drive I/O is the bottleneck, not network bandwidth.
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My HP 2133 model used a standard hard disk (SSDs are optional), so it had storage space to spare. But compared to the Eee PC it booted slowly, and its internal fans were much noisier. Hard drives are also less rugged than SSDs; but then, neither of these machines is exactly built for combat. I haven't much faith that either machine could survive any major blows.
Cost vs. Benefit
So are netbooks worth it? Whereas early Eee PC models were notable for their rock-bottom pricing, Asus seems to be distancing itself from the notion of the Eee PC as a "disposable laptop." The latest models feature improved build quality but higher price tags, with the 901 listing at $599. And HP's 2133 Mini-Note line is even more expensive, at $499 for a stripped-down configuration running Linux.
Even at $750 for a well-equipped model, however, the 2133 retails for a fraction of the price of earlier ultralight notebooks, yet delivers most of the capabilities. If you value performance over size, standard-format notebooks can be had even less expensively; but in the ultralight category, the Eee PC and the HP 2133 are both incredible bargains. Either should come as a breath of fresh air to weight-conscious customers, who have traditionally paid a premium to lighten their carry-on bags.
When I say not to expect too much of these machines or their forthcoming competitors, then, "too much" is really the operative phrase. Long-term use will surely be fatiguing, and lack of an optical drive could make netbooks a hassle to configure and maintain in department-wide deployments.
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It's no secret that I am constantly dreaming of having a baby. Of course when I say "dreaming of having a baby" I typically will mean the day dream type. It is constantly on my mind. At work I find myself wondering about if my children will have any hair when they are born or trying to come up with some more baby boy names since hubby and I can't agree. I swear I can't go a minute without thinking about having a baby.
However, every once in a while I have actual dreams of having a baby. In all of these types of dreams I have a baby girl. Perhaps this is because I have my girl names already selected. Whatever the reason I find it a little strange. The latest dream occurred a couple of nights ago. My little girl looked a lot like I did when I was a baby. Other than that I don't remember many other details other than I kept showing people and I was constantly holding her. However, the most vivid part of that dream was the thoughts I had.
Now I don't know how many of you are able to stop dreams or change dreams by command but I am. This night I had the thought, "I will be pregnant sometime in the next year." Um what was that again? This wasn't a command to change my dream as I was quite enjoying it. This leaves me to wonder, am I spending way too much time thinking about having a baby that my wishes translate into dreams and what I want to hear? Part of me thinks that this is indeed the answer but the other part of me that is looking for hope is wondering if maybe this was a sort of revelation and that I will indeed be pregnant in the next year.
This whole thing may sound silly and you might venture to guess that getting pregnant in the next year is a logical guess but I am not normal in any way. We have been ttc for 18 months. Everything seems to be doing what it is suppose to but still there is no pregnancy. Story of my life, no explanations for anything. Thus I really wonder if I will ever get preggo let alone in a year.
I can't seem to get this dream off my mind and I really wish I knew the reasoning behind it. For now we'll go will the whole revelation thing only because I need something to hope in and that's better than crumbling.
I also kind of hope that I keep on dreaming of having a baby, those dreams are so much better than the scary ones or the bad ones. What do you think? Do you often dream of having a baby? Were the details from these dreams accurate? For example, if you are like me and keep dreaming about a girl, did you in fact have a girl? Dreaming of a having a baby can sure be complicated.


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Uncyclopedia:Pee Review/Holy Martian Empire
From Uncyclopedia, the content-free encyclopedia
edit Holy Martian Empire
Ch00bakka 14:52, June 21, 2010 (UTC)
I'll reserve this for tomarrow, which then I be able to complete it in 12 hours or less--DirectorWILLYOU 333Talk IF YOU DARE 05:22, June 22, 2010 (UTC)
- I'm here now--DirectorWILLYOU 333Talk IF YOU DARE 14:18, June 22, 2010 (UTC)
- 60% done--DirectorWILLYOU 333Talk IF YOU DARE 19:33, June 22, 2010 (UTC)
Almost down--DirectorWILLYOU 333Talk IF YOU DARE 02:29, June 23, 2010 (UTC)
|I like to write a lot of things, I'm pretty good at Pee Reviews, and I received an award Author of the Month Award and one feature. Also I like Avenged Sevenfold, Modern Warfare 2, Halo 3, and brunettes and emo girls.
|I think the idea of a holy empire on mars is good idea. The article, however, was a bit of a letdown. When a reader sees the title Holy Martian Empire, they expect the article to be related to something like the Holy Roman Empire like or something like that and made into a Martian styled version of it. In the article itself, however, this is rarely the case. Instead, the article itself talks more about sex, violence, McDonalds, randomness, complete nonsense, rather unfunny jokes, and other things that I will explain later in the review. You have a good idea, but you didn't execute it well, and that's what's killing your article. Luckily, that's what I'm for; to give you advice on how to improve the humor of the article, as well as improvement on other areas of the article. My first advice is that you read HTBFANJS, a valid and brilliant source of information that helps improvement on these areas, and tells you what's best to use, and what's not.
One problem of the article is the tone of the article. You use an encyclopedic tone at times, and then veer off to a first person tone. This type of thing rarely works, and makes the article look very unprofessional. I and a few other reviewers highly discouraged this kind of writing. You can, however, use this if you put in a narrator and create a dialogue between the person narrating the article, whose tone is borne out by subtle humor and observations. This requires some work, and if you do it right, it'll work. If you do not want to do this, then I recommend that you choose a tone and stick to it throughout the entire article without veering off to another tone.
|Prose and Formatting:
|You have numerous problems here and there, especially in spelling and grammar. I will go through them one at a time.
You have made many spelling and grammar mistakes, which is common even for professional Uncyclopedians. The best way to fix mistakes and preventing from making new ones is reading over what you have type to check for mistakes. When you see an error, you just hit edit and fix that mistake. Although you might miss a word or two that you think it's right when in reality it's wrong. So using the spell-check on Microsoft Word is another great thing to fix errors. Although it might show that a word is spelled incorrectly but in reality it's spelled correctly, so watch out for that. A highly better solution would be the proofread service, were you simply put a proofread template on your article and someone from the proofreading service will come by and make corrections for you. Also, always spell Martian and Jesus with the first letters capitalized. It's incorrect if you do not do it like that
Profanity is another problem; you use it constantly use it. In HTBFANJS, it has a rule that say the following: "There's no reason to swear like a US Marine Drill Instructor or make tasteless references every other sentence.''' And I can see you did just the opposite. While it can get a few laughs, don't use it as your primary source of humor. That makes the article very dull, and people will frown upon that. Remember, just because oyu think its funny doesn't mean other people will think it's funny. It's better if you come up with something original, or at least putting it in an original manner, rather than rely on shock factor as a fucking crutch.
Also, please try to refrain from using strikethrough as much as possible. It's not particularly funny and is constantly over used.
|Let me start off by saying that the humor of the article, along with the tone, is the main downfall of the article. I'm not saying this to be mean, I'm being honest. Naming people, cities, and animals with names that use no vowels is good for humor, since an alien language would be different than ours, so that's one thing that should stay. But the rest needs work.
Your intro isn't a very good intro for the article. "This is an abridged semi-history of the Holy Martian Empire" Why can't it be a full history? You should use that instead. "For a full history, containing all of the boring details, see the Encyclopedia Galactica, Volume MCCCLXVII, Sub-volume 50, pages 367-9854." Uh, no. The article is supposed to contain the full history. Don't tell users to go to somewhere to read a history when that's the article's job itself. And I highly doubt Encyclopedia Galactica actually exist; don't tell users to go somewhere that is made up, just use the real thing. "For another good history, see this page." First, that links to a website that shows a Rick Roll, which has nothing to do with the Holy Martian Empire. Don't put links to places that are off topic. Second, try to keep Rick Rolling to Youtube or something like that.
The problem with the article is that you use a lot of things that are just not funny, or that you do not execute it very well. For example, "Nobody seems to have any idea exactly why these wars are called the omega wars, but nobody wants to argue with historians, who are always really bloody-minded bastards who never let go of an idea once they've held onto it for longer then five seconds," this could be worded better, like "The reason for the names of the Omega Wars are a mystery, and trying to argue about it on Mars isn't the wise thing to do, because Martian historians are known for their blood thirsty, savage nature towards anyone who would contradict something, and anyone who does would meet a bloody, terrifying end." See what I did? If you word your jokes better like I just showed you, the humor would come out better. Using your own judgment and HTBFANJS will help you with this. It'll take a lot of work, but it will help.
|You have images, and they support your article well, and the captions are good, but you should expand the humor on the captions some. Also, make the images bigger, and spread them out so they don't cramp the article.
|My overall grade of this article.
|Final Score:
|After reading the article it seemed that you were a new Uncyclopedia; but after seeing your contributions, it reveals that you've been here since November last year (meaning that you've been here around six or seven months) so I assume you haven't gotten yourself familiarized with HTBFANJS yet. So I highly suggest you do that before writing another article. Anyways, you have a good idea; you just need to improve on how you execute it. Follow my advice and reworking the article should be no problem. If you have any questions/comments, just go to my talk page and I'll be happy to answer them. Good Luck! Cheers!
|--DirectorWILLYOU 333Talk IF YOU DARE 03:04, June 23, 2010 (UTC)


