text:
Albert J. Henry v. Commissioner. Mary Henry v. Commissioner., United States Tax Court - Memorandum Decision, T.C. Memo. 1997-29, Docket Nos. 27188-91, 1987-92., Filed January 16, 1997
Albert J. Henry v. Commissioner. Mary Henry v. Commissioner.
United States Tax Court - Memorandum Decision
T.C. Memo. 1997-29
Docket Nos. 27188-91, 1987-92.
Filed January 16, 1997.
Timothy M. Hughes, Charles F. Gibbs, and William G. Cavanaugh, New York, N.Y., for the petitioners. June Y. Bass and Valerie N. Larson, for the respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $2,099,534 and additions to tax pursuant to sections 6653(a)(1) 1 and 6661 in the amounts of $104,976.70 and $524,883.50, respectively.
1 All section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.
The issues remaining for our consideration concern whether petitioners are liable for additions to tax under section 6653(a)(1) and (2) and section 6661 for the taxable year 1982. The parties have stipulated that the conclusions in Cramer v. Commissioner [Dec. 49,299], 101 T.C. 225 (1993), affd. [95-2 USTC ╤ 50,491] 64 F.3d 1406 (9th Cir. 1995), control as to the underlying income tax deficiency.
In Cramer v. Commissioner, supra, the taxpayers, like petitioner Albert J. Henry, were shareholders and officers in a corporation that issued certain stock options subject to restrictions on vesting and transfer in connection with their performance of services for the corporation. For certain of the options, the taxpayers filed "section 83(b) elections" in which they reported the fair market value of the options as zero. Upon the sale of the options to an unrelated company in 1982, the taxpayers misstated the transactions on their returns, reporting them as gains from the sale of capital assets. We sustained respondent's determination that the proceeds from such options were taxable as ordinary income at the time of disposition because the options did not have "readily ascertainable fair market values" as defined in section 1.83-7, Income Tax Regs.
FINDINGS OF FACT 2
2 The parties' stipulation of facts and exhibits are incorporated by this reference.
Petitioners Albert J. Henry and Mary Henry resided in San Diego, California, and Scarborough, North Yorkshire, England, respectively, at the time of filing petitions in these cases. Petitioners' 1982 joint Federal income tax return was prepared by their accountant, Robert E. Douglas (Douglas), who signed it as the preparer on April 15, 1983.
Albert J. Henry (Henry) has a bachelor of science degree in civil engineering as well as a master's degree in business administration. Between 1962 and 1968, Henry worked as a lending officer at First National City Bank (First National) in New York City. In that capacity, subject to approval, he reviewed and prepared credit lines for businesses.
After his tenure with First National, Henry worked in Los Angeles and New York City for firms that were members of the New York Stock Exchange. In that regard, Henry prepared institutional research reports on growth companies for use by entities like mutual and pension funds, as well as banks.
Institutional reports are intended to cover a particular company's products, what the projected growth rate might be, and what sort of proprietary advantages the company might have. These reports were designed to give money managers an idea of the value of a company's stock. These reports do not incorporate information on tax matters involving the particular company in question.
IMED Corp. (IMED)
Richard A. Cramer (Cramer) founded IMED, a company engaged in the design, manufacture, and sale of electronic medical instruments, primarily a device known as an "infusion pump", and related disposable devices. From 1972 through August 1982, Cramer was a shareholder, president, chairman of the board of directors, and chief executive officer of IMED. From 1972 through August 1982, Warren K. Boynton (Boynton) was vice president of IMED. Boynton was on the board from 1972 through October 1973 and from December 1974 through August 1982.
Kevin P. Monaghan (Monaghan) served as outside general counsel to IMED from its inception in 1972 until August 1982. From August 1975 through August 1982, Monaghan was assistant secretary of the board of directors of IMED (the board). Monaghan was an attorney admitted to practice in California. Cramer, Boynton, and Monaghan were close friends as well as business associates.
Dan R. Hendrickson (Hendrickson) was hired as a corporate controller of IMED on March 8, 1976, and became treasurer of IMED on February 14, 1978. Hendrickson previously had prepared Cramer's personal income tax returns for a number of years. At IMED, Hendrickson reported directly to Cramer on the financial condition of the company and the associated tax liabilities.
The stock of IMED was neither publicly traded on an established stock market exchange nor registered with the Securities and Exchange Commission from 1978 through 1981. The directors and three or four key officers owned approximately 75 percent of the outstanding IMED stock.
On March 1, 1978, Henry joined IMED as vice president-finance and chief financial officer (CFO). Initially, Henry was expected to raise equity for IMED and to institute financial controls. Later on, Henry was in charge of determining IMED's capital needs, preparing cashflow forecasts, and raising cash as necessary. As IMED's CFO, Henry was directly responsible to Cramer and met with him daily. At IMED, Henry was one of the IMED officers who could meet with Cramer on an unscheduled basis. Also, occasionally Cramer and Henry would go out to dinner and discuss business. Henry also saw Boynton, who was number two in IMED's hierarchy, on a daily basis since his office was nearby. However, Henry did not have frequent contact with Monaghan at IMED.
When Henry became the CFO of IMED, Hendrickson was responsible for the accounting department. As IMED's CFO, Henry was Hendrickson's direct supervisor. Hendrickson's office, however, was located in another building at the same office compound. When Henry began work for IMED, the accounting department had approximately 10 people who reported to Hendrickson. Later, the department expanded to approximately 50 people.
In general, Henry considered Hendrickson to be competent, diligent, and responsible. Henry believed Hendrickson would apprise him of important financial matters within the ambit of the accounting department. Also, Henry socialized with Hendrickson once every couple of months, as well as having lunch with him on a regular basis. Otherwise, Henry did not regularly socialize with the other officers and directors of IMED.
IMED also maintained outside auditors, Arthur Young & Co. (Arthur Young), which performed audits of the financial statements at the end of the fiscal year. From 1974 until 1980, the principal contact at Arthur Young was Kim Rutledge (Rutledge), an accountant. Rutledge primarily had contact with Hendrickson and his predecessor at IMED.
On March 1, 1981, Henry became a member of IMED's board of directors (the board) and remained in that position until August 1982. When Henry joined the board, Cramer, Boynton, Monaghan, and two other individuals were on it. On occasion, prior to joining the board, Henry would present financial statements for review and brief the directors on company operations.
IMED Stock Options
IMED instituted a stock option plan that it granted to certain employees. The stock options granted were intended to enable employees to participate in IMED's growth and prosperity. This particular program was managed by Cramer, Monaghan, and Hendrickson.
In the process of granting stock options to its employees, IMED required the participants to file elections pursuant to section 83(b) (section 83(b) elections). 3 Generally, IMED did not issue Forms W-2 or 1099 to any option grantee for the year in which the option was issued. Subsequent to the section 83(b) election, IMED did not deduct the costs of the stock options it granted to its employees because that might result in the realization of ordinary income by the recipients.
3 Sec. 83(a) provides generally that if property is transferred to an individual as compensation for services, recognition of income will be deferred if the property is not transferable or is subject to a substantial risk of forfeiture.
Sec. 83(b) provides, in relevant part, that the employee may elect within 30 days of receipt to include the value of the property for the year he receives it, despite the fact that such property is nontransferable and forfeitable.
On August 17, 1979, Henry received his first stock options (1979 options). The 1979 options granted Henry the right to purchase 29,250 shares of IMED's common stock. The par value of the common stock was 15 cents per share. Henry could exercise his options to purchase stock at $13 per share.
On September 14, 1979, Hendrickson presented Henry with a section 83(b) form to sign. Hendrickson further informed him that this document was required to be signed in order to obtain long-term capital gains on the 1979 stock options. The document contains the note that, as a condition of exercising these particular stock options, continued employment with IMED was a requirement. The document also includes the provision that the fair market value was "none" and there were no amounts currently paid in.
The 1979 options provided that the optionee could exercise the options "in 20% increments through the fifth-year end anniversary hereof, so long as he is, at such anniversary date, still an employee or consultant to IMED". The 1979 options also contained the following vesting schedule:
The 1979 options were transferable, subject to the vesting provisions, only to persons approved by the board as "qualified offerees". The approval of the board was stated to be contingent on the receipt of a favorable opinion of counsel and could be refused if the transfer would require registration under section 5 of the Securities Act of 1933, ch. 38, 48 Stat. 74, 77, as amended, 15 U.S.C. sec. 77a (1988).
Simultaneously with his signing of the section 83(b) election for the 1979 options, Henry was provided with a copy of a letter from IMED.
Dear Option Holder:
Congratulations on your recent stock option. The enclosed election, which is necessary to provide for capital gain treatment upon ultimate stock sale by you, should be signed by you (and your spouse where applicable) and returned to Dan R. Hendrickson, at IMED before September 30, 1979.
The original will be filed with the Internal Revenue Service and a copy retained in the files of IMED. The second copy enclosed is for your records.
You have no income to report at this time, as the election is protective only.
Very truly yours,
Dan R. Hendrickson
Sometime in March 1980, Henry exercised a portion of the 1979 options to the extent that he acquired 4,000 shares of IMED common stock at $13 per share. The 1979 options still conferred on Henry the right to purchase the remaining 25,250 shares. On October 16, 1980, Henry sold the 4,000 shares of IMED common stock for $190,000.
In December 1980, John Stine (Stine) replaced Rutledge as the Arthur Young tax principal performing corporate tax work for IMED. Stine's main contact at IMED was Hendrickson. Stine also talked with Monaghan on occasion. As tax principal for Arthur Young, Stine did not consult with Henry on tax matters.
On May 29, 1981, IMED and IMED International Corp. (International), a Cayman Islands, British West Indies, corporation, formed a trust with a Swiss corporation as trustee. 4 The Swiss trustee was entitled to exercise stock options (the 1981 options) on behalf of certain enumerated individuals designated as the "Beneficiaries". The 1981 options were allocated as follows:
4 On Oct. 3, 1980, the outstanding shares of IMED and International were "paired" so that the stock of neither company could be issued or sold without the simultaneous issuance or sale of an equal number of shares of the other company.
1 There are two other beneficiaries who were members of IMED's board, but they are not part of these cases, and hence, need not be identified.
The trust agreement was signed by Cramer, as chairman of both IMED and International. Subsequently, Henry was informed by Cramer that he would receive additional stock options. Henry did not sign or receive certificates or documents with respect to the 1981 options.
On May 27, 1981, Monaghan wrote to Hendrickson, noting that stock options in IMED had been granted to certain employees, and requesting that the aforementioned individuals sign section 83(b) elections and file them by June 17, 1981.
On October 28, 1981, Stine, of Arthur Young, sent both Monaghan and Hendrickson a letter which stated:
IMED currently takes the position that its stock options are governed by Section 83 and therefore the present tax treatment is * * * no income to the employee on grant or exercise and no compensation deduction to IMED. However, Regulation 1.83-7 states that an option must have a "readily ascertainable fair market value" before Section 83 will apply. Since the definition of "readily ascertainable fair market value" is virtually impossible to meet, IMED's present position is subject to challenge. * * *
On November 12, 1981, Monaghan informed Hendrickson that certain IMED employees had obtained options on IMED stock, but that the options "should not be delivered to the holders until their Section 83 elections have been prepared and are ready to file."
In an undated form letter from Robert Reiss, president of IMED, employees participating in the stock option plan were informed that the section 83(b) elections were "necessary to provide for capital gain treatment upon ultimate stock sale by you". This document further states that the recipient has "no income to report at this time, as the [section 83(b)] election is protective only."
In early 1982, Cramer, along with the majority of IMED's stockholders, met with investment bankers to proceed with the sale of IMED. Henry was always present with Cramer when prospective purchasers came to perform due diligence investigations with respect to IMED.
On May 6, 1982, the management of Warner-Lambert Corp. (Warner-Lambert) approached the officers and directors of IMED to propose a transaction whereby Warner-Lambert would acquire all the outstanding stock of IMED and its subsidiaries. Initially, Warner-Lambert offered $480 million, subject to a due diligence investigation.
As part of the negotiations, Cramer, Monaghan, Boynton, and Henry, as IMED's executive officers, went to Warner-Lambert's corporate offices in New Jersey. As IMED's CFO, Henry was required to supply financial analyses, as well as discuss the projected market and product forecasts. At some point during the sale negotiations, Henry told Cramer that he thought that the stock options should be longterm capital gains.
In the IMED sale negotiations, the executives from both companies recognized that there would be a problem with IMED's employee stock options. Warner-Lambert realized that if the options were not exercised, then IMED would not have $30 million to $40 million in its treasury at the time of sale. Consequently, in New Jersey, Cramer met with Ward Hagen, the chief executive officer of Warner-Lambert. When the meeting ended, Cramer told Monaghan, Boynton, and Henry that the option holders would obtain long-term capital gain treatment and instructed Monaghan to structure the transaction to achieve such long-term capital gain. Warner-Lambert was persuaded to purchase the employee stock options and to forgo a deduction in its 1982 Federal income tax return for the cost of purchasing the options. However, Warner-Lambert reduced the offer for IMED from $480 million to $465 million.
