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- WiFi
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- Rural
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Located just 984 feet from Vannes station, in the city center, Hotel de France offers comfortable guestrooms and a buffet breakfast. All the en suite guestrooms come with a flat-screen TV, high quality duvets and free Wi-Fi access. They are decorated in a contemporary style with warm wooden furnishings. Hotel facilities include a elevator and a private car park. A buffet breakfast is available in the dining area or in the comfort of your room. The historical city of Vannes, once a commercial port, is now a sailing port with many pedestrian streets and beautiful gardens. Private parking with CCTV 24 hours a day is available upon reservation and for a supplement.
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Why face and neck liposuction for men?
Fat deposits in the jowls and beneath the chin and neck produces an older, less healthy and vigorous appearance. A strong, well-defined jawline is important for a fit, youthful, masculine appearance. Liposuction is often an important part of obtaining this look.
Which men are good candidates for face and neck liposuction?
Men with good skin elasticity can achieve dramatic results with liposuction alone. For those with moderate skin sagging, combining ThermiTight treatment, which tightens the skin, with liposuction can achieve dramatic results. The ThermiTight probe uses the same tiny openings as the micro cannula liposuction instruments, preventing visible scarring. This makes combining these procedures ideal for many men who need to improve sagging face and neck skin, but wish to avoid the scars associated with many other procedures.
Why is ThermiTight andThermiLift such an important advancement?
ThermiRF is the most exciting and revolutionary of these complementary skin tightening procedures. ThermiRF's unique radio frequency energy is paired with an ultramodern thermal imaging camera, allowing for the most effective, precise and safest skin tightening results available. ThermiRF can be used alone or in combination with liposuction and in many cases can replace conventional procedures such as face lift and tummy tuck
Besides Liposuction what other procedures can improve a man's lower face and neck?
Augmenting the chin and jaw using your own transferred fat, synthetic injectables such as Artefill or implants can often complement face and neck liposuction in creating that strong, masculine look. If there are dental occlusion problems patients should have dental consultation and decide whether or not to pursue occlusion treatments first. Occlusion surgery will often improve the profile of the chin.
Can these procedures be performed at the same time?
All these procedures can be combined during the same procedure as desired.
What is recovery like?
Following liposuction, ThermiRF and injections most men will have varying swelling and discomfort for a couple of days that then gradually improves. Synthetic injections typically have less swelling. Patients who have implants have the most discomfort. Following liposuction and ThermiRF most men will wear an elastic dressing for 48 hours. The wear this dressing when at home for about a week. This duration will vary depending on the patients unique circumstances.

subset: commoncrawl


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Heterosexuals close to getting right to have civil partnerships
More than three million heterosexual couples could be allowed to form civil partnerships under proposals backed by the government.
A bill proposed by the Conservative MP Tim Loughton received an unopposed second reading yesterday. If passed, Mr Loughton said that the legislation would "correct an unintended but glaring inequality".
Extending civil partnerships to heterosexual couples is one of the five planks of The Times' Family Matters campaign for reform of family laws.
Mr Loughton said: "I am pleased that the government has accepted the wording of my bill and that it was passed unanimously and has passed through second reading.
"There will no doubt be long and complicated discussions at committee stage but for the moment we can be pleased that my wide-ranging bill,