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China's factory output rose by 9.3 per cent in April compared with March's 11.9 per cent, as cooling demand at home and abroad dragged on production growth
Economists had expected industrial production growth to stabilise at 12.0 per cent in April from a year earlier.
Chinese authorities released statistics on Friday which backed predictions that the economy is slowing. But the slowdown has been orderly. It is coming among lower inflation and included softening in fixed-asset investment, which increased 20.2 per cent in the January-April period from a year earlier, compared with an annual rise of 20.9 per cent in the first three months. Retail sales also underperformed with an annual growth of 15.2 per cent.
China's inflation was below the government's target for a third month, giving Premier
Consumer prices rose 3.4 per cent from a year earlier after a 3.6 per cent gain in March, the National Bureau of Statistics said. That compares with the government's 4 per cent annual goal.
Inflation under control may boost odds of additional monetary or fiscal stimulus after Mr Wen's campaign to rein in property and consumer prices slowed growth in the world's second-largest economy. The government may also have an easier path to loosen controls on prices of resources and utilities.
"Moderating inflation will leave the window open for further policy easing in coming months," Shen Jianguang, chief Asia economist for Mizuho Securities Asia in Hong Kong, said before the release.
"Authorities may gradually ease some restrictions on the property market and accelerate infrastructure projects and social housing construction to boost growth."
Shen, who previously worked for the International Monetary Fund and European Central Bank, said those easing measures may be accompanied by three more cuts in the banks' reserve- requirement ratio over the rest of 2012.
The producer-price index fell 0.7 per cent in April from a year earlier after dropping 0.3 per cent in March, the statistics bureau said, the first back-to-back decline since 2009.
China needs to pay attention to upside price risks, the People's Bank of China said in its first-quarter monetary policy report. "Price gains are staying on a moderating trend, but they are not yet stable," the central bank said.
The economy expanded 8.1 per cent in the first three months from a year earlier, the fifth quarterly deceleration and the slowest pace in almost three years, as Wen's crackdown on the property market cooled domestic demand and Europe's debt crisis crimped overseas sales.
The growth slowdown may have bottomed out, economists at banks including Bank of America Corp., Goldman Sachs Group Inc. and JPMorgan Chase & Co. have said, pointing to a pickup in industrial production and a surge in new loans in March.
Production may have increased 12.2 percent last month from a year earlier, after an 11.9 percent gain in March, according to the median estimate in a Bloomberg survey. Retail sales probably rose 15.1 percent, little changed from March, while fixed-asset investment excluding rural households jumped 20.5 percent in the first four months of the year, separate surveys showed.
The nation's exports and imports both rose less than estimated in April, a customs bureau report showed yesterday, adding pressure on the government to relax policies to sustain growth.
China has "certain room" to loosen monetary policy if inflationary pressures ease, Song Guoqing, an adviser to the central bank, said April 28. Inflation is expected to average 2.8 percent this year while the economy will expand 8.4 percent, Song said at a forum in Beijing.
The People's Bank of China has held off for more than two months in adding to the two reductions in banks' reserve requirement ratio after the latest cut in February.
Rising Wages
Mizuho's Shen said inflationary pressure in China will persist this year, citing drivers including rising wages and "loose" monetary policies adopted by developed nations. He estimated gains in consumer prices will average 3.8 percent.
The Ministry of Industry and Information Technology said April 25 that average wages across the nation may increase by about 20 percent this year.
Falling global commodity prices may help counter rising wage costs. China cut retail gasoline and diesel prices by as much as 3.5 percent this week, the first reduction since October, after international crude costs fell.
Bloomberg, Bloomberg


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Quick question - Is this one day event okay for beginners to go to? It seems like it is more geared towards professions or experienced coders. I am a beginner coder and looking to get involved but also dont want to hinder the process.
Thanks in advance for the help
Views: 464
Hello Zane,
I think it depends entirely on how "beginner" you are. If you've only been writing code for a few weeks, then you probably won't get much out of a coderetreat. If you've gotten to the point where you are writing unit tests or have tried Test-Driven Development before, then you will almost certainly get something out of attending a coderetreat (that's not to say that TDD experience is a requirement, but it is a good indicator as to whether or not you are ready for a coderetreat).
I think it also depends on what programming languages you are working with. I suspect a beginner in Ruby or Python would be able to participate much earlier than a beginner in Java or C#.
Instead of making a decision on whether or not to go, you could also decide at what level you want to participate. For example, I've facilitated a few coderetreats where a beginner signs up, but then decide they can learn more just by observing everyone else rather than trying to participate directly. In each case, the beginner methioned to me afterwards that they learned a lot and it was well worth their time.
I've also facilitated a few coderetreats where someone thought they were a beginner, but after a session of observing others, they decided to try participating in full. In that case, the beginner was impressed with how much they actually knew and could contribute to the group.