During the final negotiations, the officers and directors of IMED met with the law firm Skadden, Arps, Slate, Meagher & Flom (Skadden, Arps), which represented Warner-Lambert in New York City. After a meeting with the attorneys from Skadden, Arps in Manhattan, Monaghan informed Henry that he had structured the options as long-term capital gain. Subsequently, Monaghan told Boynton, in response to Boynton's question, that the option proceeds would be treated as long-term capital gain.
On July 8, 1982, the Swiss trust that held the 1981 options was dissolved. The assets of the trust, the 1981 options, reverted to IMED. In August 1982, Warner-Lambert purchased all of the outstanding stock of IMED for approximately $163 per paired share of stock in IMED and International. Warner-Lambert paid a total of $465 million for all of the outstanding stock plus the extant stock options belonging to employees of IMED.
Warner-Lambert, through IMED, issued Henry a 1982 Form W-2 that was filed as part of petitioners' 1982 Federal income tax return declaring $92,874.60 as income. Neither Warner-Lambert nor IMED provided Henry with another Form W-2 or 1099 or other form or statement that declared his stock option proceeds as income.
Robert E. Douglas
Douglas, a certified public accountant, prepared petitioners' 1982 Federal income tax return. He was licensed in California and, since 1977, a partner in the firm of Jassoy, Graff & Douglas. Henry was introduced to Douglas by Hendrickson, who informed him that Douglas was an "excellent, very careful accountant". Between 1968 and 1974, Douglas worked in the tax department of Price Waterhouse. While at Price Waterhouse, Douglas was an instructor in its national tax course. Between 1974 and 1977, Douglas practiced with George Peterson & Co.
As petitioners' accountant, Douglas prepared their 1977 through 1982 joint Federal income tax returns. Petitioners' 1978, 1979, and 1980 returns were audited by respondent. Douglas represented petitioners in these audits, which resulted in minor adjustments to petitioners' returns. Generally, Henry was satisfied with the manner in which Douglas handled the audits.
Henry informed Douglas that IMED had been sold, and that it was Henry's understanding that Monaghan, as IMED's counsel, had structured the stock options as long-term capital gain. Henry also advised Douglas that if there were any questions regarding the handling of the options to contact Monaghan or Hendrickson.
Douglas agreed with his partner, Robert W. Jassoy Jr., that the option proceeds should be classified as long-term capital gain on the income tax returns he prepared for petitioners. In reaching this decision, Douglas considered as a factor that there were no Forms W-2 or 1099, nor any other form, issued by either Warner-Lambert or IMED, declaring the option proceeds as income. Also, based on an earlier discussion with Hendrickson regarding IMED's stock option plan, Douglas surmised that Arthur Young approved the tax treatment of the stock option proceeds based on the legislative history of section 83. In addition, Douglas believed that the attorneys representing Warner-Lambert and IMED had structured the transaction to accomplish long-term capital gain for the option holders. Finally, in reaching his decision, Douglas relied on the fact that Hendrickson had informed him about the section 83(b) elections. Douglas concluded that the elections put respondent on notice regarding the stock options. However, Douglas knew that there was a distinct possibility that respondent might challenge the classification of Henry's stock option proceeds as long-term capital gain.
Douglas prepared petitioners' 1982 joint Federal income tax return. Henry provided Douglas with the Form W-2 that he obtained, through IMED, from Warner-Lambert. Douglas, however, did not review the option documents or the option plan.
Petitioners' 1982 Federal income tax return reported income from wages of $92,875 and capital gain of $3,462,345. On the Schedule D included with their 1982 Federal income tax return, petitioners reported a short-term loss of $3,796 and long-term capital gains of $8,636,553, the net of which resulted in the $3,462,345 after considering the deduction for capital gains. Next to both entries was the following reference: "SEE ATTACHED COMPUTER D".
On Schedule D, a schedule petitioners included with their 1982 Federal income tax return, they listed their capital gains. Petitioners reported:
1 This column reflects gains reported under the category of "More than 1, 5 years or less".
Petitioners reported a total of $8,636,553 as long-term capital gain in the "FEDERAL TOTALS" column. On the second page of the Schedule D, petitioners reported a net gain of $8,655,862.
Hendrickson had overall corporate tax responsibility within IMED. Hendrickson apprised Henry concerning matters related to petitioners' personal taxes but believed that was not specifically part of his duties at IMED. Hendrickson stated that it became apparent, sometime in 1977 or 1978, that with respect to the stock options, unless something was changed, longterm capital gain was not a possibility. Hendrickson also believed that it would be difficult to overturn the particular regulation in question. Hendrickson warned some of the option holders that capital gain was not guaranteed. At the time of IMED's sale in 1982, Hendrickson knew that the stock option proceeds were not entitled to long-term capital gain treatment.
Monaghan was aware of "ongoing discussions" regarding the proper tax treatment of the stock options throughout the corporate life of IMED. Monaghan believed that members of the board would have been aware of these discussions, as well as Rutledge at Arthur Young. Monaghan discussed the stock options with Henry.
Monaghan believed that upon analyzing the tax provisions related to stock options, a section 83(b) election would ensure that the proceeds would be treated as long-term capital gain. However, Monaghan understood that there were some risks associated with the section 83(b) election for the stock optionees.
Boynton believed that there had been no discussions among the officers and directors of IMED who were negotiating the sale of the company to Warner-Lambert regarding the taxation of the employee stock options. However, Boynton was aware of discussions of how Warner-Lambert would acquire the outstanding employee stock options. Boynton discussed the tax treatment of the proceeds of the IMED options only with Monaghan. Boynton was otherwise unaware of the possibility that respondent might challenge the long-term capital gain treatment of his stock option proceeds and considered it Hendrickson's responsibility to handle tax matters as well as the stock option plan.
As the chief executive officer of IMED and majority stockholder, Cramer considered Henry to be an important individual in the company. However, Cramer considered Henry to be "the one outsider" in IMED. The 1981 options granted to Henry were for services rendered, although Cramer noted that Henry had not yet accomplished anything of substance at the time of the grant.
Petitioners concede that they are liable for the underlying income tax deficiency but contend that they are not liable for the additions to tax. In that regard, petitioners bear the burden of proof with respect to the additions to tax. Rule 142(a); Luman v. Commissioner [Dec. 39,500], 79 T.C. 846, 860-861 (1982).
Respondent argues that petitioners were negligent inasmuch as they knew that: (1) When granted, the options did not have readily ascertainable fair market values; (2) the options did not have fair market values of zero at the time they filed their section 83(b) elections; and (3) at the time the 1982 Federal income tax returns were filed, their positions were subject to challenge. Petitioners, on the other hand, contend that they did not misrepresent the sale of the options, relied on professional advisers, and acted in good faith in reporting the sales of the options. The success of petitioners' contentions is dependent in part on their claim that they were unaware of the concerns of other top echelon officers of IMED, even though Henry was a director and part of that group.
For 1982, section 6653(a)(1) provides for an addition to tax equal to 5 percent of the underpayment in tax if any part of the underpayment is due to negligence or intentional disregard of rules and regulations. Section 6653(a)(2) provides for an addition to tax equal to 50 percent of the interest payable under section 6601 on that portion of the underpayment in tax attributable to such negligence or intentional disregard.
Negligence is defined as the failure to exercise the due care that a reasonable and ordinarily prudent person would employ under the circumstances. Zmuda v. Commissioner [84-1 USTC ╤ 9442], 731 F.2d 1417, 1422 (9th Cir. 1984), affg. [Dec. 39,468] 79 T.C. 714 (1982); Niedringhaus v. Commissioner [Dec. 48,411], 99 T.C. 202, 221 (1992); Neely v. Commissioner [Dec. 42,540], 85 T.C. 934, 947 (1985). The question is whether a particular taxpayer's actions in connection with the transactions were reasonable in light of his experience and the nature of the investment or business. See Henry Schwartz Corp. v. Commissioner [Dec. 32,098], 60 T.C. 728, 740 (1973). We also consider the taxpayer's experience and knowledge in determining whether he acted negligently or intentionally disregarded rules and regulations. Vandeyacht v. Commissioner [Dec. 49,770(M)], T.C. Memo. 1994-148; DeRochemont v. Commissioner [Dec. 47,786(M)], T.C. Memo. 1991-600.
A taxpayer may avoid liability for the additions to tax under section 6653(a)(1) and (2) by relying on competent professional advice if it was reasonable to rely on such advice. United States v. Boyle [85-1 USTC ╤ 13,602], 469 U.S. 241, 250-251 (1985); Freytag v. Commissioner [Dec. 44,287], 89 T.C. 849, 888 (1987), affd. [90-2 USTC ╤ 50,381] 904 F.2d 1011, 1017 (5th Cir. 1990), affd. [91-2 USTC ╤ 50,321] 501 U.S. 868 (1991). Reliance on professional advice, standing alone, is not an absolute defense to negligence but rather a factor to be taken into consideration. In order for reliance on professional advice to excuse a taxpayer from the additions to tax for negligence, the taxpayer must show that the professional had the expertise and knowledge of the pertinent facts to provide valuable and dependable advice on the matter at hand. Goldman v. Commissioner [94-2 USTC ╤ 50,577], 39 F.3d 402, 408 (2d Cir. 1994), affg. [Dec. 49,343(M)] T.C. Memo. 1993-480; Freytag v. Commissioner, supra; Kozlowski v. Commissioner [Dec. 49,286(M)], T.C. Memo. 1993-430, affd. without published opinion 70 F.3d 1279 (9th Cir. 1995).
There were three taxpayers before this Court in Cramer v. Commissioner [Dec. 49,299], 101 T.C. 225 (1993). Two of the taxpayers claimed millions of dollars' worth of basis for their options, and the third reported his sale of the options as a straightforward sale of stock. We found in Cramer that the options, when granted, did not possess a readily ascertainable fair market value. The taxpayers in Cramer filed section 83(b) elections while knowing that the options did not have fair market values of zero. Finally, they knew at the time they filed their 1982 Federal income tax returns that their position was subject to being challenged. Consequently, we held that the taxpayers in Cramer were subject to the additions to tax for negligence in part because they signed 1982 returns that they knew, at the time, contained material misrepresentations. The Court of Appeals for the Ninth Circuit affirmed the imposition of the negligence addition. 64 F.3d at 1414-1415.
Here, petitioners argue that they were in a different position from the Cramer taxpayers in that they properly relied on the professional evaluation and advice of their independent certified public accountant, Douglas, when they reported a basis of zero in the stock options on their 1982 joint income tax return. Petitioners also contend that they did not know that the proceeds from the stock options were not longterm capital gain. Based on these claimed differences, they argue that they were not negligent.
Under the circumstances here, petitioners' reliance was not reasonable. We agree with respondent that petitioners were negligent in reporting the proceeds from the sale of the options as long-term capital gain on their 1982 return. Their claims of good faith are not supported by the record.
Petitioners contend that Douglas alone made the decision to classify the option proceeds as long-term capital gain. Petitioners further contend that they had no reason to question Douglas' classification of the option proceeds as longterm capital gain. Petitioners explain that when Douglas was hired as their accountant, Henry was informed that Douglas had an impressive professional background. In addition, petitioners were pleased with Douglas' representation in several audits of prior years. Accordingly, petitioners argue that, at the time Douglas started work on petitioners' joint 1982 Federal income tax return, they had every reason to rely on his professional acumen.
Respondent points out, however, that Henry was a sophisticated businessman who functioned in a highly competitive environment and should not be allowed to claim reliance on his adviser if he failed to provide the adviser with correct and complete information. See Pessin v. Commissioner [Dec. 31,796], 59 T.C. 473, 489 (1972). Specifically, in preparing the 1982 returns, Douglas was not provided with copies of the relevant IMED options.
Douglas stated that he alone determined that the stock option proceeds were long-term capital gain in petitioners' joint 1982 Federal income tax return. In his testimony, Douglas discussed various factors that he incorporated in his ultimate conclusion that the stock option proceeds were capital gain. Douglas, however, was not sufficiently informed to reach that conclusion. He knew that there was a chance that respondent would challenge the tax treatment. Henry told Douglas to ask for more information from either Monaghan or Hendrickson with respect to the stock option plan. However, Henry specifically informed Douglas that long-term capital gain treatment for the stock option proceeds was warranted.
Douglas admitted that petitioners did not provide him with certain relevant information such as copies of the 1979 or the 1981 IMED options. Petitioners did not provide an explanation as to why these particular documents were not produced to their accountant. In other words, petitioners failed to provide their accountant with sufficient information to render a fully informed opinion concerning the relevant facts and law. See United States v. Boyle, supra; Freytag v. Commissioner, supra. Moreover, blind reliance on another for the accuracy of a return is generally insufficient to avoid liability for negligence additions to tax. See Bailey v. Commissioner [Dec. 20,146], 21 T.C. 678, 687 (1954). Here, it was not reasonable to rely on Douglas' conclusion because he was not fully informed by petitioners.
Henry contends that he reasonably believed that the stock option proceeds were long-term capital gain, for the following reasons: (1) Because of IMED's section 83(b) program; (2) the fair market value of the stock option was entered as zero in the election that Henry signed; (3) IMED provided Henry with a letter that stated that the election "is necessary to provide for capital gain treatment upon ultimate stock sale"; (4) Hendrickson informed Henry that the election was necessary to obtain long-term capital gain treatment; (5) Henry was informed that the option proceeds were long-term capital gain by both Cramer and Monaghan; (6) subsequent to IMED's sale, Henry did not possess Forms W-2 or 1099 that reflected the stock option proceeds as income.
