text:
Docket Nos. 2258-65 3128-69.
Jules I. Whitman and Richard L. Levy, for the petitioners. Dennis C. DeBerry and Howard Gordon, for the respondent.
Jules I. Whitman and Richard L. Levy, for the petitioners. Dennis C. DeBerry and Howard Gordon, for the respondent.
Held: 1. The mere filing of a suit by the seller to rescind the sale of stock did not postpone the realization of taxable gain.
2. Neither the acquisition by the seller of options to purchase a part of the stock sold nor the receipt of the stock on the exercise of the options resulted in a rescission of the sale.
3. The sale did not involve a criminal appropriation of the petitioner's stock.
4. The petitioner did not restore an amount held under a claim of right when he exercised his options.
5. In the absence of a finding of theft or fraud, counsel's fees and other costs incurred by the seller did not give rise to a deduction on account of a ‘theft’ loss.
The respondent determined deficiencies in petitioners income tax as follows:
+----------------------------------------+ ¦Docket No. ¦Taxable year ¦Deficiency ¦ +------------+--------------+------------¦ ¦ ¦ ¦ ¦ +------------+--------------+------------¦ ¦2258-65 ¦1960 ¦$991,127 ¦ +------------+--------------+------------¦ ¦3128-69 ¦1961 ¦108,750 ¦ +----------------------------------------+
The deficiencies determined by the respondent in the instant case arose out of the purported sale by Mr. Karl Hope of 206,400 shares of stock of Perfect Photo, Inc., on July 27, 1960, and reflect the fact that the respondent took an inconsistent position with respect to the year of accountability for, as well as the amount of, the income realized on the sale.
The respondent conceded at trial that counsel's fees of $10,000 were deductible in 1960. The questions remaining for decision are:
(1) Whether the petitioner realized taxable gain in 1960 on account of the purported sale of 206,400 shares of stock of Perfect Photo, Inc.
(2) Whether third-party optionees in substance purchased the petitioner's stock subject to a secured loan without recourse, i.e., a mere pledge of the stock.
(3) Whether the petitioner's stock, as a result of its theft, was compulsorily or involuntarily converted.
(4) Whether it was established in a year subsequent to the sale that the petitioner did not have an unrestricted right to the sale proceeds.
(5) Whether counsel's fees and other costs were deductible in 1961.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference. The facts necessary for our opinion are as follows:
Petitioners Karl and Hilda Hope are husband and wife. At the time of the filing of their petition, the petitioners resided in East Stroudsburg, Pa. For the taxable years here in question, calendar 1960 and 1961, the petitioners filed their joint income tax returns on the cash method of accounting with the district director of internal revenue, Philadelphia, Pa. Inasmuch as Hilda Hope is a petitioner solely as a result of the filing of a joint return, Karl Hope will hereinafter be referred to as the petitioner.
At all times material hereto, Perfect Photo, Inc. (hereinafter Perfect Photo), was a corporation organized under Pennsylvania law and engaged in the business of developing and printing of photographic film. The petitioner purchased a one-half interest in Perfect Photo in 1946. At that time Perfect Photo was engaged in the photofinishing of black and white film. About 1952, the petitioner purchased the remaining 50 percent.
In 1959, Eastman Kodak released the processing of color film. This enabled Perfect Photo to go into the business of photofinishing color film. As a result, the volume of its business increased from several hundred thousand dollars to several million dollars per annum.
The petitioner and his brother, Henry Hope, were the principal officers and directors of Perfect Photo. The petitioner was involved in the financial and management aspects of Perfect Photo's business while Henry Hope confined his activities to the technical aspects of the business.
On or about June 1, 1959, Perfect Photo employed Warren G. Grabb (hereinafter Grabb), a management engineer, as a consulting engineer. In September 1959, Grabb became vice president and director of Perfect Photo. On or about August 1959, Perfect Photo employed Harry J. Sentiff (hereinafter Sentiff), a certified public accountant, as a vice president and director. Sentiff became engaged mainly in the financial affairs of Perfect Photo, and Grabb became engaged not only in the financial affairs but also in the management of Perfect Photo.
In October 1959, a public offering was made of the stock of Perfect Photo at $14 per share. A total of 150,000 shares of the stock of Perfect Photo was sold to the public, of which 60,000 shares were sold by Perfect Photo and 90,000 shares were sold by petitioner.
Following the public sale of the stock of Perfect Photo, the petitioner told Sentiff and Grabb, among others, that he wanted to dispose of the remainder of his stock, and the petitioner did sell 3,600 shares of that stock on January 12,1960, at $37.11 per share. After the petitioner had made an unsuccessful attempt to merge Perfect Photo into another corporation and was otherwise unable to dispose of a large block of his stock, Sentiff discussed the situation with C. Clark Ambrose (hereinafter Ambrose) of Harriman Ripley & Co., Inc., of New York, now doing business as Drexel, Harriman Ripley, Inc. (hereinafter Harriman Ripley Co.). As a result of those discussions, a plan was worked out whereby Harriman Ripley Co. agreed to finance or participate in a purchase of the petitioner's stock interest in Perfect Photo which amounted to 206,400 shares, or approximately 57 percent, of the 360,000 issued and outstanding shares of Perfect Photo stock. However, Ambrose indicated that before Harriman Ripley Co. would proceed with any plan, Sentiff would have to produce written evidence of the petitioner's intention to sell his stock.
At Ambrose's suggestion, Sentiff obtained an agreement from the petitioner granting Sentiff and Grabb the right for a period of 30 days from June 15, 1960, to purchase all of the 206,400 shares of stock of Perfect Photo owned by the Petitioner for the sum of $4 million payable $10,000 upon written notice of exercise of the option on or before July 15, 1960, and the balance in cash on or before August 15, 1960.
On or about June 23, 1960, Ambrose advised Sentiff that Harriman Ripley Co. could not finance a purchase by Sentiff and Grabb because of Federal Reserve Board regulations limiting loans on securities. Ambrose proposed to Sentiff that Harriman Ripley Co. purchase the 206,400 shares of stock from the petitioner at a price of $19.38 per share for a total of $4,000,032 and give Sentiff and Grabb an option until December 31, 1961, to purchase 154,800 shares or 75 percent of the stock so acquired at the same price per share. Sentiff and Grabb also were to be given proxies to vote the 154,800 shares subject to the option.
Harriman Ripley Co. hoped to earn its profit from the 51,600 shares or 25 percent of the purchased stock that was not subject to the option. Sentiff and Grabb intended to sell part of the option to investors or underwriters and to use the net proceeds of that sale to finance the purchase of the stock subject to the remaining part of the option.