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Analysis IRC Sec. 280E
The following is our most recent analysis IRC Sec. 280E. The article is 3,500 words long, the footnotes add another 7,800. This is not for the faint of heart, it is written with a target audience assumed to be CPA's with an MST and attorneys with an LLM-Tax. You may also be interested in the companion article 280E – Beyond Dispensaries
A Methodology for Cost and Expense Allocations for IRC Sec. 280
Cannabis businesses come in all shapes and sizes. Each one is a little different. One could argue each is unique. All cannabis businesses share one attribute. Every cannabis business is subject to the potential disallowance under IRC Sec. 280E[1] of otherwise deductible ordinary and necessary business expenses under Internal Revenue Code ["IRC"] Sec. 162(a)[2]. The language in IRC Sec. 280E references the Comprehensive Drug Abuse Prevention and Control Act of 1970 [the "Controlled Substances Act" or "CSA" [3]. Cannabis has been listed as a "Schedule I" drug since IRC Sec. 280E became law. We will revisit the inter-relationship between IRC. Sec. 280E, the status of medical and adult-use cannabis under state law, and the potential consequences of cannabis being reclassified from Schedule I to Schedule II under CSA at a later point.
The potential scope of IRC Sec.280E is likely to come as a surprise to many involved in the cannabis industry, just as Congress certainly could never have contemplated that medical and ultimately adult-use of cannabis would have become legal under the laws of individual states[4].
The drafters of the statute could never have contemplated the current situation where cannabis is legal for medical use in the majority of states, for recreational use in an increasing number of states, and remains illegal under Federal law. There was a period of relative calm after the issuance of the Cole Memorandum and the IRS Chief Counsel Memorandum ["CCM"] 201504011. However, Attorney General Jeffrey Sessions rescinded the Cole Memorandum[5] with the release of Dept. of Justice Press Release 18-8 in early 2018.[6].
The cannabis industry has historically been an underground industry. Many involved in the industry under-reported gross income or did not report at all. With the passage of Proposition 215[7] in 1996 in California, medical cannabis dispensaries began appearing. The public appearance of such businesses came to the attention of the Internal Revenue Service ("IRS").
Income from illegal sources is taxable[8]. In the eyes of the IRS, medical cannabis dispensaries were a particularly attractive target. The Department of Justice could find such dispensaries. The targets of the Department of Justice, whether or not they were put out of business, were subject to IRC Sec.280E. Such dispensaries had substantial income tax liabilities as a consequence of IRC Sec.280E even if they broke-even.
As a result of the focus of the IRS on dispensaries, substantially all of the reported income tax cases involve dispensaries. The cases reported to date are not particularly instructive, however, regarding the proper contours of IRC Sec.280E because of the manner in which most dispensaries have been operated.
Medical cannabis dispensaries are largely cash businesses[9]. Most lack adequate internal accounting controls over cash. The books and records which are the financial record-keeping systems for the businesses have been historically weak. Those medical cannabis dispensaries with systems of internal accounting controls and financial record-keeping systems typically have lapses in the enforcement and maintenance of those systems. The IRS provides taxpayers with detailed suggestions for the types of records which they are required to keep[10]. The IRS further describes how records should be maintained[11] and how long the records must be retained[12] This may well change in the near future as there are a couple of United States Tax Court cases pending decision that are likely to provide significant guidance on the application of IRC Sec.280E to cannabis dispensaries.
Finally, the agencies within the State of California with primary responsibility for oversight of the cannabis industry for regulatory compliance, which are the Bureau of Cannabis Control ["BCC"] for Retail [Dispensaries, Offsite Event and Distribution licensees, the California Department of Food and Agriculture's ["CDFA"] CalCannabis Unit for Cultivation licensees, the California Department of Public Health's ["CDPH"] Manufactured Cannabis Safety Bureau ["MCSB"] for Manufacturing, Extraction and Testing Laboratories and the California Department of Tax and Fee Administration ["CDTFA"], have issued a significant number of administrative pronouncements, regulations and Special Notices that expand upon the IRS's requirements for financial records, recordkeeping, document formats, retention requirements and audit guidelines. The creation of a seed to sale "Track and Trace system, known as METRC[13] is particularly onerous and detailed.
The application of Sec.280E to dispensaries is, however, the tip of the iceberg. IRC Sec.280E applies to "any trade or business if such trade or business (or the activities which comprise such trade or business) consists of trafficking in controlled substances…". The unequivocal language of IRC Sec.280E, however, is equally applicable to cultivators, processors, manufacturers, distributors and cannabis delivery-services.
There may be some limits to the application of IRC Sec.280E to the cannabis industry. It appears unlikely the IRS will stretch IRC Sec.280E to apply its disallowance to a service business, such as marketing or representation businesses, or professional services such as attorneys, certified public accountants, that does not actually "touch the cannabis". The use of the word "trafficking" suggests that IRC Sec.280E is solely applicable to in-line businesses that are directly involved in the series of activities that move an agricultural material from cultivation to the sale of the material to a consumer. Consider, however, whether a cannabis transportation-only service business is subject to IRC Sec.280E.
MMRSA was followed by clean up legislation and Proposition 64 ["Prop. 64"] was passed California became a state that permitted adult use cannabis. Following Prop. 64, the California legislature passed the Medical and Adult-Use Cannabis Regulation and Safety Act ["MARUCRSA"]. MAUCRSA was the foundation for multiple agencies to write of regulations for oversight of the cannabis industry in California.
California has moved from a largely unregulated cannabis market to a comprehensively regulated industry in three years. The transition is a work in progress[14]. A myriad of agencies are involved, Numerous questions remain unanswered with details to yet to be addressed. The transition to regulated markets in California is a complex tale which has yet to have its conclusion revealed.
IRC Sec. 280E Interpretation
As is noted above, substantially all litigation involving IRC Sec.280E has involved dispensaries ["Retail Licensees"]. The application of IRC Sec.280E to businesses other than dispensaries is beyond the scope of this brief memorandum. This memorandum has been written in order to describe a general methodology for the application of IRC Sec.280E to the expenses of a dispensary that will minimize the adverse impact of the provision. It is worthy of note before moving on from general observations relating to the application of IRC Sec.280E that the application of this statute to a cannabis distributor ["Distribution" licensee] may be far more onerous than to a cannabis dispensary.
The IRS has formally agreed those costs and expenses that are properly included in Cost of Goods Sold[15] ("COGS") can be utilized to reduce Gross Revenue in the determination of Gross Profit for a cannabis business. The IRS generally seeks to minimize COGS in order to maximize the impact of IRC Sec.280E on a cannabis dispensary. Of greater significance, the IRS generally takes the position that IRC Sec.280E requires the disallowance of any deduction for costs and expenses incurred by a dispensary that are not properly included in COGS. We believe that the total disallowance of all expenditures which are not included in COGS is a draconian approach that does not comport with the language of IRC Sec. 280E, or the intent of Congress as articulated in the Committee Reports. In those states where the sale of cannabis is legal under state law, this approach is patently absurd.
We believe that such position is unreasonable with respect to costs such as legal advice, tax and accounting advice and executive management, as well as all comparable costs that relate to all aspects of the business as a whole. Further, expenditures such as rent, utilities, payroll and comparable general expenses are properly subject to allocation on a number of bases.
We believe that the argument advanced by the IRS is particularly weak, because the IRS' position ignores the unusual wording and structure of IRC Sec.280E. The disallowance language is clear and unequivocal,
"[n]o deduction or credit shall be allowed for any amount paid or incurred during the taxable year in carrying on any trade or business . . . ."
It is the unusual terminology utilized in the statute to describe the scope and application of the IRC Sec.280E disallowance that creates confusion. The disallowance of a deduction pursuant to IRC Sec.280E applies to amounts paid or incurred "in carrying on" any trade or business that is "trafficking" in a controlled substance. The phrase "in carrying on" suggests that IRC Sec.280E applies solely to amounts directly connected to the activity of "trafficking." The substitution of the word "of" or the phrase "in connection with" for "in carrying on" illustrates this point. Both the word "of" and the phrase "in connection with" would provide greater support for IRS's assertion that IRC Sec.280E disallows any deduction for any cost or expense incurred by a dispensary in a taxable year.
The unusual language used to describe the taxpayers subject to IRC Sec.280E provides further support for this narrower application of the disallowance language. The statute describes the taxpayers to which it applies as, "any trade or business if such trade or business . . . consists of trafficking in controlled substances." The proper interpretation of this statement is complicated by the parenthetical language which was omitted from the quotation, "or the activities which comprise such trade or business." The utilization of both the statement and the parenthetical to describe the taxpayers to which IRC Sec.280E applies indicates the disallowance of costs or expenses pursuant to IRC Sec.280E should be narrowly limited to the amounts directly paid or incurred in "trafficking" in controlled substances by the taxpayer. The meaning of the word "trafficking" as applied to cannabis for the purpose of applying laws, of course, includes all of the activities from the cultivation of cannabis to the sale of cannabis to a consumer.
A Defensible IRC Sec.280E Methodology
Historically California cannabis dispensaries have purchased cannabis flower in bulk and prepared the flower for retail sale at the dispensary. In some instances, dispensaries have also purchased oil in bulk and packaged the oil for retail sale. More frequently oil is purchased by a dispensary already packaged for retail sale. California dispensaries generally also sell items other than cannabis and cannabis products. California cannabis dispensaries, of course, sold only medical cannabis and medical cannabis products until 2018, although the differences between medical and recreational cannabis are irrelevant for the purposes of this memorandum[16].
For the purpose of describing a defensible methodology for allocating costs and expenses of a dispensary to determine the disallowance pursuant to IRC Sec.280E, it will be assumed a storefront dispensary makes all sales on-site and all of the revenue of the dispensary is generated by such sales. It is also assumed for the purposes of this memorandum 80% of the total sales of merchandise by the dispensary are sales of cannabis and cannabis products and 20% of the sales are of other products not subject to IRC Sec.280E.
Further, it is assumed the dispensary purchases substantially all of its cannabis and cannabis products in bulk and processes and packages the bulk material for retail sale. It is assumed thirty percent of the total square footage of the dispensary is devoted to the processing, packaging and storage of cannabis material held for retail sale, thirty percent of the square footage is devoted to management, back-office record-keeping and personnel needs.
The dispensary has sales revenue from the sale of cannabis and cannabis products as well as from the sale of non-cannabis products. Both these classes of products will have associated COGS. For the purposes of this memorandum, it is assumed the non-cannabis products are purchased by the dispensary and packaged and labeled for retail sale on site. Based on this assumption, all additions to COGS for costs and expenses incurred by the dispensary for the processing and packaging of products for retail sale will be added to the COGS for the cannabis and cannabis products.
The first allocation of the costs and expenses of the dispensary that must be made is the allocation of costs and expenses between operating expenses and COGS. As a starting point, it is assumed all of the costs and expenses of the dispensary will be allocated among three functions:
- costs and expenses associated with the processing and packaging of cannabis and cannabis products for retail sale;
- costs and expenses associated with the general administration and management of the dispensary; and
- costs and expenses associated with the retail sale function.
Direct costs and expenses must be first allocated among these three functions as a first step. As a second step the indirect costs must be determined and allocated. As a third step, costs and expenses allocated to general administration and management must in turn be allocated between the processing and packaging function and the retail sale function.
Some specific costs and expenses will be directly attributable to one of the three functions described in the preceding paragraph. Other costs and expenses are only indirectly allocable among these three functions. In some instances, a specific type of cost or expense may be partially attributable to one of the functions as a direct cost and partially allocable among the functions as an indirect cost. For example, if an item of equipment that utilizes a substantial amount of power in connection with processing and packaging, the cost of power for this equipment could be directly attributed to this function while the balance of the power cost was attributed to the facilities and allocated among the three functions as an indirect cost.
Each item of cost or expense must be separately examined, although the various items will fall into a fairly limited number of categories for the purposes of attribution among the functions.
Each specific item of cost or expense must be classified into categories for the purpose of attributing these costs to the appropriate functions of a business. Labor costs are useful for illustrating the methodology that should be followed. Labor costs are a significant portion of the total cost of the operation of a dispensary and a portion of the labor costs generally will be allocable to each of the functions of a business operation. The compensation of the employees of a dispensary generally can be allocated based on job title and time expended in connection with a particular function.
In the case of a dispensary, the compensation of most of the employees should be easily allocated among the processing and packaging function, the general administration function, and the retail sale function, based on the activities of employees. The associated employment costs relating to these employees should be allocated in proportion to the compensation costs in most instances. There is one category of compensation cost for most dispensaries that must be separately considered. Most dispensaries will also have a significant compensation cost for security personnel. In the instance of a California dispensary that has a substantial processing function, a strong argument can be made that the entire cost of compensation for security personnel is allocable to the processing and packaging function.
Each specific item of cost or expense that is financially significant should be examined in a manner similar to the evaluation given to labor costs in the preceding paragraph. Items of cost and expense that are not specifically allocable to processing and packaging function or to the retail sale function should be allocated to the general administration function. When each specific item of cost and expense has been allocated to one of the three categories, the total amount of the cost and expense attributed to the general administration function should be allocated between the processing and packaging function and the retail sale function based on the relative proportions of the compensation allocated to the two functions.