Although there were many self-serving assertions that capital gains were the proper treatment, the record supports our finding that petitioners were aware that the stock option proceeds were not properly characterized as long-term capital gain. In particular, in March 1980, Henry exercised the right to acquire 4,000 shares of IMED common stock for $13 per share. Later, Henry sold these shares of stock on October 16, 1980, for $190,000. Thus, petitioners sold the shares for $47.50 per share, some $34.50 more than the option price. Moreover, Henry's education and work experience enabled him to value stock and growth projections for companies. Consequently, Henry knew or should have known that the section 83(b) election, which he signed in September of 1979, was invalid insofar as it stated that the fair market value of the 1979 options was zero.
Also, petitioners cannot rely on Hendrickson's statements made concerning the election nor the IMED form letter obtained on September 14, 1979, to negate additions to tax for negligence attributable to their 1982 return. In general, petitioners had an obligation to independently verify their own proper income tax liability. In other words, petitioners failed to ask pertinent questions or even make a cursory investigation beyond the information provided to them concerning the IMED stock options. See LaVerne v. Commissioner [Dec. 46,544], 94 T.C. 637, 652-653 (1990), affd. without published opinion sub nom. Cowles v. Commissioner, 949 F.2d 401 (10th Cir. 1991), affd. without published opinion 956 F.2d 274 (9th Cir. 1992); see generally sec. 1.6661-6(b), Income Tax Regs. Moreover, the duty of filing accurate tax returns cannot be avoided simply by delegating responsibility to an agent. Pritchett v. Commissioner [Dec. 32,840], 63 T.C. 149, 174 (1974).
Henry argues that he was not part of the core group that controlled IMED and that he would not be privy to the "ongoing" discussions with Cramer, Monaghan, and Boynton regarding the stock options. Respondent, however, points to the fact that Hendrickson was responsible to Henry in the organizational scheme within IMED. In other words, Hendrickson's responsibility as the head of IMED's accounting department included conveying his interpretations of the Internal Revenue Code to Henry.
Hendrickson's responsibilities in the corporation included informally advising Henry with respect to his own taxes. Henry and Hendrickson socialized once every couple of months, as well as having lunch with each other on a regular basis. In connection with the sale negotiations with Warner-Lambert, Henry was required to supply financial analyses, as well as discuss the projected market and product forecasts. Although Henry's responsibilities did not specifically encompass taxation issues, the tax treatment of the stock options was a critical consideration. In particular, we note that a major item that was negotiated involved Warner-Lambert's forgoing a deduction on its 1982 Federal income tax return for the payment of the option purchase proceeds. That issue was important enough for Cramer to meet with the head of Warner-Lambert. Also, Henry admitted, during the sale negotiations, he expressed his belief to Cramer that the stock option proceeds should be long-term capital gain. At the very least, Henry was aware that Warner-Lambert chose to coordinate with IMED on the issue of the proper taxation of the outstanding stock options.
Hendrickson introduced Douglas to Henry and gave Douglas an excellent recommendation. Douglas had been in contact with Hendrickson regarding the IMED stock option plan when it was set up, and he gave Douglas the impression that Arthur Young had approved of the tax treatment of IMED's stock option plan. Hendrickson addressed important tax matters with Henry and also likely apprised him of the issue of the proper characterization of the stock option proceeds.
It should also be noted that in 1981 Hendrickson was placed on notice by the Stine letter that because "the definition of `readily ascertainable fair market value' is virtually impossible to meet, IMED's present position [that section 83 governed IMED's stock options] is subject to challenge." The top executives and officers of IMED believed that the proper treatment of the stock option proceeds was as long-term capital gain. Yet the record does not reflect that their belief was based on thorough research or analysis. Nor did they consult their tax professionals concerning the section 83 option issue. In this setting, the Stine letter is the only in-depth inquiry concerning the proper taxation of the income from the option proceeds. It appears improbable that the significance of the Stine letter would escape Henry and Hendrickson, especially because it contained an opinion contrary to their hoped-for capital gains reporting of the IMED stock options.
Finally, Cramer and Monaghan informed Henry at the IMED sale negotiations in New Jersey that the stock option proceeds would be structured as capital gain. In general, tax reduction is an acceptable goal as long as the reduction involves transactions with substance and is by legal means. Frank Lyon Co. v. United States [78-1 USTC ╤ 9370], 435 U.S. 561, 583-584 (1978). It does not, however, enable a taxpayer to ignore relevant information.
There were numerous opportunities for petitioners to learn of the questionable status of the capital gain tax treatment of the stock options. Hendrickson warned at least some of the IMED stock optionees at the time they signed their section 83(b) elections that the IMED options program was contrary to the regulations promulgated by respondent. Monaghan knew there was a possibility that the Commissioner would challenge IMED's treatment of the stock option proceeds, and he initiated "ongoing" discussions among the officers and directors of IMED concerning this particular issue. Also, Cramer advised the other three IMED negotiators (which included Henry), subsequent to a meeting with the chief executive officer of Warner-Lambert, that the option proceeds would be deemed long-term capital gain. This rebuts petitioners' contention that the options were not considered in the sale negotiations with Warner-Lambert. Additionally, Henry did not provide any other reasonable explanation as to why Warner-Lambert decreased the final purchase price paid for IMED from $480 million to $465 million. In these circumstances, Henry's plea of ignorance does not ring true. Henry's involvement at the top level of IMED and in the Warner-Lambert negotiations undermines his plea of ignorance, and we so find. Cf. United States v. Aleman, 728 F.2d 492, 494 (11th Cir. 1984); United States v. Jewell, 532 F.2d 697, 700 (9th Cir. 1976) (defining "`wilful blindness'").
In Cramer v. Commissioner [Dec. 49,299], 101 T.C. 225 1993), we decided Cramer, Boynton, and Monaghan were liable for additions to tax for negligence because they deliberately disregarded rules and regulations. In that opinion, it was indicated that Boynton was aware of the potential risk that the Commissioner might challenge the treatment of the stock option proceeds because of his close friendship with Cramer and Monaghan. "Cramer and Monaghan would have had to have actively misled Boynton for him to have been unaware of the risk associated with his 1982 tax return position", and this event was unlikely to have occurred "in view of * * * [the taxpayers] friendship and business relationship". Id. at 253.
Although Cramer referred to Henry as "the one outsider" on IMED's board, he met with Henry on a daily basis and occasionally went out to dinner with him. Also, Henry was involved in the negotiations regarding the sale of IMED to Warner-Lambert and was one of the four IMED executives who were delegated to pursue the sale negotiations with Warner-Lambert, Henry and the other top level IMED officers possessed significant amounts of the 1981 options. The potential value and possible tax treatment of the options to the IMED officers was certain to be a prominent topic of conversation. We find it difficult to believe that IMED's chief financial officer would not be privy to this and/or be oblivious to the concerns of the other officers, who, along with Henry, ran IMED. Henry may have entered the top echelon of IMED after Cramer and his nucleus of associates, but he was not an "outsider" regarding IMED's daily business operations.
Respondent's determination that petitioners were negligent is sustained. Petitioners' claims of good faith are undermined by the totality of the circumstances. Based on the testimony from Hendrickson, Monaghan, and Douglas, the record demonstrates that Henry was aware of the risks involved in reporting all of the proceeds from the sale of the 1979 and 1981 stock options as long-term capital gain. Moreover, Henry did not provide Douglas with all the information Henry knew about the 1979 or 1981 options. For example, if Douglas had been made aware of the fact that the value of the 1979 options was not zero, that would likely have had a profound effect on the accountant's evaluation of the proper tax treatment of the option proceeds. Finally, the fact that Henry referred Douglas to either Hendrickson or Monaghan if there were any questions regarding IMED's stock option program does not obviate Henry's responsibility to ensure that the 1982 return was accurately filed. See LaVerne v. Commissioner [Dec. 46,544], 94 T.C. at 652-653; Pritchett v. Commissioner [Dec. 32,840], 63 T.C. at 174; see generally sec. 1.6661-6(b), Income Tax Kegs. Accordingly, we hold that petitioners are liable for the additions to tax for negligence.
Substantial Understatement Addition to Tax
Next, petitioners contend that respondent erred in determining additions to tax for substantial understatements under section 6661. Section 6661(a) imposes an addition to tax when there is a "substantial understatement of income tax for any taxable year". As applicable here, the addition to tax under section 6661(a) is equal to 25 percent of the underpayment attributable to the substantial understatement. Pallottini v. Commissioner [Dec. 44,671], 90 T.C. 498 (1988). Petitioners bear the burden of proving that the addition to tax under section 6661 is not applicable. Rule 142(a).
Section 6661(b)(2)(A) defines "understatement" as the excess of the amount of tax required to be shown on the return over the amount of tax actually reported on the return. This understatement will be "substantial" if the amount of such understatement exceeds the greater of 10 percent of the amount of tax required to be shown on the return for the taxable year, or $5,000. Sec. 6661(b)(1)(A).
The section 6661 addition to tax is not applicable, however, if there was substantial authority for the position taken on the taxpayer's return, or adequate disclosure in the return of the relevant facts affecting the treatment of the item. Sec. 6661(b)(2)(B)(i) and (ii).
Petitioners have not contended that there was substantial authority for their reporting position. Petitioners contend that the tax treatment of the proceeds of the sale of IMED's stock options was adequately disclosed in their return as filed. Respondent disputes that petitioners adequately disclosed the item in question.
In Schirmer v. Commissioner [Dec. 44,113], 89 T.C. 277, 285-286 (1987), we explained that the regulations provide for two types of adequate disclosure for purposes of section 6661(b)(2)(B)(ii): Disclosure in a statement attached to the return or disclosure on the return pursuant to the Commissioner's revenue procedures. Sec. 1.6661-4(b) and (c), Income Tax Regs. In addition, we noted that a taxpayer may satisfy the adequate disclosure requirement of section 6661(b)(2)(B)(ii) by providing on the return sufficient information to enable the Commissioner to identify the potential controversy involved.
Petitioners' expert witness, John J. Monaco (Monaco), was previously Assistant Commissioner (Examination) for respondent, where he was an employee for 33 years. Monaco opined that the zero basis reported on the return would be adequate disclosure of the relevant facts. Monaco concluded that such disclosure was sufficient to apprise respondent of the facts and the nature of the potential controversy concerning the tax treatment of the item. Monaco decided that the zero basis "would be a clear indication that the options had been awarded to the employee as compensatory stock options and that no value had been reflected in * * * [Henry's] income either at the time the options were received or at any other time prior to the sale of such option." Monaco stated that there was no other likely explanation for a zero basis. Monaco opined that the zero basis reported on petitioners' 1982 return was sufficient to apprise respondent of the tax treatment of the item in question. Based on his experience, Monaco believed that a return with a reported zero basis for employee stock options and claimed capital gain treatment would be selected for examination.
In the present cases, petitioners' 1982 return identified the property in question and clearly distinguished between stocks and options. 5 Furthermore, the return disclosed the dates the shares and options were acquired and sold, sales price, a basis of zero, and the gain involved. It appears likely that the items reported generated respondent's audit. The information reported was sufficient to apprise respondent of and enable respondent to identify the potential controversy involved here; that is, whether petitioners properly treated the stock option proceeds as long-term capital gain.
5 It should be noted that in Cramer v. Commissioner [Dec. 49,299], 101 T.C. 225, 255-256 (1993), affd. [95-2 USTC ╤ 50,491] 64 F.3d 1406 (9th Cir. 1995), the returns, unlike petitioners', "contained misrepresentations that actually concealed the true nature of the option proceeds"; i.e., a false claim of basis or, in the Boyntons' case, a mischaracterization of the options as stock. See also 64 F.3d at 1415.
We hold that petitioners adequately disclosed the information and are not liable for the addition to tax under section 6661. 6
6 Accordingly, we do not reach petitioners' argument with respect to sec. 6661(c).
Petitioners argue that we should abate interest on the income tax deficiency pursuant to section 6404(e) because of respondent's delay in issuing the notice of deficiency. Specifically, petitioners assert that respondent was dilatory in issuing the notice of deficiency, thus increasing the interest payable.
The United States Tax Court is a court of limited jurisdiction. See sec. 7442; Wilt v. Commissioner [Dec. 32,151], 60 T.C. 977, 978 (1973). New section 6404(g), added to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, 110 Stat. 1452, 1457 (1996), authorizes this Court to review the Secretary's failure to abate interest only with respect to requests for abatement made after July 30, 1996. Because these cases do not involve a request for abatement made after July 30, 1996, we lack jurisdiction to abate interest herein. See Commissioner v. McCoy [87-2 USTC ╤ 13,736], 484 U.S. 3, 7 (1987); 508 Clinton Street Corp. v. Commissioner [Dec. 44,139], 89 T.C. 352, 354 (1987); Coffield v. Commissioner [Dec. 51,494(M)], T.C. Memo. 1996-365.
To reflect the foregoing,
Decisions will be entered for respondent as to the deficiency and the additions to tax under sec. 6653(a), and for petitioners as to the addition to tax under sec. 6661.
- Сколько будет стоить содержание онлайн кассы?
- О применении ККТ индивидуальными предпринимателями - плательщиками ЕНВД и налога при ПСН и о получении вычета на приобретение ККТ
- О применении ККТ, обеспечивающей передачу фискальных данных в налоговые органы, в том числе в отдаленных от сетей связи местностях