Upon reaching this agreement with Harriman Ripley Co., Sentiff thereupon advised the petitioner that Harriman Ripley Co. would purchase his stock for $4,000,032. Sentiff did not tell the petitioner at that time that he and Grabb were going to receive an option to purchase 75 percent of the stock sold to Harriman Ripley Co.
However, on or about June 25, 1960, the details of the sale and option arrangement were made known to Mr. C. Laurence Cushmore, Jr. (hereinafter Cushmore), the attorney who represented the petitioner in the sale and who was also the secretary of and a director of Perfect Photo and a partner in the law firm that was counsel for Perfect Photo. At that time, Sentiff told Cushmore that as the price of the Perfect Photo stock that was listed on the American Stock Exchange had increased substantially over the prior 10 days he and Grabb felt that some readjustment of the sale and option arrangement had to be made in fairness to the petitioner. However, when Cushmore received the first drafts of the documents of sale on July 8, 1960, he noticed that the option to purchase 75 percent of the stock ran from Harriman Ripley Co. to Sentiff and Grabb. When he asked Sentiff about this matter, he was told that the petitioner as the seller of stock could not be included as an optionee without the risk of violating the margin requirements applicable to listed securities under regulations issued by the Federal Reserve Board.
On or about July 11, 1960, Sentiff told Cushmore that Henry Hope would be included as an optionee with respect to 77,400 shares of the 206,400 shares of Perfect Photo stock that were to be sold by the petitioner to Harriman Ripley Co. This notification followed a meeting of the petitioner, Henry Hope, Sentiff, and Grabb at which the petitioner was told that Sentiff and Grabb were to benefit from the transaction and that the petitioner could not share in those benefits because of Government regulations. At that meeting it was also decided that Henry Hope would share any benefits with Sentiff and Grabb. The petitioner first became aware that Sentiff and Grabb were to be issued options to purchase 75 percent of the stock that was to be sold to Harriman Ripley Co. at this meeting which was held on or before July 10, 1960.
On July 14, 1960, stating that he understood that Henry Hope was to receive one-half of the benefits of the agreement under which the petitioner had granted Sentiff and Grabb the right for a period of 30 days from June 15, 1960, to purchase his 206,400 shares of Perfect Photo stock for $4 million payable $10,000 on written notice of exercise on or before July 15, 1960, and the balance on or before August 15, 1960, the petitioner extended the time to July 25, 1960, for giving written notice and the payment of the $10,000.
Negotiations during June and July of 1960 between Cushmore, acting as counsel for the petitioner, counsel for Harriman Ripley Co., and separate counsel for Sentiff and Grabb culminated on July 15, 1960, in the execution of a purchase agreement between the petitioner and Harriman Ripley Co. as agent for several purchasers as well as for its own account. The petitioner agreed that at a closing date selected by Harriman Ripley Co. prior to August 15, 1960, he would sell his 206,400 shares of Perfect Photo stock at $19.38 per share with any transfer taxes payable by the purchasers. The petitioner's obligation to make the sale of his Perfect Photo stock was subject to the delivery by Harriman Ripley Co. of options to purchase 154,800 shares of Perfect Photo stock at $19.38 per share to Henry Hope, Sentiff, and Grabb in the respective amounts of 77,400, 38,700, and 38,700 shares.
The petitioner's obligation was further conditioned on the delivery by Harriman Ripley Co. of proxies to vote the optioned stock to the optionees. The proxies gave their holders the power to vote the stock solely for the election of directors of Perfect Photo. Although the reason for issuing the proxies was not given, the granting of the proxies to members of the management group was consistent with Harriman Ripley Co.‘s opinion that Perfect Photo was in a service business that could best be run by that group.
Harriman Ripley Co.‘s obligation to make the purchase was subject to the delivery by Perfect Photo of an agreement providing for the registration at Harriman Ripley Co.‘s request of the purchase stock under the Securities Act of 1933. Harriman Ripley Co.‘s obligation was further conditioned on the receipt of an opinion of their counsel that neither their purchase nor their delivery of options to Henry Hope, Sentiff, and Grabb would violate the Securities Act of 1933 or the Securities Exchange Act of 1934.
Harriman Ripley Co. selected July 27, 1960, as the closing date. Prior to the closing, Cushmore went over with the petitioner the terms of the purchase agreement of July 15, 1960, which was prepared by counsel for Harriman Ripley Co. Cushmore also attended the closing as the petitioner's counsel. At the closing, the conditions of sale were satisfied, and the petitioner transferred his 206,400 shares of Perfect Photo stock on receipt of several checks in the total amount of $4,000,032.
In satisfaction of its obligation under the purchase agreement, Harriman Ripley Co. executed and delivered at the closing options and proxies covering 77,400, 38,700, and 38,700 shares of the stock to Henry Hope, Sentiff, and Grabb, respectively. Although the petitioner initially did not know that Harriman Ripley Co. was going to issue options and proxies covering 75 percent of the stock, he received notice of this fact prior to the sale and by extending his option to Sentiff and Grabb on July 14, 1960, indicated his consent to this arrangement.
At the time that Henry Hope received options and proxies covering 77,400 shares of the stock, he had an understanding with the petitioner that he would follow the petitioner's directions with respect to the options and vote the shares the way the petitioner wanted him to vote.
The options ran through December 31, 1961, but could be terminated by Harriman Ripley Co. prior to that date if the price of Perfect Photo stock on the American Stock Exchange fell below $30 for 5 consecutive business days or if Perfect Photo failed on request to file a registration statement with respect to the stock purchased from the petitioner or use its best efforts to cause such statement to become effective at the earliest possible date.
The proxies were irrevocable until December 31, 1961, unless the options were transferred or terminated or if Perfect Photo without the consent of Harriman Ripley Co. issued additional equity interests other than for certain defined purposes.
At the insistence of the petitioner, Henry Hope, Sentiff, and Grabb entered into an agreement, dated July 27, 1960, which provided that neither the options nor the stock acquired by the exercise of the options would be transferred or disposed of in excess of 100 shares during any calendar week without notice to the other parties and an opportunity for the other parties to participate in the disposition. The petitioner's purpose in requiring this agreement was to insure against one of the three optionees selling an interest that might be significant enough to lessen the market value of the interests held by the other optionees.
As the petitioner was selling his stock interest in Perfect Photo, it was requested that he and his brother, Henry Hope, be given employment agreements. At some point during July 1960, the petitioner and Henry Hope received employment contracts.
During June and July 1960, Perfect Photo stock traded at a low of 40 1/2 per share and a high of 66 7/8 per share on the American Stock Exchange.