The total amount of the direct and indirect costs and expenses are allocated to the processing and packaging function. The total amount of these costs and expenses will be an addition to COGS. The total amount of the direct and indirect costs and expenses allocated to the retail sale function must then be allocated between sales of cannabis and cannabis products and sales of other products. Based on the assumptions described above 80% of the total amount of the direct and indirect costs and expenses will be allocated to the sale of cannabis and cannabis products and not deductible pursuant to IRC Sec.280E.
The methodology described above can be readily applied to the unique facts of the conduct of business by any cannabis dispensary. This principles that are the foundation for this methodology can also be readily adapted to other cannabis businesses. Of course, as the material moves up the chain of commerce from the cultivator to dispensary, the acquisition cost for each step will be the starting point for the computation of COGS for the next step in the chain of commerce.
[1] "No deduction or credit shall be allowed for any amount paid or incurred during the taxable year in carrying on any trade or business if such trade or business (or the activities which comprise such trade or business) consists of trafficking in controlled substances (within the meaning of schedule I and II of the Controlled Substances Act) which is prohibited by Federal law or the law of any State in which such trade or business is conducted."
[2] IRC Sec. 162(a)In general There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including—
- a reasonable allowance for salaries or other compensationfor personal services actually rendered;
- traveling expenses (including amounts expended for meals and lodging other than amounts which are lavish or extravagant under the circumstances) while away from home in the pursuit of a trade or business; and
- rentals or other paymentsrequired to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity.
[3] In the Controlled Substances Act, 21 U.S.C. Sec.801–971 (1970), Congress created a regime to curtail the unlawful manufacture, distribution, and abuse of dangerous drugs ("controlled substances"). Congress assigned each controlled substance to one of five lists (Schedule I through Schedule V). See Sec. 812 of the CSA. Schedule I includes: (a) opiates; (b) opium derivatives (e.g., heroin; morphine); and (c) hallucinogenic substances (e.g., LSD; cannabis(a/k/a cannabis); mescaline; peyote).
The CSA's Schedules are:
- Schedule I – drugs, substances, or chemicals are defined as drugs with no currently accepted medical use and a high potential for abuse. Some examples of Schedule I drugs are: heroin, lysergic acid diethylamide (LSD), cannabis (cannabis), 3,4-methylenedioxymethamphetamine (ecstasy), methaqualone, and peyote
- Schedule II – drugs, substances, or chemicals are defined as drugs with a high potential for abuse, with use potentially leading to severe psychological or physical dependence. These drugs are also considered dangerous. Some examples of Schedule II drugs are: combination products with less than 15 milligrams of hydrocodone per dosage unit (Vicodin), cocaine, methamphetamine, methadone, hydromorphone (Dilaudid), meperidine (Demerol), oxycodone (OxyContin), fentanyl, Dexedrine, Adderall, and Ritalin
- Schedule III – drugs, substances, or chemicals are defined as drugs with a moderate to low potential for physical and psychological dependence. Schedule III drugs abuse potential is less than Schedule I and Schedule II drugs but more than Schedule IV. Some examples of Schedule III drugs are: products containing less than 90 milligrams of codeine per dosage unit (Tylenol with codeine), ketamine, anabolic steroids, testosterone
- Schedule IV – drugs, substances, or chemicals are defined as drugs with a low potential for abuse and low risk of dependence. Some examples of Schedule IV drugs are: Xanax, Soma, Darvon, Darvocet, Valium, Ativan, Talwin, Ambien, Tramadol
- Schedule V – drugs, substances, or chemicals are defined as drugs with lower potential for abuse than Schedule IV and consist of preparations containing limited quantities of certain narcotics. Schedule V drugs are generally used for antidiarrheal, antitussive, and analgesic purposes. Some examples of Schedule V drugs are: cough preparations with less than 200 milligrams of codeine or per 100 milliliters (Robitussin AC), Lomotil, Motofen, Lyrica, Parepectolin.
[4] Under Explanation of Provision, the Senate Report reads as follows: All deductions and credits for amounts paid or incurred in the illegal trafficking in drugs listed in the Controlled Substances Act are disallowed. To preclude possible challenges on constitutional grounds, the adjustment to gross receipts with respect to effective costs of goods sold is not affected by this provision of the bill. S. REP. NO. 97-494 (Vol. I), at 309 (1982). The Senate bill was adopted in conference. CONF. REP. NO. 97-760, at 598 (1982), 1982-2 C.B. 661.
[5] In 2013 Deputy Attorney General Jim Cole issued a formal statement of priorities for federal prosecutors operating in states where the drug had been legalized for medical or other adult use. The Cole Memorandum represented a major shift from strict enforcement to a more hands-off approach so long as the cannabis-related activity didn't threaten other federal priorities, such as preventing the distribution of the drug to minors and cartels.
[6] The release provides:
"The Department of Justice today issued a memo on federal cannabis enforcement policy announcing a return to the rule of law and the rescission of previous guidance documents. Since the passage of the Controlled Substances Act (CSA) in 1970, Congress has generally prohibited the cultivation, distribution, and possession of cannabis.
In the memorandum, Attorney General Jeff Sessions directs all U.S. Attorneys to enforce the laws enacted by Congress and to follow well-established principles when pursuing prosecutions related to cannabis activities. This return to the rule of law is also a return of trust and local control to federal prosecutors who know where and how to deploy Justice Department resources most effectively to reduce violent crime, stem the tide of the drug crisis, and dismantle criminal gangs.
"It is the mission of the Department of Justice to enforce the laws of the United States, and the previous issuance of guidance undermines the rule of law and the ability of our local, state, tribal, and federal law enforcement partners to carry out this mission," said Attorney General Jeff Sessions. "Therefore, today's memo on federal cannabis enforcement simply directs all U.S. Attorneys to use previously established prosecutorial principles that provide them all the necessary tools to disrupt criminal organizations, tackle the growing drug crisis, and thwart violent crime across our country."
[7] California Proposition 215, also known as the Medical Use of Cannabis Initiative or the Compassionate Use Act, was on the November 5, 1996, general election ballot in California as an initiated state statute where it was approved.
The passage of Proposition 215 is considered a significant victory for medical cannabis. It exempts patients and defined caregivers who possess or cultivate cannabis for medical treatment recommended by a physician from criminal laws which otherwise prohibit possession or cultivation of cannabis.
In May 2009, the U.S. Supreme Court declined to hear an appeal of a California state appellate ruling from 2008 that upheld Proposition 215 and concluded that California can decide whether to eliminate its own criminal penalties for medical cannabis regardless of federal law. The appellate ruling came about because of a lawsuit against Proposition 215 filed by San Diego and San Bernardino counties.
These counties objected to Proposition 215 on the grounds that it requires them, in their view, to condone drug use that is illegal under federal law. They also challenged a law that requires counties to issue identification cards to medical cannabis patients, so these patients can identify themselves to law enforcement officials as legally entitled to possess small amounts of cannabis. [ San Francisco Chronicle, "Solano to allow medical cannabis ID cards," June 24, 2009]
Proposition 215 also led to the lawsuit, People v. Kelly This case was decided in January 2010 by the California Supreme Court, which ruled that the state of California cannot, through the legislative process, impose a state limit on medical cannabis that is more restrictive than what is allowed under Proposition 215. People v Kelly helps define laws governing the initiative process in California especially as it relates to legislative tampering.
The language that appeared on the ballot stated:
- Exempts patients and defined caregivers who possess or cultivate cannabis for medical treatment recommended by a physician from criminal laws which otherwise prohibit possession or cultivation of cannabis.
- Provides physicians who recommend the use of cannabis for medical treatment shall not be punished or denied any right or privilege.
- Declares that measure not is construed to supersede prohibitions of conduct endangering others or to condone the diversion of cannabis for non-medical purposes.
- Contains severability clause.
In 2004, the California State Legislature passed the Medical Cannabis Program Act (MMPA). The MMPA was intended to clarify which specific practices with regard to medical cannabis were to be considered lawful in the state. The MMPA:
- Established a voluntary statewide identification card system;
- Set limits on the amount of medical cannabis each cardholder could possess;
- Laid out rules for the cultivation of medical cannabis by collectives and cooperatives.
In 2007, the California Fourth Appellate District ruled against the City of Garden Grove, and in favor of a medical cannabis patient (Felix Kha), saying that "it is not the job of the local police to enforce the federal drug laws."
The case resulted from the seizure of medical cannabis from Kha by the Garden Grove police force in June 2005.
Kha was pulled over by the Garden Grove Police Department on June 10, 2005, and cited for possession of cannabis, despite Kha showing the officers proper documentation of his status as a medical cannabis patient.
The charge against Kha was subsequently dismissed, with the Superior Court of Orange County issuing an order to Garden Grove that the city must return to Kha 8 grams of medical cannabis that was seized from him by the police. The police, backed by the city of Garden Grove, refused to return Kha's medicine and the city appealed.
In the 2007 state court decision, the court ruled that the federal Controlled Substance Act of 1970, enacted to combat recreational drug abuse and trafficking, did not intend to regulate the practice of medicine, "a task that falls within the traditional powers of the states."
Before the California Fourth District Court of Appeal issued its decision, California Attorney General Jerry Brown filed a "friend of the court" brief on behalf of Kha's right to possess his medicine. The justices noted they were convinced by Brown's arguments that local agencies are bound by state laws in approaching medical cannabis.
The California Supreme Court denied a case review in March 2008, and Garden Grove then went to the United States Supreme Court, which turned the case down in late November 2008.
Medical cannabis advocates called the decision a huge victory in clarifying law enforcement's obligation to uphold state law – in this case, Proposition 215.
[8] IRC Sec. Sec.61(a) does not differentiate between income derived from legal sources and income derived from illegal sources. See, e.g., James v. United States, 366 U.S. 213, 218 (1961). Under the Sixteenth Amendment to the United States Constitution ("Sixteenth Amendment"), Congress is authorized to lay and collect taxes on income.
In a series of cases, the United States Supreme Court has held that income in the context of a reseller or producer means gross income, not gross receipts. In other words, Congress may not tax the return of capital. See, e.g., Doyle v Mitchell Bros. Co., 247 U.S. 179, 185 ("As was said in Stratton's Independence v. Howbert, [citation omitted], 'Income may be defined as the gain derived from capital, from labor, or from both combined.'"); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934) ("The power to tax income like that of the new corporation is plain and extends to the gross income.
Whether and to what extent deductions shall be allowed depends upon legislative grace; and only as there is clear provision therefor can any particular deduction be allowed.").
[9] The IRS has specific reporting requirements for business transactions involving over $10,000 in cash. Specifically, you must file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, if you receive more than $10,000 in cash in one transaction or two or more related business transactions. Cash includes U.S. and foreign coin and currency. It also includes certain monetary instruments such as cashier's and traveler's checks and money orders. For more information, see IRS Publication 1544, Reporting Cash Payments of Over $10,000 (Received in a Trade or Business).
[10] The IRS provides guidance about the purposes of records, uses of records, and outlines their expectations about the types of records that they expect taxpayers to maintain. We have provided an overview:
- Monitor the progress of your business. – You need good records to monitor the progress of your business. Records can show whether your business is improving, which items are selling, or what changes you need to make. Good records can increase the likelihood of business success.
- Prepare your financial statements. You need good records to prepare accurate financial statements. These include income (profit and loss) statements and balance sheets. These statements can help you in dealing with your bank or creditors and help you manage your business. An income statement shows the income and expenses of the business for a given period of time. A balance sheet shows the assets, liabilities, and your equity in the business on a given date. Identify source of receipts. You will receive money or property from many sources. Your records can identify the source of your receipts. You need this information to separate business from nonbusiness receipts and taxable from nontaxable income.
- Keep track of deductible expenses. You may forget expenses when you prepare your tax return unless you record them when they occur.
- Prepare your tax returns. You need good records to prepare your tax returns. These records must support the income, expenses, and credits you report. Generally, these are the same records you use to monitor your business and prepare your financial statements.
- Support items reported on tax returns. You must keep your business records available at all times for inspection by the IRS. If the IRS examines any of your tax returns, you may be asked to explain the items reported. A complete set of records will speed up the examination.
- Electronic records. All requirements that apply to hard copy books and records also apply to electronic storage systems that maintain tax books and records. When you replace hard copy books and records, you must maintain the electronic storage systems for as long as they are material to the administration of tax law.
An electronic storage system is any system for preparing or keeping your records either by electronic imaging or by transfer to an electronic storage media. The electronic storage system must index, store, preserve, retrieve, and reproduce the electronically stored books and records in a legible format. All electronic storage systems must provide a complete and accurate record of your data that is accessible to the IRS.
Electronic storage systems are also subject to the same controls and retention guidelines as those imposed on your original hard copy books and records. The original hard copy books and records may be destroyed provided that the electronic storage system has been tested to establish that the hard copy books and records are being reproduced in compliance with IRS requirements for an electronic storage system and procedures are established to ensure continued compliance with all applicable rules and regulations. You still have the responsibility of retaining any other books and records that are required to be retained.
The IRS may test your electronic storage system, including the equipment used, indexing methodology, software and retrieval capabilities. This test is not considered an examination and the results must be shared with you. If your electronic storage system meets the requirements mentioned earlier, you will be in compliance. If not, you may be subject to penalties for non-compliance, unless you continue to maintain your original hard copy books and records in a manner that allows you and the IRS to determine your correct tax. For details on electronic storage system requirements, See Revenue Procedure 97-22