text:
Expert Tree Bracing Services in Kent and Surrounding Areas
We are proud to offer our specialised tree bracing services – an excellent method to enhance the safety and stability of your trees, offering a range of solutions tailored to suit each unique situation.
Tree bracing is an essential service that can significantly improve the structural integrity of your trees. It involves installing flexible braces in your trees to strengthen weak limbs and reduce the risk of branch failure. At Advanced Tree Solutions, we have the expertise to assess your trees’ health, identify potential weaknesses, and implement effective bracing solutions.
Why choose Advanced Tree Solutions for your tree bracing needs in Kent? Our team of professional arborists possesses a wealth of knowledge and experience in local environmental conditions and tree biology. We strictly adhere to British Standards (BS 3998:2010) for tree work, ensuring your trees receive the highest levels of care and professionalism.
When you’re searching for “tree bracing services near me” in Kent and surrounding areas, Advanced Tree Solutions stands out due to our steadfast commitment to excellence.
Our aim is to exceed your expectations by delivering top-notch tree bracing services, catering to gardens of all sizes, from small private gardens to large estates. Trust Advanced Tree Solutions to handle your tree bracing needs with professionalism and efficiency.
For reliable, proficient, and professional tree bracing services in Kent and the surrounding areas, look no further than Advanced Tree Solutions. Contact us today, and let us cater to all your tree care needs.