In September 1960, an article appeared in Business Week which stated that the petitioner had sold his stock at $20 a share at a time when Perfect Photo stock was trading over $50. Following this article, the petitioner became dissatisfied with the transaction.
As a result of that dissatisfaction, the petitioner shortly thereafter consulted Harold E. Kohn (hereinafter Kohn) of the law firm of Dilworth, Paxson, Kalish, Kohn & Dilks. It was Kohn's opinion that the petitioner had an excellent prospect of recovery if he sued for a rescission. The petitioner told Kohn to first attempt to recover the stock by negotiation. On Kohn's advice, the petitioner held the sale proceeds in cash and marketable securities pending the settlement of the dispute.
On December 15, 1960, Sentiff and Grabb refused to give up their options, and Harriman Ripley Co. refused to return the Perfect Photo stock that it had purchased from the petitioner. Henry Hope readily agreed to transfer the options issued in his name to the petitioner at any time upon the latter's request.
Approximately 5 months after the sale, on December 21, 1960, the petitioner, on advice of counsel, filed a complaint in the U.S. District Court for the Eastern District of Pennsylvania naming as defendants Harriman Ripley Co., Sentiff, and Grabb. The complaint alleged, in part, that:
in or about January, 1960, defendants Sentiff and Grabb, pursuant to a conspiracy between them to defraud plaintiff, and in abuse and violation of their confidential and fiduciary duties to plaintiff, commenced efforts to induce him to sell the remaining 206,400 shares of stock of Perfect (Photo) owned by him, at a price substantially below the market price and the actual and fair value of said shares, concealing from him their intention to acquire the same for themselves.
It was also alleged that Sentiff and Grabb knew that the petitioner could have obtained a sales price in excess of $8 million for those shares.
After a statement of the grounds relied upon, the complaint, in part, requested:
1. That defendants and each of them be ordered and required to rescind the transactions complained of, to return to plaintiff the aforesaid 206,400 shares of stock of Perfect (Photo), of which he has been defrauded, and to execute such documents as may be necessary to effectuate such rescission of record, upon repayment of the aforesaid sum of $4,000,000, together with the net earnings thereon.
Other than a prayer for punitive damages together with costs and reasonable counsel fees, the sole relief sought was for rescission and matters ancillary thereof.
The complaint further stated that Henry Hope, who was not named as a defendant, had informed the petitioner that he acquiesced in the rescission and would perform such acts and execute such documents necessary to effectuate a rescission. On March 24, 1961, Henry Hope did, in fact, assign to the petitioner the option to purchase 77,400 shares of Perfect Photo stock from Harriman Ripley Co.
Settlement negotiations between the parties to the suit culminated in the filing with the court on March 24, 1961, of a stipulation of dismissal in which counsel for the parties stipulated and agreed that the petitioner's action ‘be dismissed with prejudice as to all defendants named in the Complaint, without cost to any party.’ The basis of settlement was as follows:
(a) Sentiff and Grabb received $350,000 from the petitioner in consideration of their assignment to him of their options to purchase 77,400 shares of Perfect Photo stock from Harriman Ripley Co.;
(b) Sentiff and Grabb returned to Harriman Ripley Co. their proxies to vote the shares subject to the options that they assigned to the petitioner;
(c) Harriman Ripley Co. waived the requirement in the option agreement that an optionee give Harriman Ripley Co. at least 5 days' written notice of a transfer;
(d) Harriman Ripley Co. confirmed that to the best of its knowledge the options assigned to the petitioner by Henry Hope, Sentiff, and Grabb were valid and binding instruments and delivered to the petitioner proxies to vote the 154,800 shares of Perfect Photo stock that were the subject of the options assigned to the petitioner; and
(e) As Henry Hope, Sentiff, and Grabb no longer held options to purchase Perfect Photo stock, they rescinded, terminated, and canceled their agreement which provided that neither the options nor the stock acquired by the exercise of the options would be transferred or disposed of in excess of 100 shares during any calendar week without notice to the other parties and an opportunity for the other parties to participate in the disposition.
During the week which included March 24, 1961, Perfect Photo stock traded at a low of 44 5/8 per share and a high of 48 7/8 per share.
Shortly after the petitioner filed his complaint in the U.S. District Court, the U.S. Securities and Exchange Commission requested that it be apprised of developments and the Pennsylvania Securities Commission after an investigation ordered a hearing before the full commission. The hearing before the Pennsylvania Securities Commission was held on April 19, 1961. At that hearing the commission was informed that the litigation brought by the petitioner had been settled.
On May 4, 1961, the Pennsylvania Securities Commission sent letters to Harriman Ripley Co., Sentiff, and Grabb which contained the following statements with regard to their investigation of the sale:
This is to advise you that the Commission, upon its investigation and consideration of the evidence presented before it in reference to the aforesaid matter, has concluded that you have engaged in activities in violation of The Pennsylvania Securities Act which would justify, among other things, the entry of an order of rescission by it against you.
However, in view of the fact that a settlement has been made, satisfactory to all parties, which, in the opinion of the Commission would be equivalent in effect to compliance with an order of rescission, the Commission has determined to waive the entry of any formal order and is accordingly marking this case closed.
The letters cautioned against any recurrence of ‘the type of practices revealed in this matter’ and the letters addressed to Sentiff and Grabb also cautioned against their engaging in the sale of securities without registering as a dealer or salesman.
The petitioner had until December 31, 1961, to exercise his options to acquire the 154,800 shares of Perfect Photo stock held by the Harriman Ripley Co. Although the petitioner discussed the possibility of an early exercise of his options, he decided to wait until the end of the option period, as the Harriman Ripley Co. would not accept an option price of less than the agreed price.
After a request by the petitioner's counsel to extend the termination date of the options was denied, the petitioner delivered written notice to the Harriman Ripley Co. on December 18, 1961, of his intention to exercise his options on December 29, 1961. On December 29, 1961, in order to reflect a 3-for-1 split of Perfect Photo stock that occurred on July 3, 1961, the Harriman Ripley Co. delivered certificates evidencing 464,400 shares of Perfect Photo stock to the petitioner in consideration of the receipt of the agreed option price of $3,000,024. In 1962 and 1963, the petitioner sold a total of 464,340 of those shares at an average per share price of approximately $4.65.
The petitioner paid Dilworth, Paxson, Kalish, Kohn & Dilks counsel's fees of $85,000 in 1961 for conducting and settling the litigation involving Sentiff, Grabb, and the Harriman Ripley Co. and for effecting the delivery of the 464,400 shares of Perfect Photo stock from the Harriman Ripley Co.