- Specific Records to Keep – Purchases, sales, payroll, and other transactions you have in your business generate supporting documents. Supporting documents include sales slips, paid bills, invoices, receipts, deposit slips, and canceled checks. These documents contain information you need to record in your books. It is important to keep these documents because they support the entries in your books and on your tax return. Keep them in an orderly fashion and in a safe place.
- Gross Receipts. Gross receipts are the income you receive from your business. You should keep supporting documents that show the amounts and sources of your gross receipts. Documents that show gross receipts include the following. Cash register tapes. Bank deposit slips. Receipt books. Invoices. Credit card charge slips. Forms 1099-MISC.
- Inventory is any item you buy and resell to customers. If you are a manufacturer or producer, this includes the cost of all raw materials or parts purchased for manufacture into finished products. Your supporting documents should show the amount paid and that the amount was for inventory. Documents reporting the cost of inventory include the following. Canceled checks. Cash register tape receipts. Credit card sales slips. Invoices. These records will help you determine the value of your inventory at the end of the year.
- Expenses are the costs you incur (other than the cost of inventory) to carry on your business. Your supporting documents should show the amount paid and that the amount was for a business expense. Documents for expenses include the following. Canceled checks. Cash register tapes. Account statements. Credit card sales slip. Invoices. Petty cash slips for small cash payments.
[11] Recording Business Transactions, A good recordkeeping system includes a summary of your business transactions. (Your business transactions are shown on the supporting documents just discussed.) Business transactions are ordinarily summarized in books called journals and ledgers. You can buy them at your local stationery or office supply store. A journal is a book where you record each business transaction shown on your supporting documents. You may have to keep separate journals for transactions that occur frequently. A ledger is a book that contains the totals from all of your journals. It is organized into different accounts.
Whether you keep journals and ledgers and how you keep them depends on the type of business you are in. For example, a recordkeeping system for a small business might include the following items. Business checkbook. Daily summary of cash receipts. Monthly summary of cash receipts. Check disbursements journal. Depreciation worksheet. Employee compensation record.
[12] You must keep your records as long as they may be needed for the administration of any provision of the Internal Revenue Code. Generally, this means you must keep records that support an item of income or deduction on a return until the period of limitations for that return runs out. The period of limitations is the period of time in which you can amend your return to claim a credit or refund, or the IRS can assess additional tax.
The following table provides a basic summary of record retention requirements:
|1. Owe additional tax and situations (2), (3), and (4), below, do not apply
|3 Years
|2. Do not report income that you should report, and it is more than 25% of the gross income shown on the return
|6 Years
|3. File a fraudulent return
|Not Limited
|4. Do not file a return
|Not Limited
|5. File a claim for credit or refund after you filed your return
|Later of: 3 years or 2 years after tax was paid
|6. File a claim for a loss from worthless securities or a bad debt deduction
|7 Years
[13] METRC Regulations
Sec. 8400. Record Retention. – For the purposes of this chapter, the term record includes all records, applications, reports or other supporting documents required by the department.
(a) Each licensee shall keep and maintain the records listed in subsection (d) for at least seven (7) years from the date the document was created.
(b) Records shall be kept in a manner that allows the records to be provided at the licensed premises or delivered to the department, upon request.
(c) All records are subject to review by the department during standard business hours or at any other reasonable time as mutually agreed to by the department and the licensee. For the purposes of this section, standard business hours are deemed to be 8:00 am – 5:00 pm (Pacific Standard Time). Prior notice by the department to review records is not required.
(d) Each licensee shall maintain all of the following records on the licensed premises, including but not limited to:
- Department issued cultivation license(s);
- Cultivation plan;
- All records evidencing compliance with the environmental protection measures pursuant to sections 8304, 8305, 8306 and 8307 of this chapter;
- All supporting documentation for data or information input into the track-and-trace system;
- All UIDs assigned to a product in inventory and all unassigned UIDs. UIDs associated with product that has been retired from the track-and-trace system must be retained for six (6) months after the date the tags were retired;
- Financial records related to the licensed commercial cannabis activity, including but not limited to, bank statements, tax records, sales invoices, and sales receipts;
- Personnel records, including each employee's full name, social security, or individual tax payer identification number, date of beginning employment, and date of termination of employment if applicable
- Records related to employee training for the track-and-track system or other requirements of this chapter. Records shall include, but are not limited to, the date(s) training occurred, description of the training provided, and the names of the employees that received the training;
- Contracts with other state-licensed cannabis businesses;
- Permits, licenses, and other local authorizations to conduct the licensee's commercial cannabis activity;
- Records associated with composting or disposal of cannabis waste.
- Documentation associated with loss of access to the track-and-trace system prepared pursuant to section 8402(d) of this chapter.
(e) All required records shall be prepared and retained in accordance with the following conditions:
(1) Records shall be legible; and
(2) Records shall be stored in a secured area where the records are protected from debris, moisture, contamination, hazardous waste, fire, and theft.
Sec. 8401. Sales Invoice or Receipt Requirements. The licensee shall prepare a sales invoice or receipt for every sale, transport, or transfer of cannabis or nonmanufactured cannabis product to another licensee. Sales invoices and receipts may be retained electronically but must be readily accessible for examination by the department, other state licensing authorities, any state or local law enforcement authority, and the California Department of Tax and Fee Administration. Each sales invoice or receipt shall include all the following:
- Name, business address, and department issued license number of the seller;
(b) Name, business address, and department issued license number of the purchaser;
(c) Date of sale or transfer (month, day and year). The date of any sale or transfer of cannabis and nonmanufactured cannabis products shall be the date of transfer to the licensee receiving it;
(d) Invoice or receipt number;
(e) Weight or quantity of cannabis and nonmanufactured cannabis products sold;
- For the purposes of this section a licensee must use wet weight or net weight. Wet weight and net weight shall be measured, recorded and reported in U.S. customary units (e.g., ounce or pound); or International System of Units (e.g., kilograms, grams, or milligrams).
- Weighing Devices. A licensee shall follow weighing device requirements pursuant to section 8213 of this chapter.
(3) Count. For the purposes of this section, "count" means the numerical count of the individual plants or units.
(f) Cost to the purchaser, including any discount applied to the total price, shall be recorded on the invoice.
(g) Description for each item including strain or cultivar, and all of the applicable information below:
- Plant;
- Flower;
- Leaf;
- Shake;
- Kief; and
(6) Pre-rolls.
(h) Signature of the seller, or designated representative of the seller, acknowledging accuracy of the cannabis and nonmanufactured cannabis products being shipped.
(i) Signature of the purchaser, or designated representative of the purchaser, acknowledging receipt or rejection of the cannabis or nonmanufactured cannabis products.
Sec. 8408. Inventory Audits. The department may perform an audit of the physical inventory and inventory as reported in the track-and-trace system of any licensee at the department's discretion. Audits of the licensee shall be conducted during standard business hours or at other reasonable times as mutually agreed to by the department and the licensee. For the purposes of this section standard business hours are 8:00am – 5:00pm (Pacific Standard Time). Prior notice of audit is not required.
Sec. 8501. Inspections, Investigations and Audits. The department shall conduct inspections, investigations and audits of licensees including, but not limited to, a review of any books, records, accounts, inventory, or onsite operations specific to the license.
(a) The department may conduct an inspection, investigation or audit for any of the following purposes:
- To determine accuracy and completeness of the application prior to issuing a license;
- To determine compliance with license requirements including, but not limited to, the cultivation plan;
- To audit or inspect any records outlined in section 8400 of this chapter;
- To respond to a complaint(s) received by the department regarding the licensee;
- To inspect incoming or outgoing shipments of cannabis and nonmanufactured cannabis products; and
(6) As deemed necessary by the department.
(b) All inspections, investigations and audits of the licensed premises shall be conducted during standard business hours or at other reasonable times as mutually agreed to by the department and the licensee. For the purposes of this section, standard business hours are 8:00am – 5:00pm (Pacific Standard Time). Prior notice of inspection, investigation or audit is not required.
(c) No applicant, licensee, its agent or employees shall interfere with, obstruct or impede the department's inspection, investigation or audit
This includes, but is not limited to, the following actions:
- Denying the department access to the licensed premises;
- Providing false or misleading statements;
- Providing false, falsified, fraudulent or misleading documents and records; and
(4) Failing to provide records, reports, and other supporting documents.
(d) Upon completion of an inspection, investigation or audit, the department shall notify the applicant or licensee of any violation(s) and/or action(s) the department is taking.
[14] The Medical Cannabis Regulation and Safety Act ["MMRSA"], which went into effect in 2016, included a multitude of regulatory procedures involving many agencies, but much of the regulation of cannabis growing will now fall under the CDFA on both state and local levels. Regulations will include not only compliance with environmental requirements such as the regional water board cultivation permits, but with regulations concerning pesticide use, testing, sales, distribution, and a host of other standards akin to those faced by commercial agricultural producers around the state.
California Governor Jerry Brown signed the MMRSA into law on October 09, 2015, and it became effective on January 01, 2016. The Act, composed of 3 bills (AB 266, AB 243, and SB 643) established a licensing and regulatory framework for the cultivation, manufacture, transportation, storage, distribution, and sale of medical cannabis in the State of California. The MMRSA established the Medical Cannabis Cultivation Program within the California Department of Food and Agriculture ["CDFA"] to license cultivators, establish conditions under which indoor and outdoor cultivation may occur, establish a track and trace program for reporting the movement of medical cannabis items through the distribution chain, and assist other state agencies in protecting the environment and public health.
Subsequently, California voters passed the Adult Use of Cannabis Act (Proposition 64), which also designated responsibilities for oversight of commercial cannabis to multiple state agencies.
- CDFA was granted the authority to establish a cannabis cultivation licensing process for the state and develop a track-and-trace system to record the movement of cannabis and cannabis products through the state's supply chain.
- CDFA created a new division called CalCannabis Cultivation Licensing, which is tasked with overseeing these projects.
On June 27, 2017, California Governor Jerry Brown signed a trailer bill (also known as California Senate Bill 94). This Bill was drafted for the purpose of merging the regulatory scheme of MMRSA with the regulatory provisions of Prop. 64, into one streamlined bill. The laudable purpose was to have one comprehensive state law provide a more unified and efficient regulatory process governing both medicinal and adult-use (recreational) cannabis.
[15] Cost of Goods Sold ["COGS"] is not a deduction but actually, an adjustment which is taken into account in arriving at gross income. Reg. Sec. 1.61-3(a) provides, "gross income" means "…the total sales, less the cost of goods sold." Although IRC Sec. 280E disallows any deduction for a cannabis seller's ordinary and necessary business expenses, the legislative history fails to include the cost of goods sold in this rule. The literature suggests that Constitutional concerns of the Sixteenth Amendment, which taxes 'incomes', are the reason for this exclusion.
In the Senate hearings prior to passing IRC Sec. 280E, discussion suggested including the cost of goods sold in the 'disallowed' expenses for drug traffickers. However, the feeling that this could create a constitutional issue leading to court challenges (and delays) prevailed, and cost of goods sold remained an available adjustment to drug traffickers.
Although the IRS has not issued regulations related to IRC Sec. 280E, the IRS allows the adjustment for Cost of Goods Sold on the tax returns of businesses engaged in drug trafficking. On November 24, 2010, U.S. Representatives Fortney Pete Stark, Barney Frank, Jared Polis, Linda Sanchez, Raul Grijalva, and Sam Farr wrote to the office of the Chief Counsel of the IRS, asking the service to create guidance for regulations related to deductions for state-licensed cannabis businesses.
The Chief Counsel's Office replied to the Congressman on December 16, 2010, stating that the IRS is unable to issue regulations for IRC Sec. 280E since neither the CSA nor IRC Sec. 280E makes an exception for medical cannabis. Further, the Chief Counsel places blame on Congress to change either IRC Sec. 280E or the CSA.
Cost Method for Cost of Goods Sold
A business must use an inventory method of accounting whenever "the production, purchase or sale of goods is an income-producing factor. Under an inventory method, costs related to producing, acquiring, storing, and handling goods are not currently deductible. These costs must be included in the costs of inventory and deducted when inventory is sold. In the typical business, tax professionals look to minimize current income by taking deductions during the current period.
IRC Sec. 263A does not magically transform otherwise disallowed costs under IRC Sec. 280E into allowed capitalized costs, although the tax professional should look to maximize the number of expenditures which can be justifiably capitalized. Generally, the current year inventory costs are added to the beginning of the year inventory amount and reduced by the costs of inventory on hand at the end of the year to calculate costs of goods sold for the year.
IRC Sec. 471 and methods required by IRC Sec. 263A provide that marketing, advertising and selling expenses are "not required" to be treated as inventory costs. Under Reg. Sec. 1.471–11, 6(a), taxpayers must include as inventoriable costs all direct (e.g., the cost of inventory and delivery, and the cost of materials and labor for manufactured inventory) and indirect production costs (e.g., rent and utilities related to inventory)
[16] However, if any of the following changes were to occur at the Federal level such as:
- Reclassification of cannabis by the Drug Enforcement Administration or if Congress were to pass legislation causing cannabis to be transferred from CSA Schedule I to CSA Schedule II or
- Congress were to enact legislation with provisions such that the laws of state which had provided for the legal use of cannabis for medical or adult-use purposes were to be respected by the Federal government.
the legal validity of any application of IRC Sec. 280E in such states would be substantially undercut.
Analysis IRC Sec. 280E comprehensive article detailed from r/cacannabisregulation