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Home Success Advice (Video) Steve Stoute – The King Of Cool
(Video) Steve Stoute – The King Of Cool
This video features Steve Stoute, the man behind Lady Gaga, Rihanna and a number of other top artists and high end companies. Steve Stoute's company "Translation" is a brand management firm that arranges strategic partnerships between Pop Culture icons (Jay-Z, Gwen Stefani, Lebron James, Justin Timberlake, etc.) and Fortune 500 companies.
In this episode, Steve Stoute discusses the concept of cool and also talks about creating successful collaborations between Artists and Brands. His client roster includes companies such as Samsung, State Farm, Mc Donald's, Target, Wrigley's, HP and P&G.


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The 'So What' hitmaker reveals that she was scared she had caused permanent damage following her onstage crash because she had no feeling in her legs.
Pop star Pink feared she would be "paralyzed" for life when a stage stunt went wrong at a concert in July. The singer was forced to cut short a gig in Nuremberg, Germany when a harness she used for her acrobatic act malfunctioned and sent her crashing into a metal barrier.
The "So What" hitmaker was taken to a nearby hospital, and admits she was scared she had caused permanent damage because she had no feeling in her legs. Pink tells the Associated Press, "It's hard to complain (about pain) when you're married to (motorcycle racer) Carey Hart. He basically crashes for a living."
"It hurt a lot and I was worried that I was going to be paralyzed and break my back, and I couldn't feel my legs, and then felt really embarrassed because an entire arena full of people were staring at me."
But the brave pop star, who is now pregnant with her first child, insists she didn't hesitate to return to the stage hours later, saying "I had a show the very next night, so if I wasn't paralyzed then I wasn't canceling because I don't cancel shows."


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Electronics In Stock
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GoPro Hero3: Silver Edition is lighter and smaller than the previous HD Hero camera, which is important when you are strapping it to helmet and kayaking through whitewater rapids or off a waterfall. The Hero3 weights in at a scant 2.6 ounces, making it 30 percent smaller and 25 percent lighter than the Hero2 model without compromising performance quality. The Silver Edition is capable of capturing 180p 30 fps and 720p 60 fps video plus 11MP photos at a rate of 10 photos per second.
Unlike its predecessor, the Hero3: Silver Edition comes with built in Wi-Fi compatible with both the GoPro App and the Wi-Fi Remote (sold separately from the Silver Edition). The Silver Edition is both wearable, gear mountable and waterproof up to 197 feet. The Silver Edition captures professional quality video and photos, with increased sharpness over the older models thanks to a redesigned, flat-lens waterproof housing. The Silver Edition has a distortion reducing, aspherical lens and offers ultra-wide, medium and narrow field-of-view choices. The Silver Edition will capture subtle, natural sounds, such as voice and music, and immersive sounds, like sports. It also comes with GoPro's wind-noise reduction technology so you can be heard loud and clear despite the wind. The Silver Edition includes a rechargeable Li-ion Battery, various mounts and buckles, and USB charging cable.
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We offer a unique design and amenities, including a large Fitness Center, convenient laundry facility and a heated indoor pool, this hotel's accommodations in Rogers, AR promise a fantastic travel experience.
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- Wired Internet Available in Rooms, Suites, Business Center and Meeting Convention Spaces.
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Business Services
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Housekeeping and Laundry Services
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Health and Fitness
Multiple Elliptical Machines, Treadmills and Stationary Bike. Free Weights, Weight Bench, Balance Ball, Yoga Mat with area for Yoga/Stretching. Two flat screen tvs.
On-site Fitness Center Available
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- Hours: 12:00 AM to 11:59 PM
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Also Enjoy
- More than 20 restaurants are within walking distance like, Chilis, Applebees, Logans Steakhouse. Johnny Carinos, On the Border, Famous Daves, Coltons Steakhouse, Abuelos Mexican Embassy, Copelands Cajun Cuisine, Red Robin, Bob Evans, Starbuks and more!


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For over 30 years the staff and management have assisted average citizens acquire lease rights on public lands. The purpose of which has over that time, remained the same.
That is to sell their lease rights to oil companies for the purpose of exploration and development. These companies often pay sizable up-front cash bonuses for attractive parcels. In addition as the royalty holder you retain royalty rights on all future oil and gas production.
Our company makes it easy, fun and affordable to participate in all of this. We maintain an exclusive database – developed over 30 years – that give us an indication of important trends. This includes production information, sales data along with what oil companies are doing what and where in today's oil patch.
All of this comes together in a comprehensive yet easy to understand format for our clients so they remain informed and updated as to what is transpiring in the various lease counties.
We are always available to assist in any way we can. Our trained and competent staff prides themselves on our dedication to 100% total customer satisfaction.
Wes State Lands - Updates Website
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Bulldog would love to be part of your special occasion. Please call our catering department at (305) 940-9655 or email us at email@example.com. We look forward to assisting you and planning a perfect menu for your event.
**Please note that all catering orders must be made at least 48 hours in advance.


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Cosmic Numbers, by James D Stein (Basic Books, £17.99)
For reasons that remain mysterious, fundamental properties of the universe can be expressed as numbers, or "constants", of which this author provides an enjoyable tour: the speed of light, absolute zero, the Hubble constant, the Planck constant, and so on. Noting astronomer Martin Rees's book on the same subject (Just Six Numbers), Stein surveys a wider range of them, adding asides from his own mathematicians' perspective ("Sometimes the method of computation is more important than the results of the computation"), paying civil respect to erroneous old theories ("easy to critique […] in retrospect"), and exhibiting a sly pleasure in mixing magisteria: "Slightly below absolute zero is considerably hotter than hell."
It is a story of man's lust for measurement (I liked the definition of the erg as "the amount of energy an ant needs to stamp one of its feet"), and also a persuasive explanation of why it is worth measuring such apparently arcane phenomena very exactly. Stein points out that a more accurate figure for the strength of gravity (surprisingly known "only to five significant digits") will enable us better to predict whether any asteroids are going to smash into the planet soon, which is something I'd like to know before booking a holiday.
Viruses: A Very Short Introduction, by Dorothy H Crawford (Oxford, £7.99)
Also for reasons that remain mysterious, there exist such things as viruses, "inert" parcels of genetic matter that "hijack" living cells and then cause all manner of chaos. When you're a specialist in microbes, you'll call the world a "virosphere", as this author does, introducing the various and impressive ways viruses do harm, mainly in humans. She concentrates particularly on the epidemiology of modern threats such as HIV, Sars and avian flus, noting historical success stories (vaccination against rabies, the eradication of smallpox) and sketching the emerging recognition of viruses' contribution to cancer.
What is really striking is the degree to which one is tempted to attribute volition and ratiocination to these ancient enemies of humankind: "these viruses appear to have honed their skills […] to reach an amazing degree of sophistication"; viruses "target" certain segments of a population, and are portrayed as "manipulating" and "outwitting immune defences". If, as some theories have it, viruses came from space, then the aliens are already here, and they mean us harm.
The Real Mad Men, by Andrew Cracknell (Quercus, £14.99)
This handsome volume offers a celebratory oral history of the Manhattan advertising world in the 1950s and 1960s, with chapter epigraphs from Don Draper, Peggy Olson and Roger Sterling. Here are the real-life memoirists David Ogilvy and Jerry Della Femina, and other execs recounting sordid details to the ad-man author, who writes with commendable zip (though to call Jewish and Italian ad-men "ethnics", while celebrating their increasing success in this era, is a little awkward).
Cracknell's discussions of ad campaigns ("Think Small" and "Lemon" for Volkswagen; Avis vs Hertz) are enjoyable, and credit for some of them is contested to this day: here are two people still locked in "a high-energy spat over who did what on all sorts of ads they worked on, some of which were created 50 years ago". It seems it really was a golden age of drinking, fighting and fornicating, with the occasional composing of killer slogans. My favourite: "If it isn't Wolfschmidt's Vodka, it isn't breakfast." That was never used in a real ad, for reasons that remain mysterious.