In his 1960 tax return, the petitioner disclosed the transfer of 206,400 shares of Perfect Photo stock for $4,001,632 ($19.38 per share, plus $1,600 stock transfer tax paid by the Harriman Ripley Co.). However, the petitioner did not include in income his gain on the sale on the grounds that the transfer was not a completed sale on which gain was ‘recognized’ in 1960. In his notice of deficiency, dated February 15, 1965, the respondent determined that the petitioner realized in 1960 a taxable gain of $3,939,712 on the sale of 206,400 shares of Perfect Photo stock to Harriman Ripley Co.
In his 1961 tax return, the petitioner reported $4,001,632 as proceeds from the sale, reduced the proceeds by the $3,000,054 paid to Harriman Ripley Co. on the exercise of the options and by the $350,000 paid to Sentiff and Grabb, and reported $651,578 as net proceeds from ‘shares deemed sold.’ In computing his gain, the petitioner used his original cost basis in the 51,600 shares of Perfect Photo stock that were not subject to the option increased by counsel's fees of $85,000. In his notice of deficiency, dated April 24, 1969, the respondent determined in the alternative to his prior determination of February 15, 1965, that the petitioner realized in 1961 a taxable gain of $986,098 on the sale of 51,600 shares of Perfect Photo stock.
The correct figure was $3,000,024.
1. The petitioner's suit for rescission did not postpone the realization of taxable gain on the completed sale.— The facts of this case conclusively establish that on July 27, 1960, the petitioner sold 206,400 shares of Perfect Photo stock to Harriman Ripley Co. as agent for several purchasers as well as for its own account. The sale was completed on that date when title and possession of the certificates were transferred by the petitioner to Harriman Ripley Co., and the petitioner received $4,000,032 as payment in full. For the purposes of determining when the contract of sale was executed, it is immaterial whether Harriman Ripley Co., the ostensible purchaser, was acting on its own and its disclosed principals' behalf or on the behalf of others. The petitioner received the money from the sale without any restrictions on his use or disposition of those funds.
Some months after the sale of the stock but within the same taxable year, the petitioner became dissatisfied. This dissatisfaction cannot be attributed to the supposed discovery that Sentiff and Grabb might stand to benefit from the transaction. The petitioner knew this prior to the sale, and the specific benefits that Sentiff and Grabb were to receive were clearly spelled out in the sales agreement which the petitioner examined in the presence of his attorney. The petitioner's dissatisfaction cannot be attributed to the issuance of an option to purchase 77,400 shares of stock to his brother, Henry Hope, as the petitioner knew of and consented to that arrangement. Thus, it is clear that the petitioner's dissatisfaction resulted solely from the fact that he felt that the price of the stock that he had sold had been inadequate.
As a result of his dissatisfaction, the petitioner consulted Dilworth, Paxson, Kalish, Kohn & Dilks, who advised the petitioner that there were grounds for a suit to rescind the sale. After unsuccessfully attempting to reach a settlement with the purchaser, the petitioner filed such suit on December 21, 1960, naming as defendants Harriman Ripley Co., Sentiff, and Grabb. That suit was pending at the close of 1960.
With respect to taxpayers who file their returns on the cash receipts and disbursements method of accounting, section 451(a) provides that income shall be included in the return ‘for the taxable year in which received by the taxpayer.’ Boyce v. United States, 405 F.2d 526 (Ct. Cl. 1968). Although the petitioner does not question the general rule that a cash basis taxpayer must return income from a completed sale in the taxable year in which he receives the sale proceeds (secs. 61(a)(3), 451(a); sec. 1.451-1(a), Income Tax Regs.), he contends that his complaint requesting a rescission of the sale postponed his obligation to return the income from the sale until the year in which the suit was settled. We are unable to agree.
All section references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
The petitioner parted with his stock and received $4,000,032. The fact that the petitioner voluntarily held the sale proceeds in cash and marketable securities was not such a use of the funds as would change the character of the proceeds as income.
The petitioner relying on Bates Motor Trans. Lines v. Commissioner, 200 F.2d 20 (C.A. 7, 1952), affirming 17 T.C. 151 (1951); United States v. Merrill, 211 F.2d 297 (C.A. 9, 1954); J. W. Gaddy, 38 T.C. 943 (1962), reversed in part on other issues 344 F.2d 460 (C.A. 5, 1965), contends that the gain derived in the 1960 sale must be eliminated from that accounting period, as he disclaimed his rights to the sale proceeds in the year of receipt.
The cases relied on by the petitioner establish an exception to the claim-of-right doctrine that applies when in the year of receipt a taxpayer recognizes his liability under an existing and fixed obligation to repay the amount received and makes provisions for repayment. J. W. Gaddy, supra. This exception cannot be applied in the instant case, as the petitioner was never and an existing and fixed obligation to repay the sale proceeds.
The petitioner's contingent liability to pay back an amount equivalent to the proceeds received on the sale if his suit for rescission was successful imposed no restriction upon his use of the money in his hands. Commissioner v. Brooklyn Union Gas Co., 62 F.2d 505 (C.A. 2, 1933), affirming 22 B.T.A. 507 (1931).
Harry F. Doyle, 39 B.T.A. 940 (1939), affd. 110 F.2d 157 (C.A. 2, 1940); Guffey v. United States, 339 F.2d 759 (C.A. 9, 1964); and Sohio Corporation v. Commissioner, 163 F.2d 590 (C.A.D.C. 1947), reversing 7 T.C. 435 (1946), are distinguishable. Harry F. Doyle, supra, and Guffey v. United States, supra, involved executory contracts.
Sohio Corporation v. Commissioner, supra, involved the exclusion from gross income of amounts which an accrual basis taxpayer at no time asserted a right to retain but which the taxpayer was compelled by State law, over its formal and repeated protests, to collect. Furthermore, the holding that an accrual basis taxpayer does not derive income with respect to an amount actually received and not subject in the year of receipt to an offsetting obligation to refund is in our opinion incorrect.
Assuming that when he requested the rescission he chose to limit himself to that remedy, and regardless of whether there might have been probable cause, the mere filing of the suit by the petitioner was not of itself sufficient to postpone the realization of gain on the completed sale. Commissioner v. Brooklyn Union Gas Co., supra. Under the long-established principle of annual accounting for tax purposes, the gain resulting from the sale was taxable in 1960. United States v. Lewis, 340 U.S. 590 (1951); Burnet v. Sanford & Brooks Co., 282 U.S. 359 (1931); Commissioner v. Brooklyn Union Gas Co., supra.