domain: geography


Laser World of Photonics: Civan Lasers claims Innovation Prize
Israeli firm Civan Lasers has claimed the €5,000 Innovation Prize for its Dynamic Beam Laser (DBL) technology at this year’s Innovation Awards, held on the opening night of the Laser World of Photonics, currently underway in Munich, Germany.
The Innovation Awards, now in their third year, celebrate the most innovative products and technologies emerging from the photonics industry.
The winning technology, chosen by an expert panel of judges from 18 finalists and over 50 original entries, also won the category under which it was submitted: Laser systems for industrial production engineering.
At 100kW, the DBL is, according to Civan Lasers, the most powerful single-mode laser developed to date. The laser is designed to offer a more efficient and cost-effective approach to welding, especially in applications requiring the joining of thick sections (25-70mm at atmospheric pressure), such as the production of ships, wind turbines, and oil and gas pipes. The technology could also provide a solution to the numerous welding challenges associated with hydrogen fuel cell production.
The laser uses a method called coherent beam combining, where numerous beams of differing phase are overlapped to produce a wide range of beam shapes at up to megahertz frequencies in real time without the need for moving parts. This enables a single DBL machine to have a welding capacity equivalent to ten times that of other one-pass welding systems, according to Civan Lasers.
It eliminates the need for vacuum furnaces and reduces the time and cost associated with multi-pass welding methods.
According to Civan lasers, the economics of the laser are clear. Welding at feed rate of 10-40mm/sec with only one pass can reduce the total welding time, leading to a welding cost reduction of approximately 30 times. Furthermore, one DBL laser machine can weld with a capacity of x10 other systems, making it attractive for companies that require deep penetration welding.
"In 2019 we were nominated for our 14kW Dynamic Beam Laser, and just a few years later we are now winning the award for our 100kW laser system, so we can only imagine what the future will bring," commented Ami Spira, Marketing Manager at Civan Lasers.
Innovation Award Category Winners
The complete list of Innovation Award category winners (pictured above) are listed below:
Biophotonics and Medical Engineering
Winner: PicoQuant - Luminosa
Also shortlisted: Avantes BV - Pacto spectrometer | Futonics Laser GmbH - 2µm QCW Fiber Laser
PicoQuant’s Luminosa single-photon counting confocal microscope enables the integration of time-resolved fluorescence methods into a researcher’s toolbox. Its software includes context-based workflows that improve the accuracy, reproducibility, and quality of collected data. The system offers new insights into various research areas across life and materials science, such as dynamic structural biology, environmental sensing, cellular membrane mapping, nanovesicle characterisation, single-molecule level chemical reactions, and advanced materials characterisation. The software's predefined workflows and parameter settings eliminate the need for extensive microscopy expertise.
Winner: Ushio - High power 700nm laser diode
Also shortlisted: QUIX Quantum - 20-mode Quantum Photonic Processor | NKT - Koheras ADJUSTIK HP T20
Ushio’s single-mode, continuous-wave red laser diodes (LDs) cover a wavelength range of 660nm to 705nm with 5nm increments and deliver 200mW power. The HL67001DG & HL69001DG LDs offer wide-ranging applications in sensing, biomedical, and quantum technology. These LDs are based on AlGaInP material with a narrow stripe, allowing them to operate up to 75°C with high wall plug efficiency (>30%), and can maintain stable lifetime performance for thousands of hours without degradation. These devices are the world's first to achieve 200mW continuous-wave operation in the single-mode range of 660nm to 705nm using AlGaInP-based material, according to Ushio, while the 705nm LD achieves the world's longest wavelength with reliable lifetime performance, without degrading crystal quality in the active layer due to increasing lattice mismatch.
Optics / Manufacturing Technology for Optics
Winner: Trioptics - OptiSurf with LensGage
Also shortlisted: Trumpf - AI Filter for VisionLine Detect | Edmund Optics - TECHSPEC® 120i Infinity Corrected Objectives
The LensGage module is designed for non-contact centre thickness measurements of single lenses or doublets using low-coherence interferometry. It consists of two glass plates that form a measuring cell, which is used to calculate the centre thickness (with an accuracy of 1.5µm) without knowledge of the material’s refractive index. It can also identify the glass material of unknown lenses by its group refractive index. This process is embedded in the software so that data can be read directly. The LensGage module offers easy switching between traditional measurements by removing the lower glass plate insert. The LensGage is easy to calibrate and its high thermal stability means it can deliver reproducible measurement results.
Sensors, test and measurement / Optical measuring systems / Imaging
Winner: Castor Optics - Thorlabs - 2 Mode Selective Photonic Lantern
Also shortlisted: PicoQuant - Luminosa | Hamamatsu Photonics - OPAL-Luxe High dynamic range spectrometer
Castor’s photonic lantern (PL) is an efficient all-fibre device that enables accurate modal multiplexing and demultiplexing of optical signals between single-mode and multimode fibres. The device provides a one-to-one correspondence between single-mode input and multimode output fibres. The PL ensures near-lossless transmission across a wide wavelength range, with exceptional modal separation (e.g., <0.1dB insertion loss and >30dB isolation). The design offers up to 10 times shorter coupling lengths than alternative designs, allowing it to fit within a standard fibre connector. Its compactness also enables easy integration into optical systems and offers adaptability in network design, leading to cost savings by reducing the need for multiple components. Castor's PL has shown promising results in lidar and non-invasive 3D flow measurements, as reported by early prototype users.
Lasers & Optoelectronics / Illumination and Energy
Winner: Twenty-One Semiconductors - MEXL Gain Crystals
Also shortlisted: ams Osram - SPL S1L90H_3 | Viulase - Tenacity
MEXL Gain Crystals consist of a semiconductor membrane sandwiched between transparent heat spreaders – a design which combines semiconductor gain and the open cavity concept to enable Watt-level visible lasers for flow cytometry and fluorescence microscopy. The gain chip features high-quality coatings and gold-plated surfaces for easy integration while the linear pump geometry and broad absorption of the semiconductor structure have minimal wavelength and mode quality requirements. Optical elements can be inserted in the open cavity for tailored emission properties, including narrow linewidth operation. MEXL crystals can be scaled from a few mW to multi-Watt levels. Optically-pumped membrane lasers based on MEXL crystals offer low noise operation, excellent beam quality, direct modulation, and wavelength tuning. According to Twenty-One Semiconductors, MEXL outperforms other technologies in the green-yellow and orange range in terms of laser properties, simplicity, and cost-effectiveness.
Laser systems for industrial production engineering
Winner: Civan Lasers – DBL 100 KW (see above)
Also shortlisted: Scanlab - SCANMotionControl | Fusion Bionic - CORE - Flexible manufacturing solution for biomimetic surfaces using Direct Laser Interference Patterning


text:
Updated from 10:43 a.m. EDT
JDA Software Group
rose 23% in Friday late morning trading on news that the company's first-quarter results will exceed Wall Street's expectations due to better-than-expected revenue from software licensing.
The stock was up 3 3/8 to 18, after an increase of 102% in the last year. (JDA closed up 2 13/16, or 19%, at 17 7/16).
The company, based in Scottsdale, Ariz., did not quantify the amount of the expected earnings per share gain, but the consensus estimate of analysts polled by
First Call/Thomson Financial
is 3 cents.
However, JDA did indicate that their software revenue will come in at about $15 million, more than double the $7.4 million booked by the company in the same period last year.
JDA will report its results after the market close on April 20.
JDA creates management information systems -- for both corporate and in-store use -- for more than 740 retailers worldwide such as
Petco Animal Supplies

domain: finance


text:
Everyone is looking to get healthy, to achieve their own diet plan. Whether it’s to lose a few pounds, look better at their wedding, fit back into their favorite dress or just to add a sparkle to their look.
First a disclaimer. Scientifically and medically, there’s no such thing as “it works for everyone.” But this has worked for many and most of the healthy-ish general population.
The 2-3 Diet
The secret to living a long and healthy life is all about following a standard healthy eating routine. Vitamin and mineral-rich foods can keep you healthy and fit, enjoying your life to the fullest. While it is commonly believed that eating high-calorie and high protein foods like meat and eggs are important for living a long life.
The secret here is 2 fruit per day and 3 vegetables. Simple, right?
Why you should try it?
Studied confirm the secret to longevity lies in a nutrition plan involving more fruits and vegetables. Correct. Not meat or chicken-based. But rather leafy greens and fresh fruits to help enhance your system and prevent aging.
Want a diet to live longer?
A new study released in March 2021 by the American Health Association and conducted by researchers at Harvard TH Chan School of Public Health showed eating a balanced amount of fruits and vegetables can help us live longer.
A daily nutrition plan of two servings of fruit and three servings of vegetables lowers aging symptoms.
While so many others create complicated plans and struggle to keep up. The 2-3D Diet plan is simple, affordable and works.