text: Franklin boasts historical landmarks dating back to the early days of the United States. The town is home to the first public library in the United States, which holds books donated by Benjamin Franklin. A one-room red brick schoolhouse from the 18th century is still in use today. Dean College is located near the town center, while Franklin State Forest provides recreation opportunities.Hide


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Keira Knightley Would Like You To Know That "Love Actually" Is A Cinematic Legend
"It's obviously the greatest movie ever made."
I adore "Love Actually," and I will never understand why it's attracted such a legion of haters, but I think Keira Knightley is going a bit too far in saying it's best movie ever. In an interview with MSNBC's "Morning Joe," interviewers mentioned film critics' long-lasting conundrum over whether the rom com was a blessing or a curse to Hollywood, and Knightley insisted "Love Actually" should be shown on cable more often than it already is. I'm really hoping she was joking. Keira, there are so many quality movies out there that don't involve Hugh Grant dancing and creepy doorstep love confessions! Maybe her new film "Begin Again" will even be a contender, if only for scenes of her with wonderful Mark Ruffalo and all that summery footage of New York City. [TIME]


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Sir Alex Ferguson's attempt to show the Football Association he genuinely regrets accusing Alan Wiley of not being fit enough to referee high-profile matches will not prevent Manchester United's manager questioning the physical condition of the Premier League's match officials when he attends a disciplinary hearing in London tomorrow.
Ferguson is facing a charge of improper conduct after his criticisms of Wiley's performance in United's 2-2 draw against Sunderland on 3 October, when he accused him of being "not fit" and claimed that the 49-year-old was deliberately taking a 30-second breather when he was booking players because "he needed a rest".
Allan Leighton, the national secretary of Prospect, the union which represents referees, has described as "half-hearted" the carefully worded apology Ferguson submitted through the club's lawyers and recommended that the FA imposes a touchline ban if it wants to demonstrate that it is serious about its Respect campaign for match officials.
Ferguson, who will be represented at the Wembley hearing by a legal team involving the FA's former compliance officer Graham Bean, is open-minded about what kind of punishment he will receive but hopes to receive only a fine and a suspended touchline ban.
He will try to persuade the independent four-man panel that his comments had not been meant as personal against Wiley and he will also argue that there are authentic reasons to be concerned about the physical condition of the Premier League's referees. Ferguson wants more stringent fitness checks to be introduced and his representatives will try to make a case that he had legitimate reasons to believe match officials should be fitter.
His complaints are unlikely to go down well at the Professional Game Match Officials Limited, particularly given the statistical evidence which revealed Wiley had run further than all but four of Ferguson's own players. The guidelines state that all referees have an individually tailored fitness regime and a weekly training programme which requires them to be able to run 40 metres inside 6.2 seconds as well as passing various long-distance tests. The average Premier League referee now covers around 11km in every match.
Ferguson had complained English match officials are well behind their counterparts in mainland Europe. "It's an indictment of our game that we see referees from abroad who are fit as butchers' dogs," he said. "We've got some good referees in our country who are fit. But he [Wiley] wasn't fit. He was actually walking up the pitch after the [final] goal needing a rest. He was taking 30 seconds to book a player. I think he's taking a rest, writing down the names on his card and taking 30 seconds for a booking. It's ridiculous."
Ferguson has a long history of criticising referees and this is the fifth occasion in six years that he has appeared before an FA disciplinary hearing. Wiley was reportedly so distressed about the remarks that he briefly considered whether he wanted to continue in football.
The FA wrote to every Premier League manager at the start of this season asking them to show, collectively, a greater respect to match officials but Ferguson has been heavily critical of two more recently, questioning whether Andre Marriner was too inexperienced to take charge of United's 2-0 defeat at Liverpool and also verbally attacking Martin Atkinson for his performance after they lost 1-0 at Chelsea on Sunday.


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Edinburgh University Taekwondo was founded in 2006, and since then became a full member club within two years and has been growing rapidly, with many new members both new to the sport and more experienced.
Taekwondo is a Korean martial art which focuses strongly on high-speed kicking techniques, blocking and hand techniques. The literal translation is "the way of the hand and the foot". It has been an event at the Olympics since 2000, and is one of the most popular martial arts in the world.
Two styles of taekwondo are offered at our classes – World Taekwondo Federation (WTF), and International Taekwon-Do Federation (ITF) styles. The WTF style is the style seen in the Olympics, and puts more emphasis on the sport aspect of the martial art. It is characterised by fast kicking and full-contact sparring. The ITF style is a more traditional form of the martial art, and places emphasis on practical self-defence. ITF sparring is generally of a semi-contact nature. We recommend that you try both styles before deciding which is best suited to you.
Both styles offer training towards taking part in competitions and progression through the belts, as well as improving fitness, overall strength, flexibility, balance, focus and mental discipline.
The purpose of the Taekwondo Clubis to provide the opportunity to all Edinburgh University students to train and appreciate the various aspects that Taekwondo embodies, both as a martial art and as a world-renowned sport.


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Puppet Government
The Puppet Government, or the Second Philippine Republic, is a Japanese-imperial-sponsored government established during the Japanese occupation and World War II in the Philippines. This government sought to legitimize Japanese occupation in the country and promised independence for the Filipino people but Imperial government failed to commit to this pledge.
Established in October 14, 1943, Jose P. Laurel was inaugurated as the first President of the Second Philippine Republic after leaving his post as the Chief Justice of the Supreme Court of the Philippines. The Japanese's choice for president was based on Laurel's open criticisms against the U.S administration in the Philippines and his degree from Tokyo International University. Benigno Aquino Sr. and Ramon Avancena were also elected as vice-presidents, and Manuel Roxas and General Jorge Vargas were appointed as the cabinet member and chair of the Executive Commission, respectively.
The first act of the puppet regime was to sign a military alliance with Japan. The second act appealed for the sympathy of the United States but was denied by the said country. US President Franklin Roosevelt refused to recognized the puppet government.
The Puppet Government was established in the pursuit of creating the Greater East Asia Co-Prosperity Sphere under the chairmanship of the Japanese Imperial government. Manuel Roxas and Jose Laurel wrote and signed the Philippine puppet constitution which was an act of rebellion against the U.S. and a testament of allegiance to Japan.
Those who pledged their loyalty to Japan were showered with supply of the best food, luxuries and finest accommodations while the Filipino who did not pledged suffered under the harsh Japanese rule. <ref name="test1"> A Toast to Edsa. (accessed May 21, 2008) </ref> The sons of Laurel were sent to Japan to study. Consequently, the Puppet Government gained little popularity amongst the Filipino people.
The Americans through General Douglas MacArthur led a war against the Japanese in the Philippines. Manila was liberated in March 4, 1945 and on March 22 of the same year President Laurel and the Second Republic officials departed for Japan.
<references />
- Roosevelt's Statement. http://www.presidency.ucsb.edu/ws/index.php?pid=16330 (accessed May 20, 2008)
Original content from WikiPilipinas. under GNU Free Documentation License. See full disclaimer.