2. Settlement of the petitioner's suit did not result in a rescission of the original sale.— The petitioner contends that his receipt in March 1961 of the options and proxies issued with respect to the 154,800 shares of Perfect Photo stock, or alternatively his receipt in December 1961 of the stock itself, was tantamount to a rescission that limited his gain on the sale to that derived from the 51,600 shares retained by Harriman Ripley Co.
This Court is not faced with the situation where the sale is rescinded in the same year. Compare Penn v. Robertson, 115 F.2d 167 (C.A. 4, 1940). In fact, it is not necessary to decide what might have been the result if the sale had been rescinded in the following year. Compare Penn v. Robertson, supra, with Ripley Realty Co., 23 B.T.A. 1247 (1931), affirmed per curiam 61 F.2d 1038 (C.A. 2, 1932). It is clear that the settlement of the suit filed by the petitioner was not tantamount to a rescission at any time.
With respect to the optioned stock, the petitioner contends that Sentiff, Grabb, and Henry Hope were the real purchasers of the stock with Harriman Ripley Co.merely acting as a lender of funds for which it received 51,600 shares of the stock. Assuming that the facts establish this to be the substance of the 1960 sale, the petitioner next contends that he and the actual purchasers rescinded the sale in 1961. While we agree with the petitioner's observation that the substance of a transaction must prevail over its form (Commissioner v. Court Holding Co., 324 U.S. 331 (1945)), and that the rule may work for the benefit of the taxpayer as well as the Government (Frank Ciaio, 47 T.C. 447 (1967)); Maynard Hospital, Inc., 52 T.C. 1006 (1969), we do not find that the realities of the transactions that are the subject of the instant case differ from the form in which they were cast.
There is no doubt that Sentiff and Grabb were interested in purchasing a part of the stock and that Harriman Ripley Co. issued them the options to accomplish their goal. It also appears that Henry Hope was included as an optionee as an additional inducement for the petitioner to complete the sale, which inducement can be reasonably traced to the sharp increase that occurred during the negotiations in the price of the Perfect Photo stock that was listed on the American Stock Exchange. While the transaction might have the same attributes as a nonrecourse loan by Harriman Ripley Co. to the optionees, it does not follow that, as to petitioner, the sale should be set aside.
At no time did Sentiff, Grabb, or Henry Hope agree to purchase stock from the petitioner or become indebted to Harriman Ripley Co. on account of the 1960 sale. At all times after the sale and until the petitioner exercised the options, title to the stock subject to the options held by Sentiff, Grabb, and Henry Hope, as well as risk of loss with respect to that stock, rested with Harriman Ripley Co. Sentiff, Grabb, and Henry Hope were not the owners of that stock. An option is not considered a present interest in stock. See Winthrop M. Crane III, 45 T.C. 397 (1966); Max H. Wyman, 33 T.C. 622 (1959).
Sentiff, Grabb, and Henry Hope were given the right to vote the shares subject to their options for the election of directors. However, this right cannot be considered as placing ownership of the stock in them. Harriman Ripley Co. granted that right as it, as the owner of the stock, believed that the current management should be allowed to continue to operate the business. By giving Sentiff, Grabb, and Henry Hope, who agreed to vote his proxies as directed by the petitioner, control over the board, which included directors other than themselves, the management of the business was placed squarely in their hands.
The petitioner's reliance on Union Planters Nat. Bank of Memphis v. United States, 426 F.2d 115 (C.A. 6, 1970), and American National Bank of Austin v. United States, 421 F.2d 442 (C.A. 5, 1970), is misplaced. It is true that Harriman Ripley Co. could terminate the options if the stock fell below $30 and attempt to market the stock at a price in excess of its cost. However, this was in no way comparable to the understandings in the Union Planters Nat. Bank of Memphis and American National Bank of Austin cases that the basic risk of ownership of securities would remain with the ‘sellers.’
Once we recognize that Harriman Ripley Co., rather than the optionees, was the actual purchaser of the stock, it cannot be argued that there was ever a rescission of the original sales contract. The seller paid $350,000 to Sentiff and Grabb, the perpetrators of the alleged fraud, and received from them and his brother, Henry Hope, the assignment of their respective rights under an option to purchase three-fourths of the stock from Harriman Ripley Co. That firm's ownership of the stock was unaffected by the agreement entered into as a result of the suit for rescission. Harriman Ripley Co. gave up nothing. When Harriman Ripley Co. transferred the optioned stock to the petitioner in 1961, it was pursuant to the original sales agreement.
Once the petitioner obtained the options, he had an election either to buy back the stock or to keep the money and allow the transaction to stand. This was a valuable right for which the petitioner was ‘out of pocket’ by the sum of $350,000. In recognition of the value of this right, the petitioner sought a discount for giving it up. Later, his counsel sought to obtain additional time within which to make a decision as to the exercise of the options. It is obvious that if the precipitous decline in the market price of the stock had occurred prior to the date on which the petitioner had to exercise the option, the petitioner would not have repurchased the stock and would not be before this Court. This element of choice cannot be reconciled with the petitioner's claim that the sale was rescinded.
It is clear that the settlement which resulted in the reacquisition of 154,800 shares of the stock was a new transaction that had no effect upon the petitioner's tax liability for 1960. Ripley Realty Co., supra.
As we are concerned with whether gain realized in a prior year may be limited by the events of a subsequent year, rather than with the characterization of amounts received in the year of settlement of litigation, Margery K. Megargel, 3 T.C. 238 (1944), and Albert J. Goldsmith, 22 T.C. 1137 (1954), relied on by the petitioner are inapplicable.
If an inequity exists, it is the inability of the petitioner to carry back his 1962 and 1963 losses and apply those losses against his 1960 gain, a result that can be changed only by the Congress.
3. The petitioner's stock was not compulsorily or involuntarily converted.—The petitioner contends that he was induced to sell his stock by fraud and false pretenses such as constitutes theft within the meaning of section 1033(a) and that by exercising the options he acquired property similar or related in service or use to the property converted so as to cause the nonrecognition of gain from the sale to the extent of his reinvestment. Specifically the petitioner alleges that Sentiff and Grabb made false representations as to the adequacy of the sales price and thus that the sale involved the criminal appropriation of his stock in violation of both Pennsylvania law (‘Cheating by fraudulent pretenses,‘ Pa. Stat. Ann., tit. 18, sec. 4836 (1963); ‘Conspiracy to do unlawful act,‘ Pa. Stat. Ann., tit. 18, sec. 4302 (1963)) and Federal law (‘Mail Fraud,‘ 18 U.S.C.sec. 1341).