domain: medical


text:
16 Trending Jobs for Creatives (With Duties and Salaries)
The Indeed Editorial Team comprises a diverse and talented team of writers, researchers and subject matter experts equipped with Indeed's data and insights to deliver useful tips to help guide your career journey.
There are many well-paid careers available for people who want to use creativity in their day-to-day work and take advantage of their talent, interest and passion for art. From marketers and public relations specialists to tattoo artists and illustrators, job opportunities in the art world are limitless. If creativity is your strength, you may consider pursuing a career in one of those industries. In this article, we list 16 trending jobs for creatives, explain their main responsibilities and explore how much you could make in those professions.
16 best jobs for creatives
Here's a list of 16 jobs for creatives that you may consider if you'd like to pursue a career in the art world:
National average salary: £6.70 per hour
Primary duties: Actors are creative professionals who perform on stage or star in films and TV programmes. Their responsibilities include researching their characters, memorising scripts and learning songs or dances. Actors who are actively preparing for a premiere regularly attend rehearsals. They typically work with other actors, directors, costume designers, makeup artists, stage coordinators and other professionals who collaborate to make a play or film successful.
National average salary: £21,050 per year
Primary duties: Stylists are typically freelancers who choose outfits for people for a living. As a stylist, you may choose to work with individual clients, such as senior business employees, helping them find clothing for special occasions or business attire. You may also choose to work on sets, choosing outfits for actors, presenters and other performers. To increase your chances of succeeding in this profession, you may consider learning about colour theory, beauty types, textiles and how to find flattering outfits for different body types.
National average salary: £23,881 per year
Primary duties: Photographers are skilled professionals whose main responsibility is to organise photo shoots and take pictures of people, products, places or other things. They have extensive knowledge of photography techniques and equipment, cameras or lighting. Becoming a photographer may be perfect for someone who wants to use their creativity at work and combine it with very specific soft and hard skills, such as communication and time-management skills or the ability to use professional editing software. There are many specialisations available for photographers, including interior or product photography.
National average salary: £26,486 per year
Primary duties: Primary duties of a fashion designer include following fashion trends, collaborating with the design team to develop new ideas and styles that consumers would like and preparing sketches of seasonal clothing collections. It's possible for fashion designers to work independently under their own brand or name. Many successful designers find employment as lead designers at luxury fashion houses or casual fashion brands. They typically work in a creative work environment and regularly collaborate with manufacturers, suppliers or models.
National average salary: £14.67 per hour
Primary duties: Painters are artists who focus on creating works of art on different surfaces, including canvas, wood or glass. They need extensive knowledge of painting techniques and paints, including oil, acrylics, watercolour or gouache. Some painters work on commission, delivering works of art that are portraits or landscapes. Painters who focus on their unique style and vision typically sell their works at art auctions or to art galleries.
National average salary: £28,631 per year
Primary duties: Illustrators are creative professionals who, unlike painters, typically use digital tools to create their works. They commonly create illustrations for magazines, book covers, company logos or other elements of brands' visual identities. Most illustrators are self-employed freelancers who work for multiple clients, but it's also common for them to sell illustrations as prints under their own name.
National average salary: £30,503 per year
Primary duties: Typically, editors are skilled writers who have extensive knowledge of one or more languages. They work alongside copywriters and content creators, making sure the texts they deliver meet project guidelines and other requirements. Many editors are responsible for improving and revising content to make it ready for publication in books, newspapers or on websites.
National average salary: £31,497 per year
Primary duties: Social media managers use their creativity to research, plan and execute marketing and content strategies for their clients or the brand they work for. Their day-to-day responsibilities include analysing online community demographics, creating a content calendar, scheduling and publishing posts on social media profiles. Many social media managers work at marketing agencies alongside other marketing executives, graphic designers and copywriters.
National average salary: £31,630 per year
Primary duties: Typically, advertising specialists work at creative agencies, working with clients to promote their products or services. Modern advertising specialists are digital experts who can design and implement effective social media or ad campaigns. They coordinate communication and media strategies to ensure client satisfaction and increase their revenue or build online communities for them.
National average salary: £35,191 per year
Primary duties: Interior designers are creatives responsible for helping clients and investors finish and decorate a place. This typically includes private flats and houses or public spaces, such as stores or offices. Their duties involve creating a creative concept, creating realistic 3D renders of rooms and working alongside contractors and suppliers to ensure interiors are finished according to the project. To succeed in this profession, they need excellent communication and organisational skills and expert knowledge of textiles, materials, colours and interior design trends.
Related: How To Become an Interior Designer
11. Brand manager
National average salary: £36,692 per year
Primary duties: Brand managers are responsible for designing and adapting a brand strategy to meet the expectations of the brand's target market. With their efforts, they maintain a brand's identity and ensure consistency of its communication channels. It's common for them to work within marketing teams and collaborate with marketing specialists, including content managers or graphic designers.
12. Tattoo artist
National average salary: £37,857 per year
Primary duties: Tattoo artists' primary duties involve designing tattoo concepts, sketching projects and tattooing clients. They're also responsible for sterilising and cleaning equipment and their tattoo stations or booking appointments. Many tattoo artists regularly go to tattoo conventions to keep up with the latest trends in the industry, network with other artists and participate in various contests to promote their work.
National average salary: £38,169 per year
Primary duties: Public relations officers typically work at PR agencies. They're responsible for designing and implementing creative communication and promotional campaigns for clients, such as celebrities or brands. It's common for PR officers to choose a narrow specialisation, which allows them to position themselves as experts within certain niches or industries. Common PR specialisations include music, fashion or lifestyle PR. On a daily basis, PR officers draft and send out press releases, meet with clients to present campaign ideas to them and communicate press information to the media.
National average salary: £20.24 per hour
Primary duties: Singers are stage entertainers whose primary duties include learning, memorising and performing songs. Similarly to actors, their daily responsibilities involve attending rehearsals to prepare for concerts and premieres. Most singers work with managers, producers, dancers, producers and other musicians. It's common for them to travel regularly and go on national or international tours to promote releases of their albums and other musical projects.
15. UX designer
National average salary: £43,514 per year
Primary duties: UX designers are digital creatives whose duties include designing online experiences for application users and website visitors. They regularly meet with clients to consult project ideas and present website or app concepts to them. Most UX designers work alongside UX researchers, graphic designers and web developers. They perform usability tests and create wireframes, storyboards or sitemaps.
National average salary: £72,634 per year
Primary duties: Marketing directors are senior creatives typically responsible for leading marketing agencies and managing a team of marketers, advertisers and content creators. They're typically marketing generalists with years of experience in the field who have extensive knowledge of all areas of marketing and advertising. To succeed in their role, they need excellent leadership, active listening and communication skills. It's also good for them to have great negotiation and analytical thinking skills.
Salary figures reflect data listed on Indeed Salaries at the time of writing. Salaries may vary depending on the hiring organisation and a candidate's experience, academic background and location.
Explore more articles
- What is interior design? (Job roles, skills and salaries)
- How to become a lyricist: definition, duties and skills
- How to become an information system manager (with tips)
- Job hunting tips to help you find your next job
- What does a historian do? (Plus salary and skills)
- 8 Renewable Energy Careers (Descriptions and Salaries)
- How to become an office administrator: a complete guide
- How to get into freelance programming (with steps and tips)
- How to become a qualified accountant (definition and steps)
- What qualifications do you need to be a director in film?
- A Guide to the 14 Best-Paying Jobs in Tech (Plus Duties)
- What is diversity hiring and why is it important at work?

domain: artistic


text:
You are using an outdated browser. Please upgrade your browser to improve your ReverbNation experience.
The Space Cadets, formed in 2011, just as a group of friends jamming together. Their musical direction has thus emerged from an initial concept of incorporating different genres and playing styles to create an entirely new sound. They have since dedicated their time to performing and studio recording.


text:
Scientex Conferences organize world conferences to give a platform for exhibiting cutting-edge discourses, which bring in a wide range of medical advances, scientific discoveries, and downsides in both.
It’s our pleasure to invite you all to take part in a virtual conference “International Webinar on Breast Cancer and Therapeutics” which has been scheduled on December 07-08, 2023 at Dubai time (GMT+4) through the Zoom platform. The conference goes around the vibrant theme “Congregation of the Recent Revolution and Medicaments of Breast Cancer”.
The overall purpose of the Breast Cancer Congress webinar is to bring all of the world's surgical and clinical oncologists, gynecologists, cancer science specialists, radiation oncologists, academics, bloggers, scientific experts, research scholars, breast cancer surgeon executives underneath the tower to convey their existing study results, share opinions, and illustrate their thoughts & feelings from all the perspectives of Women's Nutrient and breast cancer.
Webinar Scientific Sessions
- Breast Cancer...
- Breast Cancer Therapies & Trea...
- Women’s Health and Nutrients...
- Male Breast Cancer ...
- Breast Cancer-Clinical Trials...
- Breast Cancer Radiology...
- Breast Cancer During Pregnancy...
- Breast Cancer- Risk Factors & ...
- Screening & Diagnosis for Brea...
- Breast Cancer Symptoms and Cau...
- Chemotherapy for Breast Cancer...
- Breast Cancer Surgery...
- Reconstruction of Breast Cance...
- Breast Pathology Treatment and...
- Gynecology ...
- Metastatic Breast Cancer...
- Optimal Breast Cancer Patholog...
- Immunotherapy of Breast Cancer...
- Biology of Breast Cancer...
- COVID-19 Impact on Breast Canc...
- Robotic Breast Oncology ...
Who Can Attend?
• Cancer science specialists
• Clinical and medical oncologists
• Breast Cancer Surgeon
• General surgeon
• Radiation oncologist
• Plastic surgeon
• Physician and Doctor
• Lymphologist or Lymph specialist
Why You Must Attend?
The Breast cancer congress 2023 aims to create awareness and convey medical skills about new technologies on Cancer Science
• Can get recent innovation ideas on Breast Cancer
• Can unite with Cancer Science specialists through online
• Can showcase your most advanced ideas through a virtual platform
• Attendees can fetch with the following benefits, reach the wider audience, meet skilled specialists and influencers face to face, networking opportunities.
• Can grow your skilled networking, new tips & ways.
Breast Cancer Congress 2023: WHEN, WHAT AND WHY?
Webinar Name: International Webinar on Breast Cancer and Therapeutics
Theme: Congregation of the Recent Revolution and Medicaments of Breast Cancer.
Date: December 07-08, 2023
Time Zone: GMT+4 (Dubai time)
Platform: Zoom Meet
• Get an opportunity to meet renowned scholars
• Chances to Interact, & Forge Powerful Professional Relationships
• Access to All Sessions Online E-Handbook kit E-Certificate Accreditation from the Organizing Committee
• Online publication of Abstract and Biography on our website
• 10% abatement on the registration fees for the next annual conference
Guidelines for Joining Webinar:
• After register for the webinar, you will receive a meeting invite link with personalized user ID one day before the event for webinar access.
• Follow the steps provided in prior, for preventing any technical issues on day of the event.
• Please join the webinar 15 minutes early to eliminate the last-minute hassle.
• Ensure that your device meets the system requirements for running the specific application.
• For audio/video clarification, it is always better to attach an external device.
What Will Be Discussed?
• Medical devices innovation in Breast Cancer
• Diagnosis and monitoring of cancer patients in healthcare
• Treatment and therapies for Breast Oncology
• Complication of stage fourth Breast Cancer
• COVID19 impediment in Breast Cancer department
• Current trends in Breast Cancer surgery