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Meschi, Elena and Vivarelli, Marco (2009) Trade and income inequality in developing countries. World Development, 37 (2). pp. 287-302. ISSN 0305-750X. DOI UNSPECIFIED
PDF (Meshi2009Trade287.pdf)
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We use a dynamic specification to estimate the impact of trade on within-country income inequality in a sample of 65 developing countries (DCs) over the 1980-1999 period. Our results suggest that trade with high income countries worsen income distribution in DCs, both through imports and exports. These findings provide support to the hypothesis that technological differentials and the skill biased nature of new technologies may be important factors in shaping the distributive effects of trade. Moreover, we observe that the previous results only hold for middle income countries (MICs); we interpret this evidence by considering the greater potential for technological upgrading in MICs.
|Item Type:
|Controlled Keywords:
|Quantitative analysis; globalization; within-country income distribution; technology transfer; developing , countries; LSDVC estimator.
|Depositing User:
|IOE Repository Editor (1)
|Date Deposited:
|18 May 2010 06:39
|Last Modified:
|29 Jan 2015 08:38


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Fishman: Finding the groove after vacation
There's a problem with vacations. They end too soon. And we're greedy. We want more.
Arts briefs
Is there an artist in you just dying to get out?
Morris and Eco Productions Inc. to launch bilingual magazine
AUGUSTA -- Morris Communications announced it has signed an agreement with Eco Productions Inc., of St. Augustine, Fla., to jointly publish a Spanish-English magazine.
No-nonsense Byrne sticks to the issues in governor's race
Former Cobb chairman must overcome gruff image, shortage of name recognition in GOP bid.
Fort Stewart hopes improvements heal school
Renovations come after student health complaints but delay school start on post.
Hilton Head calls for tax to help out The Heritage
HILTON HEAD ISLAND -- The one-year rescue pledge would help fill void left by WorldCom's ouster as golf tournament's title sponsor.
Schrenko hoping to offer different choice for governor
Schools chief running low-key, low-budget in GOP race.
County budget OK'd
It was their shortest meeting in months -- too short, some would say.
The beauty in nooks and crannies
Photographer Christopher Welshon believes that beauty manifests itself in many guises.
New middle school opens Monday in Effingham
Workers race to put finishing touches on the new $8 million Ebenezer Middle School.
Students taught responsibility by cleaning their school bathrooms
That's when he found his calling as "the Bathroom Man." His mission: to get students to take on bathroom cleaning duty, learn responsibility and make school bathrooms a little less frightening.
Retired Marine general, Korean War POW dies
John McLaughlin fought in three wars before retiring in Savannah.
Location, location, location
Out on Cumberland Island's beach you're alone. Really alone.
Like night and day
School year opens with new middle school building, new faces and new administrative strategies.
Regents back more non-tenured lecturers
ATLANTA -- Following a national trend, the state Board of Regents agreed Wednesday to permit universities to place more non-tenured lecturers in undergraduate teaching roles.
Not enough sugar and too much spice
Teen girls often gossip, bully and back-stab their way up the adolescent social ladder.
Traffic on River Street permanently one-way
City Council approved the change at its Thursday meeting.
Perdue politicking for GOP nod
Ex-senator, candidate for governor wants to return government "of the people."
Police investigating the shooting of a Savannah teen
Police are investigating the Thursday night shooting of a 17-year-old Savannah man.
Second annual Music Meltdown entertains more than 100
The performers, mostly teen and 20-something men, used an assortment of instruments ranging from acoustic and electric guitar to tambourine and saxophone. The melodies varied from metal rock, to pop and instrumental.
Pooler, Port Wentworth edge toward sewage decisions
While fast-growing Pooler moves forward with building a larger plant, Port Wentworth considers tying into planned Savannah facility.
Chambliss leads GOP money race
U.S. Senate candidate increasing his lead over the competition.
Tybee council approves guidelines for selling small parcels
By a 4-2 vote, council approved a new ordinance that lays out the process by which the city can sell off small, unbuildable lots to adjacent property owners.
Motorist critically injured collision with ambulance
A Savannah man was in critical condition Friday after the car he was driving collided with a MedStar ambulance.
Weddings, Engagements, Anniversaries
Walker late to reveal profitable connections, state lawyer says
DOUGLASVILLE, Ga. -- Senate Majority Leader Charles Walker has shown a pattern of revealing his business dealings and connections to non-profit groups only after they're uncovered.
Obituaries for August 10, 2002
Obituaries for August 11, 2002
Barton: It's back to school Monday for snoozing students, late buses
Remember to set your alarm clocks, gentle parents. And let the groans begin.
Editorial: School choice: Golson
THERE'S A lot happening in the Savannah-Chatham County public schools.
Editorial: Whether, when, and how to go to war with Iraq bears reflection and discussion
First, there is strong consensus among experts that Saddam is continuing his quest for weapons of mass destruction, although there is somewhat less agreement that he will eventually use them against America, given the opportunity.
Editorial: Two super choices
For the past eight years Georgia's superintendent of schools has been a lightning rod for controversy.
Oglesby inches further ahead of Strickland in Late Models
The crucial final installment of the Red, White & Blue Series double features loomed a week away. So Bobby Oglesby wanted to build his NASCAR Late Model points lead over Kent Strickland as much as possible Friday night.
Guidera: Maybe, just maybe, there won't be a strike
But these days I could be getting a little overly wide-eyed. Because I'm actually starting to think there might not be a baseball strike this season.
HR beats Savannah in New Jersey
LAKEWOOD, N.J. -- Second baseman Andres Silvera ended a 1-of-18 stretch with a home run in the seventh inning Saturday to lift Lakewood to a 2-1 South Atlantic League win against Savannah before a crowd of 8,253 at FirstEnergy Park.
Braves beat Astros in thrilling fashion
HOUSTON -- I13th-inning heroics lift Atlanta to 6-5 win in Houston.
Watkins Glen win would bolster Rudd's championship hopes
WATKINS GLEN, N.Y. -- Ricky Rudd, driver of the No. 28 Havoline Ford, still has aspirations of winning a Winston Cup Championship.
Atlanta falls to Houston in quiet fashion
Despite the loss, Braves still hold an 18-game lead in the National League East.
Sauers tied for sixth in Buy.com Tour event
LONG GROVE, Ill. -- Savannah's Gene Sauers is tied for sixth place after the second round of the Buy.com Tour's LaSalle Bank Open.
Burke: Still Hot Weather, But Hunting Seasons Near
Hot weather or not, hunting seasons is just around the corner.
Rudd wins pole at Watkins Glen
WATKINS GLEN, N.Y. -- Ricky Rudd didn't let the distraction of his impending departure from his team slow him down Friday.
Braves notebook: Shake up in the scouting department
Barry Bonds hits 600th homer
SAN FRANCISCO -- Barry Bonds hit his 600th homer Friday night, capping an amazing two-year power surge by becoming the fourth major leaguer to reach the lofty mark -- and the first in 31 years.
Helms beat up after Friday's win in Houston
HOUSTON -- Wes Helms said he felt like he like he went to a baseball game and a football game broke out.
Falcons cage Jaguars
ATLANTA -- Long-suffering fans who've endured 15 losing seasons in the last 18 years watched the Falcons begin a new era with a 23-13 preseason win over the Jacksonville Jaguars.
Injuries mounting for Atlanta
FLOWERY BRANCH -- Coach Dan Reeves has no plans to put the Atlanta Falcons through a hard week of practice as they prepare for their second preseason game.
Falcons notebook: Backup QB Johnson shines in sharp second half
GSU's Davis trying to regain last season's form
The Folkston native, who had a propensity for big plays, watched his freshman season hobble almost to a halt after a severe right knee sprain.
Smith leader of the UGA backs
It's as clear as anything in this preseason that no one on the Georgia football team has a chance to unseat a healthy Musa Smith.
Miami No. 1 in AP preseason poll
Little has changed for the Miami Hurricanes since winning the national championship with a perfect record at the Rose Bowl earlier this year.
Tech's Hollings has plenty of competition at RB
ATLANTA -- Georgia Tech junior Tony Hollings made a nice move last spring in switching from safety to running back.
Hawks' Glover raps with Savannah youth at Jonesville Baptist Church
The youth of Savannah received another visitor from the world of professional sports Saturday night.
Gnats open Lakewood series with win
LAKEWOOD, N.J. -- Former South Carolina standout Drew Meyer had three hits and drove in a run to lead Savannah to a 3-2 South Atlantic League win Friday against Lakewood.
UGA QBs: Competition not controversy
ATHENS -- It's early evening, nearly 22 days to the minute before Georgia opens its 2002 football season, and Mark Richt is wondering the same thing you are.
NASCAR notebook: Stewart puts outburst behind with fast lap
Leggett, Burnsed continue impressive runs at OSP
Doc Leggett and Jim Manka should consider playing the Georgia lottery.
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Ramsay principle
The Ramsay principle is the shorthand name given to the decision of the House of Lords in two important cases in the field of UK tax, reported in 1982:
- Ramsay v. IRC, the full name of which is W. T. Ramsay Ltd. v. Inland Revenue Commissioners, Eilbeck (Inspector of Taxes) v. Rawling, and its citation is [1982] A.C. 300.