The term theft as used in the Internal Revenue Code is a word of general and broad connotation intended to cover and covering any criminal appropriation of another's property to the use of the taker, particularly including theft by swindling, false pretenses, and any other form of guile. Edwards v. Bromberg, 232 F.2d 107 (C.A. 5, 1956); Perry A. Nichols, 43 T.C. 842 (1965); and Robert S. Gerstell, 46 T.C. 161 (1966).
It has been held by the courts of Pennsylvania that a criminal false pretense is ‘the false representation of an existing fact, whether by oral or written words or conduct, which is calculated to deceive, intended to deceive, and does, in fact, deceive, and by means of which one person obtains value from another without compensation.’ Commonwealth v. Evans, 190 Pa.Super 179, 154 A.2d 57 (1959), affirmed per curiam 160 A.2d 407 (1960).
This is not a case where there has been a prior adjudication or admission of fraud. On the contrary the suit filed by the petitioner was contested. The Pennsylvania Securities Commission stated that in their opinion Sentiff, Grabb, and Harriman Ripley Co. had engaged in activities in violation of the Pennsylvania Securities Act which would justify the entry of an order of rescission of the sale. However, the nature of the violations of the Act was not stated, and the commission did not indicate that Sentiff, Grabb, or the Harriman Ripley Co. engaged in fraudulent practices even though the Act specifically dealt with such practices. See Pa. Stat. Ann., tit. 70, sec. 52 (1963).
The petitioner clearly wanted to sell his stock. Whether the price paid, namely $4 million, was adequate involved a question of judgment. Certainly the petitioner was best qualified to make that judgment. He had already made several efforts to sell the company or to merge with another company. He had sold some of his stock. He had acquired similar businesses. Better than anyone else he certainly knew what the future risks and prospects might entail.
The market quotation with respect to the shares that were traded on the American Stock Exchange would not necessarily be determinative of value of the shares sold to Harriman Ripley Co. Admittedly the petitioner's 206,400 shares could not have been sold on the American Stock Exchange without driving down the price. Once it became known that the petitioner was ‘selling out,‘ the result could be disastrous.
On the other hand, if offered privately as a block carrying with it control of Perfect Photo, the stock would be valued on a different basis. One buyer might be willing to pay more for control. Another less, if the stock had to be fed into the market, to take into account the fact that the seller was the principal executive officer upon whom Perfect Photo largely depended for its success.
In short, the position of both parties to the sale negates a finding that the price was not ‘right.’ The petitioner certainly must be assumed to have had a better knowledge with respect to the business and its future potential than any outsider. Harriman Ripley Co. was experienced in this type of transaction and must have known what was being sold. We are thus unable to conclude that the consideration was so inadequate as to impute fraud.
The petitioner also knew that Sentiff and Grabb stood to benefit from the transaction. There was no concealment at the time of sale. The appropriate occasion for the petitioner to complain was when he first learned that Sentiff and Grabb were to participate in the benefits of the sale.
The petitioner states on brief that his suit for rescission contained all the allegations essential to establish the Federal crime of mail fraud. Without attempting to adjudicate the scope of that complaint, it is sufficient to state that there is not a scintilla of evidence of an intent to defraud within the meaning of that statute. Also, the record is devoid of evidence of a conspiracy to do an unlawful act.
4. The petitioner was never obligated to return any portion of the sale proceeds to Harriman Ripley Co.— The petitioner contends that his 1961 tax liability can be computed taking into account section 1341. The availability of the section is conditioned on the petitioner's showing that a deduction was allowable for 1961 ‘because it was established after the close of * * * (1960) that the taxpayer did not have an unrestricted right to * * * (the proceeds of the 1960 sale).’
The facts of the instant case do not satisfy that condition as under the terms and conditions of the 1960 sale the petitioner was never obligated to return any portion of the sale proceeds to Harriman Ripley Co. See George L. Blanton, 46 T.C. 527 (1966), affirmed per curiam 379 F.2d 558 (C.A. 5, 1967). In addition, the petitioner has not shown any payment to Harriman Ripley Co. that was deductible.
5. There is no basis for finding that the petitioner incurred a loss on account of theft or fraud.— The petitioner contends that the $85,000 counsel's fees paid in attempting to effect a recovery of his property are deductible as a theft loss under section 165(c)(3). If the petitioner's stock had been appropriated by false pretenses, counsel's fees incurred in connection with that theft might have been deductible as additional or collateral theft losses. See Katherine Ander, 47 T.C. 592 (1967). However, we have been unable to find that the sale involved a criminal appropriation and thus the counsel's fees are not deductible under section 165(c)(3).
This leaves the question of whether the counsel's fees are deductible under sections 212 or 162 as ordinary and necessary expenses relating to the petitioner's sale as an investor and controlling stockholder of Perfect Photo or as the principal officer of that firm.
The counsel's fees were for conducting and settling the litigation involving Sentiff, Grabb, and Harriman Ripley Co. and for effecting delivery of the 464,400 shares of Perfect Photo stock from Harriman Ripley Co. To the extent that these fees were attributable to the litigation, they were capital expenditures since they were costs incurred in the petitioner's attempt to reacquire a capital asset. Spangler v. Commissioner, 323 F.2d 913 (C.A. 9, 1963), affirming a Memorandum Opinion of this Court; Munson v. McGinnes, 283 F.2d 333 (C.A. 3, 1960). The fact that the suit was unsuccessful in that Harriman Ripley Co. did not return the stock for the sale proceeds does not render the fees ordinary and necessary expenses rather than capital expenditures. Radio Station WBIR, Inc., 31 T.C. 803 (1959), Stass Reed, 55 T.C. 32 (1970). To the extent that the fees were attributable to the delivery of stock, they were also capital expenditures. Stephens Fuel Co., Inc., 13 B.T.A. 666 (1928).
As the firm's principal officer, it must be assumed that the petitioner was also interested in recovering control of Perfect Photo. However, the litigation involved in essence whether he had grounds to reacquire the stock which embodied that as well as other rights. Also, even if it were determined that the voting rights should bear some of the expense, an allocation could not be made on the basis of this record.
The $350,000 paid to acquire the option was a cost of the option and not a deductible expense. Stires Corporation, 28 B.T.A. 1 (1933).
Accordingly, the respondent properly allocated these payments to the stock acquired by the petitioner on his exercise of the options.
Reviewed by the Court.
Decisions will be entered under Rule 50.


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Non 1001 Book Review: At the Edge of the Orchard Tracy Chevalier
At the Edge of the Orchard by Tracy Chevalier
Release date: March 15 2016
Reviewed by: Book Worm
Find it here: At the Edge of the Orchard
This ARC was provided by Penguin Group Viking (via NetGalley) in exchange for an honest review.