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Ice Cream Desserts
Collection by Brenda James • Last updated 4 weeks ago
Easy Frozen Oreo Dessert
This Easy Frozen Oreo Dessert is light, frozen summer dessert… so easy to prepare – just perfect for Oreo cookie fans. One of my favorite frozen desserts. I love it because it is so easy to prepare. 7 ingredients and a little free time is all you need to make Easy Frozen Oreo Dessert.
Blueberry Pie Ice Cream Sandwiches
Do you remember where you were when you had your best "ah-ha!" moments? For me, the lightbulb always goes off in the shower – the only place where I can seek solitude these days. No phone, no computer, and no toddler. So it was in the shower one morning, that I was envisioning making blueberry […]
Red Velvet Ice Cream (Cream Cheese Ice Cream)
Red Velvet Ice Cream is one of my favorite homemade ice cream recipes. This cream cheese ice cream is perfect for Valentine's Day desserts!
Strawberry Colada Smoothie - Cooking Classy
It's summer so we should all be drinking as many smoothies as we can right? I think it is the best time of year for smoothies because there's such an
Peanut Butter Banana Ice Cream - 2 Ingredients!
Smooth and velvety peanut butter banana ice cream, made with just 2-ingredients and a food processor! So good you'd never suspect it's healthy too!
Ice Cream Bar Trifle Recipe
What a PERFECT dessert for a hot summer's day! This deliciously unique ice cream bar trifle can be made with any of your favorite ice cream bars, just substitute the...
Fresh Blueberry Ice Cream | Recipe from Leigh Anne Wilkes
Delicious ice cream made with fresh blueberries.
KETO Chocolate Ice Cream- ONLY 2.6 CARBS Per Serving!
Keto Chocolate Ice Cream is silky smooth, sweet as can be, and a tasty cold treat to cool down this summer.
Weed-Infused Raspberry Ice Cream
Sweet, succulent, cold, and cannabis-infused; this is a simple 7-step raspberry ripple ice cream recipe for vegans.
Cinnamon and Honey Homemade Ice Cream Recipe | Foodal
Love sweet and tasty leftover cereal milk? Try our recipe for homemade ice cream that's infused with cinnamon and honey. With only 5 ingredients, it's so simple to make this creamy treat. Enjoy it on its own, or plop a scoopful on top of your favorite fruit pie or vanilla cake. Learn how to make it now on Foodal.
S'mores Chocolate Chip Cookie Ice Cream Sandwiches
Homemade s'mores chocolate chip cookie ice cream sandwiches are a perfect summer dessert recipe. Chocolate chip cookies with marshmallow ice cream are dipped in chocolate and graham cracker crumbs.
Homemade Strawberry Ice Cream
This homemade Strawberry Ice Cream recipe is an easy summer dessert full of fresh strawberry flavor. This easy strawberry ice cream is creamy and dreamy.
Healthy 5-Minute Strawberry Pineapple Sherbet
Healthy 5-Minute Strawberry Pineapple Sherbet Recipe - This simple no-churn ice cream recipe is half fruit and half yogurt, with a light healthy sweetener.
Strawberry Buttermilk Ice Cream
This homemade Strawberry Buttermilk Ice Cream is made with 6-ingredients! This easy strawberry ice cream recipe is smooth, creamy, and the perfect summer dessert! Do you ever have those moments where you get caught off guard