Model Saskia de Brauw appears hand-in-hand with male model Sung Jin Park in Bottega Veneta's spring 2015 ad campaign. Japanese photographer Nobuyoshi Araki shot the images in Tokyo.
"More than simply provocative, Araki's images have a powerful honesty and human poignancy that make them unforgettable," the brand's creative director, Tomas Maier, told WWD.
"He has his own visual language, which I was very excited to see translated to the collection," Maier added.
You can view an image from the ad campaign here.
The campaign is set to launch in the February issues of international fashion magazines.
Other renowned photographers — including Ryan McGinley, Pieter Hugo, Nan Goldin, Stephen Shore and David Sims — have also shot ad campaigns for Bottega Veneta.
In related news, back in October, Maier opened his first eponymous boutique in Manhattan. The New York location utilizes 2,800 feet of selling space featuring his entire lifestyle concept, oak floors, bronze details and display pieces designed by Maier himself.
"We wanted to open here for a long time," Maier told WWD back in October.
"In all the three stores we have had [Palm Beach, East Hampton and Miami, which has closed], we always had New York clients," he added. "So it was important to have a store in the city. Thanks to our joint venture, we are now able to do this."
Maier didn't comment on the Manhattan store's sales projections, but they are expected to be higher than his other locations in Florida and the Hamptons, which do not present year-round opportunities for sales.
The main floor of the boutique also features many accessory collaborations — including one-of-a-kind rope mirrors created by Christian Astuguevieille, semiprecious earrings from Maier's friend Osanna Visconti, semiprecious beaded necklaces by Florian and hats by Mühlbauer. Additionally, there is a display of candles created in collaboration with Diptyque.


Dewatering pumps are useful for removing waste water from excavations and trenches. If you are looking to buy dewatering pumps, then think about Darling Pumps. Darling Pumps is a leading manufacturer of smart pumping solutions such as submersible dewatering pumps. We are well known in the market for offering SMART pumping solutions. Our main focus is on the quality and reliability of pumps. For any assistance, call us at +91 99819 92833.We’d love to serve you in the best possible manner.


text:
It's big, beautiful and unbreakable: the Voopoo Argus X Pod Mod Kit!
The Argus X accepts a single 18650 battery (not included) with a 4.5ml capacity PnP Pod and up to 80w of output wattage. As with the rest of the Argus line, this one's got plenty tough leather or PCTG backing and an even tougher zinc alloy shell to keep it safe on the go anywhere.
The Argus X is completely and fully compatible with the range of PnP coils, well known for being absolute guardians of flavour and long lifespans. Down below the pod is your airflow slot, and you can easily adjust your flow by rotating the pod above to your liking.
Just as with the usual PnP Pods, each one is filled from the bottom by a silicone suction valve to avoid any messiness. To change coils over is just a simple plug and pull in and out whenever you need!
The X also brings along a very cool anti-drop cover for the pod, just in case you would somehow manage to crack these already tough PCTG pods. This one's for the professional vapers (not literally), so toughen up with an Argus X today!
- Dimensions: 128 x 35 x 30.5mm
- Materials: zinc alloy shell, leather / PCTG backing
- Battery: 1 x 18650 (not included)
- Capacity: 4.5ml
- Wattage Range: 5 - 80w
- Resistance Range: 0.1 - 3ohm
- Voltage Output: 3.2 - 4.2V
- PnP-VM6 Mesh 0.15ohm: 60 - 80W
- PnP-VM1 Mesh 0.3ohm: 32 - 40W
- Compatible with ALL PnP Coils plus both MTL and regular PnP Pods
- New leather backed designs for ultimate hand feel and comfort
- Pod encased at the base to avoid damage from accidental drops
- Newest Gene.TT chipset with fantastic performance and efficiency
- Infinite Airflow adjustment under pod for the perfect intake
- Bottom filled, plug pull coil replacement pod
What's in the box:

domain: hobby


text:
The leader of the team that found the Titanic at the bottom of the North Atlantic in 1985 announced yesterday that he would return to the wreck as part of a federal expedition to assess its deterioration and study new methods of preservation.
Hundreds of tourists and salvagers, explorers and moviemakers, have assailed the Titanic since the team of American and French scientists discovered its resting place more than two miles down. Partly as a result, the vessel, the world's most famous shipwreck, is rapidly falling apart.
''The world's oceans are the museums of the deep,'' said the team's leader, Dr. Robert D. Ballard. ''It is in the interest of all peoples to protect and conserve both wrecks of recent history as well as submerged sites of antiquity.''
In late May, Dr. Ballard is to join with the National Oceanic and Atmospheric Administration on an expedition to the sunken liner, which went down on April 15, 1912. It now lies in international waters 380 miles off Newfoundland, upright but split in two. The goal is to spend 11 days hovering over the hulk and lowering tethered robots to map its remains and their state of decay.

domain: news


Google I/O 2023 kicked off today, and there were quite a lot of exciting announcements at the event. While the keynote touched on just certain topics, there was still plenty to talk about, and many awesome new products and services were shown off.
It wasn't a short keynote, so to save you the trouble of having to sit through the full two hours, we are highlighting some of the biggest announcements from Google I/O so you can get excited with us (we'll still link the video at the bottom if you really want to watch it).
Artificial Intelligence is everywhere
As you might have guessed, AI was everywhere during the event, to the point where there's now a supercut of Sundar Pichai saying "AI."
During the event, Google announced a number of ways that AI will enhance its products, from the new Magic Composer in the Google Messages app to the cool new features coming to Google Maps and Photos. Google also took the time to highlight the new Duet AI-powered features arriving on Workspace apps like Docs, Sheets, Slides, and more. With these new features, Google can help users compose content, organize plans, and generate images from words.
And for those of you interested in trying out Google Bard, the company has now removed the waitlist, so now everyone can play with the upgraded chatbot. And while a standalone Bard app isn't happening, Google is integrating it into various apps and services like Adobe Firefly.
Google Search, supercharged
It's been long speculated that Google would integrate generative AI into Search to challenge Bing/ChatGPT. After all, AI has been a big part of Search for a long time (why do you think it's so good?). At I/O, Google revealed a new Search experiment that will let users test out its generative AI. This should allow Search to gain a better understanding of longer-form questions while providing an easy-to-read snapshot of important information that could potentially save you from constantly scrolling for the right answer.
The new Search experience isn't available yet, but you can sign up now for the waitlist through the Google app.
Android 14 and Wear OS 4!
Android 14 has been in beta for some time now, but Google talked a bit more about the upcoming update and more of the features we can expect. For instance, users are gaining more Material You customizations for your lock screen and wallpaper, and something called "Ultra HDR" should really make your photos pop. There are also a host of new privacy features, improved predictive back animations, and more.
But that's not all. Google also took the time to tease the upcoming Wear OS 4 update. With it, the company promises better battery life, improved accessibility features, better watch faces, and finally a backup and restore feature. Some long-awaited apps are also on the way, such as Gmail and Calendar.
We're still not sure what watches will be eligible for the update, which is a big question since Mobvoi is still having trouble with Wear OS 3. Hopefully, we'll get more information soon.
Google's Pixel Fold is finally coming
One of the most exciting hardware launches was the Pixel Fold. It had been rumored for some time, and after many leaks, the foldable is finally here. And it's gorgeous. Say what you will about foldable phones, but the Pixel Fold is truly a looker and might even put all the other foldable phones to shame.
The phone sports a Tensor G2 chipset, a wide 7.6-inch folding screen, a smaller 5.8-inch external screen, and a 48MP triple camera setup on the back. And thanks to Google's efforts to improve the Android experience on larger screens, Android 13 looks great and works great on the Fold, particularly when it comes to things like multitasking.
As the only folding phone to really challenge Samsung in the U.S., we can't wait to really put it through its paces to see if it's worth the $1799 price tag.
The Pixel 7a offers an incredible value
We were impressed by the Pixel 6a last year, but Google stepped things up quite a bit with the Pixel 7a. Sure, it's a smidge more expensive, but you're getting upgraded cameras, a new 90Hz AMOLED display, the flagship-level Tensor G2 chipset, and the same upgrade promise Google gives to its best phones.
There's a lot to like about the Pixel 7a, including its stunning Sea and Coral colorways, which really stand out. And at just $500, it really puts some other cheap Android phones to shame. Heck, it makes the iPhone SE (2022) look incredibly dated.
Pixel Tablet transforms your idea of a smart home hub
While we didn't get a new Nest Hub, Google launched literally the next best thing: the Pixel Tablet. It's an Android 13 tablet with an 11-inch display that does all the things you expect a tablet to do. But Google gave the tablet a new purpose by including a charging dock. This way, it transforms into a smart display, allowing you to control your smart devices while still being able to interact with your favorite apps.
The best part is that with Chromecast built-in, you can easily cast your content to the Pixel Tablet while it's in hub mode, making it easy to really jam out with the charging dock's powerful speaker.
Google Home gets a long-overdue overhaul
The Google Home app has been undergoing renovations lately, and Google is finally ready to reveal the newly improved app to everyone. With the update, Google Home is more visually appealing, customizable, and useful. You can now have your most-used controls front and center, so you don't have to dig to find your thermostat or lamp.
Camera support has been greatly improved, so not only can you bring your old Nest cameras into the app, but they're now as much as 38% faster in the Google Home app. Wear OS devices also gain new features, such as camera and door lock controls, enhanced notifications for doorbells, and more.
The new Google Home experience will roll out to everyone starting May 11.
Magic Editor is Google's next mind-blowing photo editing tool
There's a lot to love about Google Photos, but one new feature really blew our minds during the keynote. Google demoed "Magic Editor," which takes the Magic Eraser we know and love to another level. Instead of simply removing an object or person from a photo, Magic Editor will let you do things like make the sky brighter or move the subject from one position in the photo to another. It can really give your images a whole new look.
The feature will be available on "select Pixel phones" later this year for users to test the feature out and provide feedback. We hope it will eventually come to other Android phones like Magic Eraser did.
Find My Device gets an upgrade
Google is supercharging its Find My Device feature in order to help users locate devices, even if they're offline or don't support location services. Soon, the new Find My Device network will tap into other Android phones in order to locate a device that may be too far from you.
"The new Find My Device network will harness over a billion Android devices across the world to help you locate your missing belongings like headphones, tracker tags, or even your phone via Bluetooth proximity."
Google says it's also working with companies like Tile, Chipolo, and Pebblebee, who will be able to tap into the Find My Device network.
In addition, Google will also enable a new feature that will alert users if an unknown tracker is following them. This comes not long after Apple and Google announced a joint effort to tackle unwanted tracking.
There's still so much left to digest
Everything announced during the keynote was just the tip of the iceberg. Google I/O has tons of sessions and workshops that provide updates on other topics Google didn't talk about at the keynote or even give deeper insight into things that were talked about.
We'll be diving into these sessions to see what additional updates Google has in store for us throughout this next year.
Be an expert in 5 minutes
Get the latest news from Android Central, your trusted companion in the world of Android
Derrek is a long-time Nokia and LG fanboy who loves astronomy, videography, and sci-fi movies. When he's not working, he's most likely working out or smoldering at the camera.
I saw the news regarding Apple and Google working on bluetooth tracker detection - which is great, but I have not seen anything new regarding the rumored Google tag (maybe a Next branded device) that would be a competitor to the Apple Airtags and fully supported on Android.Reply
Is there any news on the Google trackers, or is that coming later this summer or fall?