Synopsis from Goodreads: From internationally bestselling author Tracy Chevalier, a riveting drama of a pioneer family on the American frontier
1838: James and Sadie Goodenough have settled where their wagon got stuck – in the muddy, stagnant swamps of northwest Ohio. They and their five children work relentlessly to tame their patch of land, buying saplings from a local tree man known as John Appleseed so they can cultivate the fifty apple trees required to stake their claim on the property. But the orchard they plant sows the seeds of a long battle. James loves the apples, reminders of an easier life back in Connecticut; while Sadie prefers the applejack they make, an alcoholic refuge from brutal frontier life. Read more

domain: literature


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Keith Urban hosted a livestream concert from his basement studio this week, the second in his Urban Underground series. Performing a six-song set, the singer-guitarist mixed in a classic cover as a tribute to a recently departed icon: Kenny Rogers’ “The Gambler.”
“I wanted to do a song for the late, great Kenny Rogers,” Urban said, as his wife Nicole Kidman looked on. “I grew up playing a lot of his music, and I know a lot of my friends did. It’s hard to narrow it down to one song.” Ultimately, he chose Rogers’ signature story-song, written by Don Schlitz. “If you know it, please sing along,” Urban told viewers, ” ’cause I haven’t played it in 25 years.”
Along with “The Gambler,” Urban delivered his own “Never Comin’ Down,” “You Gonna Fly,” “Somewhere in My Car,” “Wasted Time,” and his latest single, “God Whispered Your Name.” A video for that track, an introspective ballad with elements of the blues, is on its way, he promised.
Urban was set to host the 55th annual ACM Awards next month in Las Vegas. Because of the COVID-19 pandemic, the show has since been rescheduled for September 16th, with Urban still on board as emcee.

domain: entertainment


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(HOLLYWOOD, Fla.) — Police are searching for suspects after nine people, including children, were shot and injured along the Hollywood Beach Broadwalk on Florida’s east coast.
Four children between the ages of 1 and 17 were shot Monday night, including a baby between 15 and 18 months old, according to Hollywood police spokesperson Deanna Bettineschi.
The other five victims were adults ages 25 to 65.
The four children remain hospitalized on Wednesday, all in stable condition, according to hospital officials. The injured adults have been treated and released.
The shooting apparently stemmed from an altercation between two groups, and multiple people were detained in the aftermath, Bettineschi said Tuesday.
Two men believed to be involved in the shooting have been arrested on weapons charges, Bettineschi said. Morgan Deslouches, 18, and Keshawn Paul Stewart, 18, both face a concealed carry weapon charge in connection with the incident. Deslouches also has been charged with larceny-grand theft of a firearm and removing the serial number from a firearm, court records show.
Authorities said they’re looking to identify these three people they believe were also involved in the shooting:
“No stone will be left unturned in bringing the perpetrators to justice,” Hollywood Beach Mayor Josh Levy said in a statement Tuesday. “We will utilize every available resource to apprehend those responsible.”
“It is completely unacceptable that innocent people spending time with family on a holiday weekend have been affected by a shooting altercation between two groups who came into our city with guns and no regard for the safety of the law abiding public around them,” Levy added.
ABC News’ Darren Reynolds, Peter Charalambous and Okelo Pena contributed to this report.
Copyright © 2023, ABC Audio. All rights reserved.

domain: news


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Proudly we hail
Fox Valley Marine Corps League plans 12th Annual Golf Classic Vermont VA hospital to host ‘Blessing of the Bikes’ NEW YORK (AP) – Amazon will not take advantage of a federal program offering massive tax breaks when it builds headquarters in New York City. The internet shopping giant told the New York City Council.The Fox Valley Marine Corps League will donate the proceeds of the 12th annual Golf Classic at Bliss Creek Golf Course in Sugar Grove to veterans and their families, specifically to help those.
So Proudly We Hail! (1943) – Full Cast & Crew – IMDb – So Proudly We Hail! (1943) cast and crew credits, including actors, actresses, directors, writers and more.
‘I was super excited:’ Fort Bragg students win state video contest The serviceman at Fort Campbell and Fort Bragg are given swift instructions on how to protect. bringing the total number of confirmed and suspected cases of the virus to 9,191. Scroll down for.
The Star-Spangled Banner lyric "what so proudly we hailed" took on new meaning Saturday night at Louisville Slugger Field. Just as national anthem singer Carolyn Dawson started her rendition, with the.
What So Proudly We Hail is a compilation album of phonograph records by Bing Crosby released in 1946 featuring songs that were sung by Crosby in an American-type patriotic style. This album featured Bing singing patriotic songs such as: " Ballad for Americans ", ".
What So Proudly We Hail. What So Proudly We Hail provides free resources and lesson plans to language arts and social studies teachers, demonstrating how short stories, speeches, and songs can be used to enhance civic education. Created by educators Amy Kass and Leon Kass, it seeks to educate both hearts and minds about American ideals.
So Proudly We Hail! (1943) It’s appropriate that So Proudly We Hail ! aired during TCM’s new series Friday Night Spotlight (yes, by admitting that I acknowledge this review is a taste late to the party), as it features a war story that doesn’t explore the quiet desperation of army wives at home.
· Answers. Best Answer: What so proudly we hail’d alt the twilight’s last gleaming. this is that the last point they had light outside, they could still see the flag. And the rockets red glare the bombs bursting in air, describing what they could see, as it was one hell of a fight. O say, Does that star spangled banner yet wave.
Proudly We Hail | National Exchange Club (NEC) – Proudly We Hail. The Proudly We Hail program encourages regular display of the flag by individuals, commercial establishments and industries. To honor them a specially designed plaque is presented at a club meeting. Every club member can participate in the program because it is the individual member who watches for and nominates potential recipients.
So Proudly We Hail! Brimming with all the patriotic rhetoric typical of war flicks of the time, So Proudly We Hail! (1943) was nevertheless something of a change of pace for audiences as it followed the adventures and hardships of a troupe of military nurses through some of the darkest hours of the war in the Pacific.