- IRC v. Burmah Oil Co. Ltd., the full name of which is Inland Revenue Commissioners v. Burmah Oil Co. Ltd., and its citation is [1982] S.T.C. 30, H.L.(Sc.)
In summary, companies that had made substantial capital gains had entered into complex and self-cancelling series of transactions that had generated artificial capital losses, for the purpose of avoiding capital gains tax. The House of Lords decided that where a transaction has pre-arranged artificial steps that serve no commercial purpose other than to save tax, the proper approach is to tax the effect of the transaction as a whole.[1]
The decision is not limited to capital gains tax, but applies to all forms of direct taxation, and is an important restraint on the ability of taxpayers to engage in creative tax planning.
Facts (Ramsay v. IRC)[edit]
The important facts are set out in the following quotation from Lord Wilberforce:.
- [This] is an appeal by W. T. Ramsay Ltd., a farming company. In its accounting period ending May 31, 1973, it made a "chargeable gain" for the purposes of corporation tax by a sale-leaseback transaction. This gain it desired to counteract, so as to avoid the tax, by establishing an allowable loss. The method chosen was to purchase from a company specialising in such matters a ready-made scheme. The general nature of this was to create out of a neutral situation two assets one of which would decrease in value for the benefit of the other. The decreasing asset would be sold, so as to create the desired loss; the increasing asset would be sold, yielding a gain that it was hoped would be exempt from tax.
The two assets in question were loans of equal amounts, which had an unusual condition: Ramsay Ltd. was entitled, once, to reduce the rate of interest on one loan, provided that the rate of interest on the other loan increased by the same amount. Ramsay Ltd. exercised this right, such that one loan became worth far more than its original value, and the other far less. The loan that had gained in value was disposed of in such a way that it was intended to be exempt from tax as "debt" (sec. 251 [2] TCGA 1992: Where a person incurs a debt to another, whether in sterling or in some other currency, no chargeable gain shall accrue to that [that is the original] creditor or his personal representative or legatee on a disposal of the debt, except in the case of the debt on a security [as defined in section 132]), while the loan that had fallen in value was disposed of in such a way that it was intended to be a deductible capital loss. Funding for the entire transaction was provided by a finance house, on terms such that the money would inevitably pass round in a circle, and back into their hands again, within a few days, with interest.
The House of Lords rejected the idea that there was any exemption from tax under the "debt on a security" rule. However that was not the basis of their decision, which was a more far-reaching principle.
Facts (Eilbeck v. Rawling)[edit]
Some types of interests in trusts are "assets" of a kind that can be bought, sold, and be subjected to CGT. Other types of interests in trusts are not "assets" in that sense. The taxpayer in this case, Mr Rawling, tried to take advantage of that fact by entering into the following transactions:
- On day 1, two trusts were created:
- a Gibraltar trust, of the kind in which a reversionary interest would be a taxable asset.
- a Jersey trust, of the kind in which Mr Rawling's interest would not be a taxable asset.
- It was a term of the Gibraltar trust that its trustees could make appointments of money to the Jersey trust.
- On day 2, Mr Rawling bought a reversionary interest in the Gibraltar trust.
- On day 3, The trustees of the Gibraltar trust appointed £315,000 to the Jersey trust.
- On day 4, Mr Rawling sold his reversionary interest in the Gibraltar trust at its new market value, making a substantial loss since the asset was worth far less than it had been on day 2.
- It was not a coincidence that the loss was a little under £315,000: just enough to cover an unrelated taxable capital gain Mr Rawling had made in the same year.
The court rejected the idea that there had in fact been any loss. Lord Russell said, quite bluntly:
- I wholly fail to comprehend the contention that the taxpayer sustained a loss.
His reasoning was that Mr Rawling had an interest in the Jersey trust, anyway, so there simply had not been any loss on the sale of the interest in the Gibraltar trust. Also, all of the money needed to fund these trusts, and to purchase the interests in them, had been provided by a company called Thun Ltd., on terms that it would all be paid back to Thun Ltd. after the transactions had been completed. (Indeed, the court doubted that there had ever been any real money, at all: the whole matter appears to have been dealt with by means of paper accounting entries.)
However (as with the Ramsay case above) the core of the decision was not related to the judges' disagreement with the detail of the taxpayer's case. Instead it was based on a more fundamental principle (The Ramsay Principle) explained under "Judgements" below.
Note that the facts have been simplified for ease of explanation, and that the actual transaction was rather more complex.
'Particles' in a gas chamber[edit]
Lord Wilberforce described the transactions in the Ramsay and Rawling cases with this colourful (if not necessarily scientifically accurate) simile:
- In each case two assets appear, like "particles" in a gas chamber with opposite charges, one of which is used to create the loss, the other of which gives rise to an equivalent gain that prevents the taxpayer from supporting any real loss and whose gain is intended not to be taxable. Like the particles, these assets have a very short life. Having served their purpose they cancel each other out and disappear. At the end of the series of operations, the taxpayer's financial position is precisely as it was at the beginning, except that he has paid a fee, and certain expenses, to the promoter of the scheme.
Facts (IRC v. Burmah Oil)[edit]
In this case, the Burmah Oil group had suffered a genuine loss on the sale of an investment. However, the loss was not of the right kind to be deductible for tax purposes. Accordingly, the company's accountants and lawyers formulated a plan to "crystalise" that loss into a deductible form. They did this by entering into a series of (perfectly genuine) inter-group transactions, the overall effect of which was that the loss already incurred became a deductible capital loss on the liquidation of one of the subsidiaries in the group. These transactions were made using Burmah Oil's own money, and were therefore quite different from the pre-arranged, marketed "schemes" using borrowed money in the Ramsay and Eilbeck cases.
The judges were quite clear that they would have found in favour of Burmah Oil, and against the IRC, had it not been for the decision in the Ramsay case, some months before.
In the Ramsay case, Lord Wilberforce distinguished three ingredients of the schemes involved
- 1 that there was a ' clear and stated intention that once started each scheme shall proceed through the various steps to the end' whether admitted or implied
- 2 that the taxpayer does not need to use his own funds, typically provided by a financial group with only the customer's security, and that by the end of the scheme his financial position is unchanged (other than in providing fees and expenses to the scheme's promoter), so that 'in some cases one may doubt whether, in any real sense, any money existed at all'
and the key ingredient
- 3 that 'it is candidly, if inevitably, admitted that the whole and only purpose of each scheme was the avoidance of tax'.[1]
Wilberforce summed up the emerging principle
- It is the task of the court to ascertain the legal nature of any transaction to which it is sought to attach a tax or a tax consequence and if that emerges from a series or combination of transactions intended to operate as such, it is the series or combination which may be regarded.
and ruled that in the particular facts of Ramsay
- [It would be] a faulty analysis, to pick out, and stop at, the one step in the combination which produced the loss, that being entirely dependent upon, and merely, a reflection of the gain. The true view, regarding the scheme as a whole, is to find that there was neither gain nor loss, and so I conclude.[1]
The core of the Ramsay Principle is to be found in the Burmah Oil case in this remark by Lord Diplock:
- It would be disingenuous to suggest, and dangerous on the part of those who advise on elaborate tax-avoidance schemes to assume, that Ramsay's case did not mark a significant change in the approach adopted by this House in its judicial role to a pre-ordained series of transaction (whether or not they include the achievement of a legitimate commercial end) into which there are inserted steps that have no commercial purpose apart from the avoidance of a liability to tax that, in the absence of those particular steps, would have been payable.
More recent cases have tended to move away from a narrow focus on disregarding circular transactions and inserted pre-ordained steps with no commercial purpose. A number of tax counsel have cited the following comments by Ribeiro PJ in Collector of Stamp Revenue v Arrowtown Assets Ltd [2003] HKCFA 46, para 35 with approval as an authoritative statement of the prevailing view of the judiciary on the application of legislation in tax avoidance cases:
- The driving principle in the Ramsay line of cases continues to involve a general rule of statutory construction and an unblinkered approach to the analysis of the facts. The ultimate question is whether the relevant statutory provisions, construed purposively, were intended to apply to the transaction, viewed realistically
See also[edit]
External links[edit]
"Ramsay principle – Ramsay, W T Ramsay Ltd v IRC, Westminster doctrine, IRC v Duke of Westminster". law.jrank.org. Retrieved 31 March 2011.
- ^ a b c Tutt, Nigel (1985). Tax Raiders: The Rossminster Affair. London: Financial Training Publications. pp. 267–274. ISBN 0-906322-76-6.