A wide variety ofstone grading machineoptions are available to you, such as new. You can also choose fromegypt, none, and canadastone grading machine, as well as from easy to operate, long service life, and high-accuracystone grading machine, and whetherstone grading machineis building material shops, hotels, or manufacturing plant.Get Price
You can send a message to us by this email [email protected]
Your email will only for contact and not be shared with any third parties.
Reconditioned Eagle Stonekor G&P One ConcreteGrinder& Polisher. The G&P One Eagle by Stonekor is all about productivity. It is a solidGrinderand Polisher. No need for two concretegrinder machineson site, just one G&P One. A hefty, 1,300 lbs of concretegrindingmuscle, ta...Get Price
Get the best deals on ValveGrinderAutomotive Shop Equipment when you shop the largest online selection at eBay.com. Free shipping on many items ... Sioux Tools Inc. 680 Valve FaceGrinding Machine Grinder. $850.00. Brand: Sioux. 16 watching. Type: ValveGrinder. ... ValveGrinder Stonefor Black & Decker, Van Dorn, Sioux, Thor, 80 Grit 5 ...Get Price
Demo Eagle Stonekor Rejuvenator Concrete Grinder. The Rejuvenator 3000 offers 4-in-1 capabilities to strip all floor finishes and restore worn or damaged polished concrete floors. The Rejuvenator achieves this versatility using four different attachments in thre...Get Price
stonebreakingmachine stonejaw crusher 86 . usedstonecrushermachine GrindingMill fromstonecrushermachines,stonecutting 86.5%machinein . Small Rock Crusher supply slurry dewatering equipment. small rock crusher for gold in malaysia rock goldgrinding machine(86 ) separatormachine(86 .source from . FoodGrindingAnd . Get PriceGet Price
A wide variety ofstone grinding machineoptions are available to you, such asstone grinding machine. There are 37,251stone grinding machinesuppliers, mainly located in Asia. The top supplying countries or regions are United States, China, and India, which supply 1%, 99%, and 1% ofstone grinding machinerespectively.get price. Chat OnlineGet Price
Grain mills can help you save loads of money on grains by allowing you to buy whole grains in bulk and grind your own instead of buying more expensive packaged pre-ground grains. It can also be healthier to grind your own whole grains fresh rather than grains that have been potentially treated with preservatives and left in storage for long ...Get Price
StoneCuttingMachineThe key parts of the bridgestonecuttingmachineare all from high quality suppliers. Thestonecuttingmachinehas high cutting efficiency, high cutting precision, high stability and easy operation, which is suitable for all kinds ofstoneprocessing factories.Get Price
The American-made Hi-Tech Diamond 6" All-U-Need is a flat lapmachinethat is one of the best available on the market. Easily grind, shape and polish rocks to make cabochons for necklaces, earrings, rings and other jewelry pieces, or, polish synthetic material and metals on the All-U-Need.Get Price
Think ofStone Grindinglike a dermabrasion or “facial” for the ski base. Thegrindingprocess carefully removes the damaged & hardened layer of base, removes scratches, other imperfections & debris and exposes a virgin surface which will avidly absorb wax through freshly opened pores.Get Price
Spiral separators, which are also called spiral concentrators, are gravity devices that separate minerals of different specific gravity according to their relative movement in response to gravity, centrifugal force and other forces in the fluid medium.
The ball mill is one of the most widely used super fine grinding machine in the industry and it is the key grinding equipment after materials have been crushed.
The convery belt is mainly composed by the expansion cylinder on both ends and the closed belts tightly knotted on them.


Party Smasher Inc. – the new musician / illustrator / photography site created by Dillinger Escape plan’s
Ben Weinman – has released a new video interview with actor Madds Mikkelsen, in which he discusses horror movies, classic rock, and more. Check it out below, and Party Smasher also comments:
“Mads Mikkelsen is the Danish actor currently killing it (literally) as Hannibal Lector on the hit show Hannibal. Perhaps it was his bloody eyed role in the James Bond film Casino Royale, that showed us just how creepy this guy could be. What most people don’t know, however, is that he was originally a gymnast and dancer. The guy can KICK!
“Check out this one-on-one with Elliot of Little Punk People where Mads talks about his love for classic rock, horror movies, and getting over the nerves of playing one of our generation’s most iconic villains.”


text:
Published April 2007
by Child"s Play International .
Written in English
|The Physical Object|
|Number of Pages||16|
Lucille Colandro has written many books for children including the There Was An Old Lady series illustrated by Jared Lee. Jared Lee has illustrated more than books for young readers. He has received awards from the Society of Illustrators, the Martha Kinney Cooper Ohioana Library Association, the National Cartoonists Society, and others/5(). There are a series of these "Old lady swallowed " books. This one is exactly the same as all the others. An old lady swallows a bunch of parts, then coughs up something more complete. This is the Christmas version. She swallows bells and holly and stuff and coughs of Christmas, basically. There is nothing overly redeeming about it/5(91). There Was An Old Lady Who Swallowed A Shell This is a funny book. It make you want to keep reading so you can find out what eventually happend at the end. This book teach children of items you find at the beach. It teachesr Rhyming words, new vocabulary words and has lots of repititions/5. This is the sturdy board book edition of this prequel to "There was an Old Lady who Swallowed a Fly". The Old Lady returns to swallow a number of sea creatures increasing in size, which you can follow through die cut holes.4/5(30).
13 rows The complete series list for - There Was an Old Lady Lucille Colandro. Series reading . Printables for Books Day Activities All About Me Alligators/Crocodiles Apples Around the World Art Baker Baseball Sea Seals on the Bus Self Awareness Senses-Five Senses Sesame Street Shapes There was an Old Lady Who Swallowed a Shell There was an Old Lady who Swallowed Some Leaves. Pam moved into writing with the ‘Mrs Honey’ series. Her attractive artwork, sense of humour and great versatility made her an invaluble member of the Child’s Play team. Pam work for Child’s Play for nearly forty years, illustrating her final book, a prequel to ‘There was an Old Lady who Swallowed a Fly’ in Format: Paperback. The book "There Was an Old Lady Who Swallowed the Sea" was in excellent shape and the childen enjoyed it. The CD had scratches on it but it did not skip. Read more4/5(30).
Her first book ‘There was an Old Lady who Swallowed a Fly’, published in , is still Child’s Play best selling title. Her bright, clear colours, appealing shapes and attention to detail make her pictures instantly successful with children/5(K). This book is another spin off of the original story "There was an Old Lady Who Swallowed a Fly". The book starts off with the old lady swallowing some books. It continues with her swallowing all different kinds of school supplies/5. There Was an Old Lady Who Swallowed the Sea - book, teaching resources, story, cards, mat, sequencing, primary resources, play, Early Years (EYFS), KS1 & KS2 Primary Teaching. " There Was an Old Lady Who Swallowed a Tie " (also known as "I Know an Old Lady Who Swallowed a Fly" and "There Was an Old Woman Who Swallowed a Fly") is a children's rhyme and nonsense song of a kind known as cumulative. The song tells the nonsensical story of an old woman who swallows increasingly large animals, each to catch the previously.

domain: literature


text:
Hairy Commelina Commelina benghalensis is an annual or sometimes perennial herb, also known as Bengal Dayflower and Tropical Spiderwort. Stems have a high moisture content. Once well rooted the plant can survive for long periods without moisture availability and can then grow rapidly on the onset of rains. An aggressive weed that produces aerial (above ground) and subterranean (below ground) flowers. This results in viable seed being produced both above and below ground. Will also root at the nodes and can be propagated from cut stems. Tolerance to glyphosate has been documented. Light cultivation can often break plant parts and increase the area of infestation. Commelinaceae named for 17th century Dutch botanist Jan Commelin.
Photo: Robert Whyte
Brown Hairs, Hairy Fused Spathe
Confusion can occur with a number of other Commelina species, but the following combination of characters may be used to distinguish C. benghalensis – all three petals blue, leaves broadly elliptical (length up to twice width only), spathe sealed to form triangular pocket, seeds rugose, presence of stolons, leaf sheaths with reddish-brown-tipped hairs. C. diffusa, the commonest of other species, has blue petals, but the spathe is open along one edge, leaves are narrower, seeds are smooth, and there are no stolons. C. forskalaei has stolons and rough seeds, and the spathe is sealed, but the leaves are narrower, and their length is up to four times the width, and wavy-edged (Holm et al 1977, Drummond 1984). None of the other weedy species have brown-tipped hairs. Hence this is an especially useful character when looking at vegetative material. SOURCE: North American Plant Protection Organization (NAPPO)
Note brown-tipped hairs and fused hairy spathe. Photo: Robert Whyte

domain: biology