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Did we play a Premier League side yesterday?
Let's be honest, for as good as we were, Hull were absolutely woeful. They were already being outclassed, but once Ahmed El Mohamady was sent off on the half-hour mark, they never stood a chance.
Based on that performance, it is a miracle that they have already got seven points in the league. We can't help but feel they will be in the bottom three by May.
Mane downplays Liverpool performance
Return of standing areas to Anfield?
Klopp slams Sakho's antics
One image from yesterday's game really stood out, and it's an image of Loris Karius.
The new signing was making his league debut in the game, but he barely had a thing to do. He was helpless for the goal, and didn't face another shot on target in the entire 90 minutes.
Check out the snap below:
Look where he is stood. Almost on the halfway line and not a player from either side anywhere near him.
Perhaps we should have just played 11 strikers!


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According to reports, the naira was yesterday sold at the parallel market for 440 per dollar, as the lingering foreign exchange scarcity increased to a new level.
The local currency, which closed at 436/dollar on Thursday, eased to 435 in the early hours of Friday.
The latest declines in the naira value started on Wednesday, a day after the Central Bank of Nigeria's Monetary Policy Committee retained the benchmark lending rate at 14 per cent


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Have you ever looked at the big gas and oil companies and thought, that you would want to have a piece of the pie, when it comes to enjoying the wealth that many of the big Oil & Gas companies have benefited from over the years, whether it be from the actual production of oil and gas, or the end sale?
Unfortunately over the years many potential investors, of which you may very well be one, have received telephone "boiler-room" sales calls, offering high returns that can be obtained quickly if you invest upwards of $100,000 or more into a single oil or gas well exploration.
Or as is often and rightly the case, you knew what type of call it was, and through your justified scepticism you hung up the call.
Well despite the boiler room sharks, there is no doubting the reality that oil and gas companies continue to see profits increase and record levels of wealth is being created by them, and if you buy stocks in their companies, you will hopefully benefit in some way as hopefully their stocks increase.
The traditional method of oil and gas investing in wells, will produce results, over the long term, but the levels of success can be diminished if the first few wells you invest in do not produce a return. You invests in the first 3 and get nothing, but you want to keep going, because you know from data that the field is able to produce, it just wasn't in those first three wells. So you invest int eh fourth and there is a small return, and so you put that into the 5th and bingo, you strike gold. It took 5 different investments in 5 different wells, but you got a good return.
Now to keep taking this approach takes time and a lot of money. But if you could invest in the oil and gas wells like you invest in other ways, through diversification, then things would be better. After all spreading investment allocations over lots of wells is what the major oil and gas companies do, to limit their losses, so if you could do the same, you too would benefit. Unfortunately it is not possible with this traditional method of oil and gas investing.
While that is the case, with traditional investment, there is an alternative available to normal investors like me and you, that does enable you to build wealth just like the major Oil & Gas Investment Companies.
How to Invest in Oil & Gas Just Like the Major Oil Companies
To explain this alternative method, we will explain how each method works
As the investor you place you entire investment into one single well, be it gas or oil. Now evidence shows that around 50% of normal wells that are drilled, end up being dry. In fact statistics show that on average, only one out of every ten producing wells, is actually classified as outstanding when it comes to production. Furthermore, the risk of loosing your investment by this method of investing in one well at a time, is greater than 50%
So if we take the above mentioned statistics concerning traditional investing, it is fair to say that if you do invest this way, you don't have much hope of a good return. The traditional method shows us the obvious fact that exploratory oil and gas drilling will often result in there being either huge dry hole losses or at best, marginal productive wells that never really achieve payback of the original investment.
So if this is the case, which we all know, if we have done our basic homework, is the situation, how then are oil and gas companies able to be successful? The answer is simple. The oil and gas companies are successful because they invest in a diversity of top-quality well prospects at the same time.
Let us now explain this alternative method that the companies are using.
They will decide to spread their capital investment across, lets say, nice oil or gas projects.
Out of those nine wells, around three of them will come back as dry. The remaining six wells will be classified as commercial because they are producing, and out of those six, two, maybe even three, will be extremely profitable. And what that means is that the risk of losing their entire investment over the wells becomes insignificant, compared to the return.
So having explained how the oil and gas companies ensure a good return on their investment, compared to the old traditional method of investing we are used to, is it possible for us as investors to do the same?
The short and simple answer to that is yes.
There is an oil and gas investment company who provide the means to invest exactly as the big players do. The company is called Clarke Energy Fund Management and their innovative, paradigm-shifting strategy for investing copies that of the gas and oil companies.
The investment they offer is called EPF-IX which is short for Energy Partners Fund 9, nine being the number of wells you invest in at one time. And on of the major benefits of the fund are substantial quarterly income dividends, based on the entire well portfolio.
As an Energy Partners Fund investor, you would become what is referred to as 'Independent Small Producer'. This means that you are able to benefit from all the tax breaks that are available to an IRS-recognized pass-through oil and gas business, as well as also benefiting from the investment power that the Energy Partners Fund company has, with regards to high-quality, high-impact oil and natural gas prospects that are available.
The video below explains it in more detail, or you can do straight to their website and get more information on how the fund works.


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Just when you think scientists have agreed on the melting ice in Antarctica and how this will affect sea-level rises, a new study comes out disagreeing with the last. Now, in a new study, scientists say that while the melting of ice in Antarctica will contribute to sea-level rises this century, and will be significant as well as challenging,
the nightmare scenarios of some studies are just not realistic.
The study, led by Catherine Ritz from Université Grenoble Alpes in France and Dr. Tamsin Edwards from The Open University, now predicts that sea-level rises are more likely to be 10cm this century under a mid to high climate scenario, and that it is extremely unlikely to be higher than 30cm. Previous studies have claimed from 30 cm to one meter rises; this study says there is a 1 in 20 chance of that happening.
"In our study — those just aren't plausible," Edwards told BBC News.
This study is unique in that the researchers have used real world physics together with the shape of the continent's bedrock and how the ice moves over it, with satellites that track changes on the continent supporting their data. The model revealed how the polar south would react if greenhouse gases rose at a medium to high rate.
"The bed of Antarctica is so important for what the ice sheet is doing, and there are parts of it that are just too bumpy and rough or are not sloping in a way that will allow for anything to happen too quickly," said Edwards.
The researchers ran the model over 3,000 simulations; this is not the first time multiple simulations have been done on this; however, it is a first for the simulations to be compared with present day, and then have the comparisons taken into account.
Edwards said in a statement: "Our method is more comprehensive than previous estimates, because it has more exploration of uncertainty than previous model predictions, and more physics than those based on extrapolation or expert judgement."
"People have done multiple simulations before, but what they haven't then done is see how well they compare with the present day, and put that into re-weighting the predictions.
"So, we take those 3,000 runs and compare them to what's happening now in the Amundsen Sea, and if any look as though they are going too fast or too slow, we give them a lower weight in the future.
"We're constraining the model with the observations. Nobody has really done this sort of formal scoring before," Edwards explained to BBC.
The study's central estimate raises the Intergovernmental Panel on Climate Change (IPCC) central prediction of 60 cm global sea-level rise by just a few centimeters under the mid to high scenario they used. But the UK and French team's method allowed them to assess the likelihood of sea-level rise from substantial parts of the ice sheet collapsing, which the IPCC could not due to a lack of evidence, according to the University of Bristol.
Andrew Shepherd from Leeds University, who heads the "Ice sheet Mass Balance Inter-comparison Exercise" (IMBIE) project, and where the study gained its satellite information, told BBC: "This new study is the first prediction of future ice losses to really take today's changes into account. Because of this, we can be more confident in their findings."
"Although extreme ice losses are an unlikely prospect, there is no reason to be complacent about the impacts of climate change on our lifestyles," he warned.