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Yep, A Herd of Goats Strolled into a Train Station in Spain
It's no secret that goats are pretty cool.
But who knew they had a thing for walking on train tracks?
… More »
It's no secret that goats are pretty cool.
But who knew they had a thing for walking on train tracks?
… More »
The city of Santiago likes sports and it doesn't care who knows.
On Wednesday, Chile officially eliminated Spain's running towards becoming the FIFA World Cup's next top team with a 2-0 win.
When Charles Aránguiz scored the second goal for Chile, the people of Santiago went wild.
… More »
Lamar Odom has said adios to Spain.
The former NBA star's comeback on the court was short-lived after an ongoing back injury has sidelined him.
… More »
Lamar Odom just can't let go.
That, or he just likes the look of man jewelry.
Khloe Kardashian's future ex-husband was spotted at LAX Thursday sporting his wedding ring two months after his wife of four years filed for divorce.
The elated-looking former Lakers star wasn't trying to hide… More »
Chris Hemsworth's superhero skills come in handy on the big on screen, but in real life he needed emergency services to come to his rescue.
The Thor star and his wife, along with eight other passengers, were stranded in their boat off the coast of the Canary Islands over the weekend, according to… More »
Miley Cyrus was living it up in Spain on Thursday night, and the pop princess was even caught gold-handed, as photographers snapped pictures of the 17-year-old starlet holding a beer.
Spain's legal drinking age is 18, but as in many parts of Europe, the law is quite loosely enforced. So, while Miley's Madrid club… More »
• Larry King has announced that he will end his show, Larry King Live, this fall. The show has been on the air for 25 years. (PopEater)
• Spanish soccer hunk Cristiano Ronaldo showed off his toned gams while on the field earlier this week. Maybe he figures he can convert more Americans to… More »
Tom Cruise is back on the promotional trail, and you know what that means: It's time for another round of head-scratching behavior from the Losin' It star.
Cruise was stumping for his latest cinematic epic Knight and Day in Seville, Spain, with his co-star Cameron Diaz on Wednesday, and decided to get the crowd… More »
Teen Queen Selena Gomez made an appearance yesterday on Spanish TV show El Hormiguero which is either filmed in space or Madrid, we aren't quite sure.
Selena looked all science-y and stuff when she donned a lab coat, rode a wooden scooter and talked to a purple space blob (we're going to chalk up… More »
The Jonas Brothers had a pleasant surprise at their latest stop in Madrid, Spain.
Kevin, Joe, and Nick were singing their hit single "S.O.S" at the end of the show when a super-pumped fan decided to rush the stage!
And, BOY, was he excited!
Fast forward to 1:55 to see the LOL-worthy… More »
Has Ashley Tisdale been taking lessons from her former High School Musical co-star Vanessa Hudgens?
The Tiz is currently in Spain, promoting her new album Guilty Pleasure, and as part of her promotional duties she appeared on Spanish TV program El Hormiguero (translation: The Hormiguero).
During her segment, Tisdale performed a steamy dance… More »
¡Hola, Ashley Tisdale!
High School Musical alum Tisdale popped up at La Letras Hotel in Madrid on Thursday to present her new album, Guilty Pleasure.
Aside from her burgeoning musical career, Tisdale also has a new comedy, Aliens in the Attic, hitting the big screens on July 31, co-starring Andy Richter, Robert Hoffman… More »


text: Interesting ... when your MacBook is shipped, a piece of plastic is actually blocking a vent. Be sure to check this out: MacBook's Vent Blocked Be sure to check out the photos. If you have a MacBook, you'll want to check if the plastic is blocking the vent. An interesting discovery.


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Top 25 Wild Bird Photographs of the Week #29
African green pigeons only really come to the ground when they drink water and congregate at salt mud pans in forest clearings. They are captured in their thousands at these vulnerable locations to supply the bushmeat trade. See: https://newswatch.nationalgeographic.com/2012/08/29/will-the-congos-green-pigeons-go-the-way-of-the-passenger-pigeon/ Photographed here in Odzala-Kokoua National Park (Congo).
Dana Allen


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Best Of :: People & Places
If beachside routes are as popular and predictable as Top 40 radio, this tour is like NPR: You'll learn something if you pay attention. Witness the confused chicken clucking around NE Second Avenue. This is her home, and she is not afraid of you. Head west and wonder, What's that noise? It sounds like a party, but it's actually a church. Peek inside: They are dancing. Down the street, a hair weave has been tossed to the sidewalk, ominously. Wonder how it got there. Loop back south and spot that new Obama mural. Mr. President is smiling again. Breathe in the smoky barbecue smell; see the ghostly foreclosed buildings; marvel at the gang graffiti. Roll by Churchill's and end with a beer. Then make a toast: To Haiti. To one hard year.
What you need is a weekend away. But alas, Miamians, you're already living in the very place most Floridians vacation. So where to go? If you answered the Keys, go ahead and line up in bumper-to-bumper traffic on the Seven Mile Bridge. (Besides, it's the same pastel motels, just more coconuts.) Instead, steer the car north like you're heading for Disney, but bypass all the mouse-touting exits and that spooky biblical theme park called the Holy Land Experience. Deep in the Ocala National Forest is Wekiwa Springs State Park, where you can spend the weekend camping in a backcountry Florida Shangri-la. Here's the scene: Moss-draped oaks canopy the park's springs, and pristine blue water nestles in natural rock that, thanks to the Floridan Aquifer, is always a cool 72 degrees. As for lodging, choose one of the campsites in the inner circle for the best shade, and kayak the Wekiwa Lagoon for some guaranteed gator watching. Camping costs $24 a night, or for primitive camping, $5 a person. Otherwise, park admission is $6 per car. For noncampers, the park is open 8 a.m. to sunset.
Most TV news talking heads, even the dudes, look and act like failed beauty queens trying to make a second career for themselves. But WSVN's Belkys Nerey bucks that trend. The 42-year-old Emmy winner is a solid, straight-up anchorwoman — telegenic but still intelligent. Born in Havana, Nerey spent her childhood in Long Island before tripping down I-95 to South Florida. Once here, she studied radio and television at Miami Dade College and Florida International University, got her start in cable news, and earned a spot in the Magic City's media parade as cohost of local gossip institution Deco Drive. Today, Nerey is cruising through the post-Deco phase of her career, holding down WSVN's nightly newscasts alongside Craig Stevens. And whether it's a celebrity sex scandal or a political con job, she always delivers the day's stories with appropriate seriousness. Case in point: Unlike some of the lesser faces populating the public airwaves, Nerey never falls prey to that annoying TV anchor tic of flashing a vacant smile after reporting Miami's latest murder.
Without warning, a woman brandishes two bushels of tree limbs and proceeds to beat our friend Lourdes from toes to shoulders. Between sweeps of the soggy branches, the woman dumps bucket after bucket of cold water on our friend. No, she's not swabbing the deck of a fishing boat. She's helping Lourdes relax with platza, one of the traditional spa treatments available at the Russian and Turkish Baths on Miami Beach. The baths attract Miami's ultimate relaxation-seekers, those who are willing to abandon modesty, vanity, and sometimes plain old comfort if it gets them closer to bliss. Women and men in barely-there bathing suits, heads wrapped in towel turbans, endure the volcanic heat of the schvitz as if sweating were a way to absolve past sins. A skeletal older man stands under a heavy waterfall that pounds on his bony shoulders. He raises his head, eyes closed, waiting to be beamed up to the mother ship. Make your way through the rest of the grotto-like rooms and hear the cries of those jumping into the icy polar tank; catch glimpses of red flesh, pores screaming from the extreme heat, and shield your eyes from the meaty woman having the mud hosed off. What are you looking at, you perv? Pass the wet branches and wait your turn. A day pass costs $30, and the baths are open from noon until midnight.
Michael Putney doesn't tweet. He doesn't pop up when we search his name on Facebook. And as far as we can tell, he doesn't blog. No, sir, Michael Putney is decidedly old school, and in this Internet age, we couldn't appreciate him more. While most TV reporters seem to come and go, Putney has been covering local government and politics in South Florida for nearly 30 years. Add to his incisive reporting a hosting gig on This Week in South Florida, one of the few must-watch local programs, and his occasional columns in the Miami Herald (which often upstage the newspaper's regular gaggle of columnists). There are few voices on local airwaves we trust as much as Putney and who report on politics with such authority.
Miami is a town where clubs spit out adjectives like exclusive, VIP, and upscale like an overchewed piece of Juicy Fruit. But WALL Lounge is actually one of the few places that can blow hard without bursting its own bubble. Jessica Alba, Gabrielle Union, the All American Rejects, Erykah Badu, Swizz Beatz, Jamie Foxx, Jason Binn, and Selita Ebanks are just a few of the celebrities who have walked through WALL's infamous doors. Other guest sightings have been rumored, but unless the press snaps a picture, they're almost impossible to confirm. In fact, it's nearly impossible to get a photo of the place, period. WALL's success lies in its size; it is so boutique it does not merit a VIP section — the lounge itself is the VIP. So if you're lucky enough to get in, keep the video phone ready — you might catch a TMZ-worthy moment.


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Bring your favorite wild game dish plus a "normal" main or side dish for a fun evening at Chili Crossroads Bible Church. There will be doorprizes and giftcards awarded from local hunting and sports stores. Do you love hot and spicy foods? Then enter the Atomic Wing Challenge. The winner gets bragging rights and a T-shirt. There will be milder wings for non-competitors. Bring your friends, family, hunters, sportsmen, and neighbors.
Where: Chili Crossroads Bible Church
When: January 30, 2011
What Time: 6 pm
Located at the the intersection of County Road 10 and County Road 236. From Walmart in Coshocton, go one mile east on State Route 36. Turn left on County Road 10. Go eight miles and the church is on the left.