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Vitamin D and cognitive function: a Mendelian randomisation study
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'In the Old Days...'
This untitled poem is from Ko Un's most recent book, Flowers of a Moment, translated by Brother Anthony of Taize, Young-moo Kim, and Gary Gach. Ko Un grew up in Korea during the Japanese Occupation. During the Korean War, he was conscripted by the People's Army. In 1952, he became a Buddhist and lived a monastic life for ten years.
To mark National Poetry Month, NPR.org is featuring a series of newly published works selected by the Academy of American Poets. Learn more about this and other titles at the academy's New Spring Books list.
Ko Un
In the old days a poet once said
our nation is destroyed
yet the mountains and rivers survive
Today's poet says
the mountains and rivers are destroyed
yet our nation survives
Tomorrow's poet will say
the mountains and rivers are destroyed
our nation is destroyed and Alas!
you and I are completely destroyed
Books Featured In This Story
Flowers of a Moment
Paperback, 103 pages |purchase
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Creation Care recognizes that God calls us to care for everything, with special attention needed for the environmental. In 2003, All Saints was the first congregation in New England to receive the EPA's Energy Star Award. The award recognized major environmental improvements by the parish, including a change from steam to hydronic heating with high-efficiency generation and zones to match use patterns. As a result, environmental impact of the parish dropped by about 50%.
In 2011 light bulbs in the Sanctuary (over 400) and Music Room were changed to LED, with a drop in electricity use for the building of about 40%, and cost reduction of over $6,500. The installation of on-demand hot water generation in the kitchen dropped gas use for hot water by over 40%.
The benefits from these environmental actions can be multiplied where you live, work, learn and play – indeed everywhere. Each one of us is called to care for God's creation via Everyday Environmental Stewardship You can find Everyday Environmental Stewardship Briefs for all kinds of actions at the Massachusetts Interfaith Power & Light website. Find out what you can do, act on it, then encourage others to join in Creation Care.
For more information contact Tom Nutt-Powell


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Here's 7 Easy Ways to Fix Your Mediocre Sex Life
Some sex is so-so. Some is spectacular. But it actually doesn't take much effort to turn a routine romp into a mind-blowing experience.
Many people assume it's a lost cause when sex starts to get boring and just go through the motions, says Sadie Allison, author of Ride 'Em Cowgirl! Sex Position Secrets for Better Bucking.
Read More
- Health Benefits of Sex for Women
- Best Sex Positions for Quickies
- 4 Sex Positions She Wants More Than Missionary
"But it's definitely possible to initiate change in the middle of sex," she says.
Here are seven ways you can transform OK sex into a night you'll both never forget. (And for more in-depth techniques—including a step-by-step guide on how to give her an orgasm—check out How to Pleasure a Woman, the ultimate sex manual from the editors of Men's Health.)
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As the Hollywood stars make their way to the red carpet decked out in glamorous dresses, tuxedos and diamonds that cost more than the average person's car, we watch as they are praised once more at the Academy Awards, the most prestigious awards show in the business. Movie buffs can take part in watching, celebrating and making fun of Natalie Portman's dress on Sunday, Feb. 27, at several local theaters and film centers hosting viewing parties.
From 4-8:30pm, the 142 Throckmorton Theatre in Mill Valley presents its viewing party as a benefit for the Breast Cancer Foundation and Harbor Point Charitable Foundation. (142 Throckmorton, Mill Valley; $83; 415.383.9600.) Sonoma International Film Society hosts its party at Estate Restaurant in Sonoma beginning with a red carpet welcome at 3:30pm and culminating in a four-screen viewing (one screen is in the "silent room," for those who want to get away from the incessant mocking of dresses). Hors d'oeuvres, wine, buffet and more are included. (400 W. Spain St., Sonoma; $125; 707.933.2600).
The doors will open at the Lark Theatre's Oscar Party at 4pm in Larkspur, benefiting the theater. Emcee Chad Carvey knows a thing or two about Hollywood—his uncle's Dana Carvey!—and there'll be food and wine from Emporio Rulli, Jessie et Laurent, Melting Pot, Red Robin, Rustic Bakery and more. (549 Magnolia Ave., Larkspur; $55-$75; 415.924.5111.) The Smith Rafael Film Center in San Rafael holds its annual "Black Tie, Blue Jeans, Red Carpet" affair starting at 3:30pm. Emceed by Michael Pritchard, the night promises official awards programs, food and wine, and silent auction and raffle items galore. (1118 Fourth St., San Rafael; $55; 415.454.1222.)
Finally, in Napa, Mondavi Winery hosts a viewing party to raise funds for HIV-AIDS and Cancer Case Management Programs from 5pm to 11pm. Nationally known commercial actor and "Voice of the 49ers" Bob Sarlatte will be featured as live entertainment. (7801 St. Helena Hwy., Oakville; $35-$75; 707.738.4040.)
Don't want to get gussied up? There's always the option of watching the Oscars unfold on the comfort of your own couch in a T-shirt and sweat pants, drinking a nice cold beer. The show starts at 5pm.


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David Layton
David Layton has had short fiction and articles published and anthologized in various literary journals, newspapers and magazines including: Penguin, Exile, the Daily Telegraph, Condé Nast, and the Globe and Mail. He is the author of Motion Sickness, a memoir that was shortlisted for the Trillium Award. His critically acclaimed second book, The Bird Factory, was published by McClelland and Stewart and film rights for the novel were sold to Marty Katz, executive producer of Hotel Rwanda. David Layton's third book, Bloodlines, will be published by HarperCollins in the spring of 2012.


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A company producing rye gin and whiskey used RDP support to increase its production capacity to meet the demand of national and international markets.
Projects & Practice
Total results: 5.
RDP support helped a farmer to acquire the necessary equipment and infrastructure to continue expanding his organic beef cattle herd.
A farm used RDP support to acquire new machinery in order to improve its strawberry production and increase its profitability.
RDP support enabled a family farm to improve the quality of the organic wine they produce by financing the purchase of new equipment.
A marketing project to promote the high-quality Finnish oats to the international market and increase the income of small farms.


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Upskill your experience in building and construction
Invest in your future and add to your current building and construction skills! By enrolling in the Construction Skills Queensland (CSQ) funded Short Courses program, you open the door to future job opportunities and skills development.
The CSQ Short Courses program assists with upskilling and cross skilling existing workers in the building and construction industry and can involve a combination of face-to-face training and supported online learning. You will walk away with skills and experience that are in demand by the industry.
Australian Trade Training College (ATTC) is contracted to deliver the CSQ Short Courses program in the Brisbane North, Sunshine Coast and Gold Coast regions. ATTC can deliver the following units of competency funded by the CSQ Short Courses program:
Students may choose a maximum of three units during the Short Courses funding period (1st October 2016 – 30th September 2017)
Australian Trade Training College are a premier provider of traditional trade training and assessment services. We know the industry and understand the changing needs of the building and construction industry, tailoring our training delivery and assessment services to remain constantly relevant. Our on-site state-of-the-art facilities in North Brisbane among the best in Queensland, allowing participants to learn best industry practice.
Grow your skills today and enrol in the Short Courses program. Call ATTC on 1300 4 MRAEL (1300 467 235) to register your place. The Short Courses program is available from 1 October 2016 to 30 September 2017.
CSQ is an independent industry funded body supporting employers, workers, apprentices and career seekers in the building and construction industry.CSQ Short Courses Program
To be eligible to enrol in the short course program, participants must be an Australian or New Zealand citizen, or a permanent resident of Australia or a refugee and humanitarian visa holder; and must permanently reside in Queensland or be permanently employed in Queensland as a current employee or eligible worker in the Building and Construction industry.
An existing worker is a current employee in the building and construction industry who has a one month or more employment relationship with their employer. The working relationship can be built up through full-time, part-time or casual employment or engagement as a contract worker
An eligible worker has the same meaning as the Building and Construction industry (portable long services leave) Act 1991 (QLD) as amended from time to time.


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Dental bridges are an option we offer that is meant to bridge a gap, usually created by the absence of one or more teeth, between two teeth. Typically, the presence of teeth in the area act as an anchoring point for a false tooth called a pontic – made of either gold, porcelain, alloys, or a combination of those materials – to be placed. Missing teeth are not uncommon; in fact, the American Dental Association reports that adults between the ages of 20 and 64 years old have three decayed or missing teeth. The good news is that we offer several options for missing teeth replacement in the form of dental bridges.
Dental bridges can last anywhere from 5 to 15 years – or even longer. With excellent hygiene and regular checkups, having a dental bridge last over 10 years is not uncommon. Additionally, dental bridges should help you eat and speak better than you did with missing teeth, though it may take some time to get accustomed to it. For eating, until you become used to it, you should try to eat soft foods that have been cut into smaller pieces.
Bridges are a restorative option for an individual who is missing one or more teeth. The absence of teeth results in gaps that can cause remaining teeth to shift into the empty spaces and change your bite. Other issues like gum disease and TMJ can result from areas with absent teeth that are left unattended. Bridges, like crowns, can be made from several different types of materials, including porcelain and can help with maintaining the shape of your face, distributing the force of your bite by substituting for your missing teeth, restoring your smile, reconstructing your ability to speak and chew properly and comfortably, and preventing the aforementioned shifting of teeth.
Dental bridges are anticipated to last from 5-15 years or longer, with the proper care. Excellent oral hygiene routines and regular check-ups help ensure that this will be the case. As your natural teeth serve as a foundation for the bridges through the placement of the abutment crowns, it's incredibly important to take good care of them. The presence of crowns or dental bridges does not mean your teeth or the surrounding areas are protected from issues like decay or gum disease. An oral health routine involving brushing your teeth twice daily, flossing daily, and using an antiseptic mouthwash at least once a day can help with the longevity of your porcelain bridges and the prevention of these problems.
Dr. Lawlor belongs to the American Academy of Cosmetic Dentists and has been specifically trained in cosmetic dentistry. The American Dental Association does not issue special certifications or licenses indicating which dentists are cosmetic dentists and which are not. The dentist you go to for twice-yearly check-ups is probably not going to be the same dentist you go to for cosmetic enhancement. Unless you're in the qualified hands of Dr. Lawlor!
We bill most dental insurances and accept credit cards or CareCredit as forms of payments. Unfortunately, we don't accept MaineCare. Any questions? We're here to help!
We get it. You hate the dentist. You've been trained to loathe the very word and everything associated with it. That's exactly what inspired us to rethink the dental experience, backed by decades of insights and know-how. Meet Maine Dentistry–our space feels both familiar and inviting, our crew seriously knows their stuff, and our approach promotes long-term luster over emergency care.


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The Ravines Golf Course - Golf Package
Custom Stay and Play Package from $159
Custom Stay and Play Package from $149
Golf Ravines is an 18-hole championship golf course steeped in history. The Ravines is a traditional-style public golf course, designed by Duane Dammeyer, that embraces the beauty of the area. The Ravines is designed to provide an enjoyable experience for golfers of all skill levels.
The land that the Ravines Golf Course sits on has been a part of the Ade family for over 115 years. We take pride in providing you with a great golf value with many other amenities, including a comfortable clubhouse and venue for weddings, company outings and more.
We offer a variety of stay & play packages so give us an opportunity to exceed your expectations and book your next golf getaway with us!
Courses Included:
Birck Boilermaker Golf Complex: Ackerman-Allen Course
Birck Boilermaker Golf Complex: Kampen Course
Coyote Crossing Golf Club
Harrison Hills Golf and Country Club
Battle Ground Golf Club
Lodging Options:
Courtyard by Marriott
Four Points by Sheraton
Hampton Inn
Homewood Suites by Hilton
TownePlace Suites by Marriott
The Ravines Golf Course reserves the right to change price and offer at anytime. Prices and offer are subject to change without notice. IndianaGolf.com is not responsible for errors posted in this golf package.


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Welcome to the Media Law Roundup, a weekly digest of developing media news stories from around the world. This week's issue covers India's new open internet policy, the UK's latest surveillance power bill, a Zimbabwe court's strike-down of a defamation law, and more.
India's new open internet law is stronger the United States', MOTHERBOARD
In response to protests and petitions against Facebook's Free Basics app, India introduced a new open internet policy on February 8. At the end of December, India's telecom regulator asked Reliance Communications to suspend the Free Basics app, Facebook's initiative to provide free basic internet services in developing countries. Through Free Basics users can access roughly 80 sites, including the BBC, Wikipedia, and Facebook, on their smartphones without a data plan. Several protesters and advocacy groups have spoken out against the app, claiming that it violates net neutrality. India's new law bans zero-rating, a practice that allows mobile network operators and internet service providers to give preferential treatment to certain apps and websites. This new policy blocks Free Basics in India, although Facebook CEO Mark Zuckerberg said he remains, "committed to keep working to break down barriers to connectivity in India and around the world." India's new law is stronger than the US's Federal Communications Commission regulation, which does not explicitly ban zero-rating. Malavika Jayaram, executive director of the Digital Asia Hub, applauded the new law, but cautioned that India has a lot of progress to make on internet connectivity. "This is a victory for a broad movement that included policy experts as well as grassroots activists," Jayaram said. "But this is not the end of the fight, because it does not answer the larger question of how to connect India's unconnected population to the entire internet, not just a select portion of it. That must be the focus moving forward."
UK surveillance powers bill slammed for privacy, clarity, and targeting failures, TECHCRUNCH
On February 9, the Intelligence and Security Committee of Parliament published its Report on the Draft Investigatory Powers Bill. The Draft Investigatory Powers Bill, introduced in November 2015, is now subject to scrutiny by the Parliament. On February 1, the Science and Technology Committee of Parliament criticized the draft bill's lack of clarity, especially on the issue of encryption. The latest report by the Intelligence and Security Committee (ISC) addresses a wider range of issues including privacy, hacking, and government intrusion. One of the aims of the bill is to close "capability gaps" for intelligence agencies and police forces, however the ISC believes the bill lacks clear justification for its intrusive measures. In a press statement released on February 9 alongside its report, the ISC argues, "The issues under consideration are undoubtedly complex, however it has been evident that even those working on the legislation have not always been clear as to what the provisions are intended to achieve. The draft Bill appears to have suffered from a lack of sufficient time and preparation." The bill faces a short timetable, because the current emergency surveillance legislation, the Data Retention and Investigatory Powers Act of 2014, is set to expire at the end of this year. Another committee is expected to release its report on the draft bill later this week.
Zimbabwe court strikes down criminal defamation law, VOA
On February 3, Zimbabwe's Constitutional Court struck down a criminal defamation law that negatively impacted journalists for over a decade. The Chronicle lauded the court for striking down the law, writing, in an editorial, "The piece of legislation was outdated and uncivilised as it criminalised the practice of journalism and we agree with the full bench of the highest court in the land that criminal defamation has no place in a modern society." The Media Institute of Southern Africa brought the case to court, arguing that the law was unconstitutional and inconsistent with media freedoms outlined in the new constitution. The head of the Media Institute of Southern Africa, Nhlanhla Ngwenya, applauds the victory but also cautions that there is still much work to be done to ensure free journalism in Zimbabwe. "It is a small victory in the sense that there are still a lot of laws which can be used to criminalize the profession of journalism," said Ngwenya. "There is still a litany of laws that Zimbabwe still needs to fight; but, having said that, we are coming from [leaving] a period where criminal defamation was now the preferred law that members of the ruling elite were now using against journalists. They were wantonly and recklessly using the law where they felt the stories were quite unpalatable."
Israel's military censor takes on dozens of bloggers, Facebook pages, HAARETZ
On February 4, Israel's Chief Military Censor Col. Ariella Ben-Avraham requested that 30 bloggers and Facebook page administrators submit military and security-related reports to the censor for review prior to publication. Previously, censors mainly targeted major media sources. The censor claims that examining independent Facebook pages and blogs is necessary for maintaining national security in the internet age, and stresses that they are only evaluating pages listed as public. Ben-Avraham stated, "Let it be made very clear that these are not private profiles. They are all public profiles that define themselves as 'media' and are open to public scrutiny." Dr. Tehilla Shwartz Altshuler, head of the media reform program at the Israel Democracy Institute, criticized the new expansion of military censorship. She said, "On the face of it, it looks like adding insult to injury: Not only do the defense regulations constitute an anti-democratic arrangement that does not recognize the right to free expression, the censor is now asking to expand these bad arrangements to the digital world, instead of fixing them. It is unreasonable that the system chooses to expand [the censor's] authority instead of using it in proper measure, under the perception that the world of 2016 can continue to operate in the reality of the beginning of the 20th century."
As concern grows over terrorists on social media, Senate bill calls for national strategy, WASHINGTONPOST
On February 10, the Senate Homeland and Governmental Affairs Committee began exploring a bill that would establish a comprehensive strategy to combat terrorists' use of social media. The House of Representatives unanimously passed a similar bill after the San Bernardino shooting in December. Law enforcement officials reported that the perpetrators of this attack, Syed Rizwan Farook and Tashfeen Malik, communicated via private message on Facebook to coordinate the attack. After the attack, Malik pledged her support to ISIS on Facebook, which spurred fears about terrorist activity and social media. Congressman Ted Poe (R-TX) pushed for legislation because he did not feel that the Obama Administration was dealing with the issue effectively. "There isn't an overall plan," said Poe. "The Department of Homeland Security, the State Department and the FBI all have different ideas on how foreign terrorist organizations should be combated online…just come up with a uniform plan so we're all dealing with the same issues." The White House disputes this accusation and insists that the government is working to combat terrorist threats on social media. "When the use of social media crosses the line from communication… into active terrorist plotting, that is deeply concerning and has to be addressed," said Emily Horne, a spokeswoman for the National Security Council. "This is something that we have been focused on for some time."
Index unveils 2016 Freedom of Expression Awards shortlist, INDEX
On February 9, Index released its shortlist for the 2016 Index on Censorship Freedom of Expression Awards, featuring 20 individuals and organizations shortlisted from over 400 nominations worldwide. The list recognizes journalists, artists, campaigners, and writers fighting for freedom of expression. Many of the shortlisted nominees have faced death threats, prosecution, and imprisonment for their efforts. The finalists will be announced on April 13 and receive funding to support their work. Jodie Ginsberg, CEO of Index on Censorship, believes it is important to honor those fighting censorship globally. "Censorship is not something that happens 'somewhere else'," said Ginsberg. "It occurs on a daily basis in every country, in every part of the world. The shortlist honours those who are among the bravest and most creative in tackling such threats."
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