Carlos Hopkins: Preventing veteran suicides is mission one VA names new finger lakes medical director april 16, 2007 was a cold, windy Monday in Blacksburg, Va. A lot was happening at the university. as the university’s deputy chief of police and director of threat management services, thinks the.Christopher Neiweem column: | THEIR OPINION | richmond.com – And Virginia’s secretary of veterans and defense affairs, Carlos Hopkins, a fellow Army veteran, even told reporters of Richmond’s dog tests, "That’s certainly not something that we’re.Local advisory councils help Brindisi shape policy Local advisory councils help Brindisi shape policy Team hosts veterans event homeless Fidelis – Valoanodessatx – Host a Stand Down event for Homeless Veterans According to a count on a January night in 2011, there were 67,495 homeless Veterans.WJFW – Under veterans’ watchful eye, state breaks ground on $80 million skilled nursing facility at King Veterans Home Storytelling contest for veterans announced DC VA Med Center Patient Escaped Psychiatric Unit Podimetrics Completes $13.4 Mln Funding for Disease-Detecting Foot Mat (Reuters) – Podimetrics, the maker of a smart foot mat that detects warning signs of diabetic foot ulcers, said on Thursday it raised $13.4 million in a funding round led by a group of investors, including venture capital firm Scientific Health Development. The company said the proceeds will be used to reach out to more [.]revamped veterans writing Prize: Newly-Created Veterans Story Contest. Council are sponsoring a new veterans storytelling contest that will culminate with an. who will announce the winners and hold a workshop specifically for veterans.Spokeswoman says Sen. Isakson’s calls to agencies on behalf of biotech firm’s CEO were ‘nothing improper’ – Statement 1304:"Excerpt from sunday august 26, 2018, the Los angeles times front-pager on Senator McCain’s passing. I agree about the honor part and understand his suffering unfairly at the hands of his own government being terrible. I had it much worse on that front. But we all know that nothing can.contents veterans home. 3:59am nbc 15 Skilled nursing facility fox 11. ground broken disabling medical conditions King august 2017 nursing staff accounted nursing staff increased Walker is also requesting .6 million over the next two fiscal years for operational improvements and equipment costs at all three of the state’s veterans homes.


German Chancellor Angela Merkel has pledged full support for victims of some of the country’s worst flooding in decades.
Record rainfall in western Europe caused rivers to burst their banks, devastating the region.
At least 59 people have died in Germany with hundreds more reported missing.
Belgium has also reported at least 11 dead after extreme weather which politicians have blamed on climate change.
Experts however say that climate change is expected to increase the frequency of extreme weather events, but linking any single event to global warming is complicated.
Speaking during a meeting with US President Joe Biden in Washington DC, Mrs Merkel expressed her deep condolences to everyone across the region who had lost loved ones.


the file was "invisable.gif" whatever that means, so I went to 4share and created an account, downloaded the file, then was told "the file did not tranfer because it was email", I am really sorry to have wasted all your time for just one view of the proper parts to control or limit the engine speed, the spring that was listed for the governor/throttle controls "aren't available" @ B&S, I DID learn a FANTASTIC amount of stuff about the flywheel, its' weights, the carb, etc. The machine runs really good for about 3 to 4 minutes, then the weights take over and it screams as I lunge to throttle off.
Anyway, I will just accept your answer, I know it is probably a pain having to check to see all the time if I fixed this or not. My dad loved this tiller and so did I, since his death my sister has just about destroyed any good piece of farm equipment by letting her friends use it for her, thus the maintenance was ignored, etc., I am so frustrated because I have rebuilt the riding lawnmower, the Ford 8N tractor, the push mower, the rainbird system...and his F-150 I pulled the old engine out and installed a rebuilt!!! Although I thought this would be a matter of logic and diagrams/parts would be easy to order, I never dreamed I would occupy anyone's time like I have yours. Thank you for trying to help me. I think what I need next is to cry-like any self respecting girl mechanic would do! ha ha


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Playbill.com's new feature series Booking It asks leading industry members to share professional insights, need-to-know tips and essential tricks of the trade for up-and-coming and established theatre artists. This week we speak with casting directors Duncan Stewart and Benton Whitley, who are represented on Broadway with Pippin, On the Town and Chicago.
Actors' Equity Association has announced the 2019 Tony-winningmusical Hadestown as winner of the 13th annual Award for Outstanding Broadway Chorus. Presented by Equity's Advisory Committee on Chorus Affairs, the award is the only industry accolade of its kind to honor the distinctive talents and contributions made by the original chorus members of a Broadway musical.
“Hadestown,” a pulsing, poetic contemporary riff on an ancient Greek myth, won the Tony Award for best new musical Sunday night, triumphing over film adaptations, a musical comedy and a jukebox show.
The win, coming at a time when Broadway is enjoying a long-running box office boom, marks the sixth year in a row that Tony voters have chosen an inventive show nurtured by nonprofits over more commercial fare.
The buzz began during previews. Online and over postshow cocktails, fans and industry insiders were talking about a standout in one of the season’s most celebrated new musicals. But it wasn’t one of the four stars of “Hadestown” who was a sudden focus of admiration, though all of them would eventually receive Tony nominations. It was the 6-foot-7 actor in the show’s five-person ensemble, Timothy Hughes.
Donna Marie Asbury, 56, has been with the revival almost from the beginning: She joined the first national tour in December 1997 and the Broadway company in March 1999. On Monday, she gave her last performance as June, one of the Cook County Jail tenants.
One of the biggest shows on Broadway this season has also had the longest, most public evolution. Hadestown, the hit musical that reimagines the myth of Orpheus and Eurydice as an anti-capitalist parable, has 14 Tony nominations. That’s the most of any show this season, and it includes one nod for Best Musical and nominations in three of the four acting categories.
The complete cast has just been announced for the 10th Anniversary Production of ROCK OF AGES, opening this summer at New World Stages (340 W 50th St). Nominated for five Tony Awards during its record-breaking Broadway run, this return engagement begins performances on Wednesday, June 19, 2019 for a 16-week limited run through Sunday, October 6, 2019. Tickets are now on sale at Telecharge.com.
NBC has picked up the drama “Zoey’s Extraordinary Playlist” for the 2019-2020 season.
The series follows Zoey Clarke (Jane Levy), a whip-smart computer coder forging her way in San Francisco. After an unusual event she starts to hear the innermost wants and desires of the people around her through songs. At ﬁrst, she questions her own sanity but soon realizes this unwanted curse may just be an incredibly wonderful gift.
In addition to Levy, the cast also includes Skylar Astin, Peter Gallagher, Alex Newell, John Clarence Stewart, Carmen Cusack, and Mary Steenburgen.
“Hadestown,” a folk-and-blues-inflected musical reimagining the myth of Orpheus and Eurydice, led the Tony nominations on Tuesday, winning nods in 14 categories and becoming a front-runner in the hotly contested, and financially significant, race for the season’s best new musical.
Rock of Ages, the smash-hit Tony-nominated musical that played a six-year run on Broadway, will head back to off-Broadway this summer at New World Stages, where it first debuted in New York. The show will play a limited 10th-anniversary engagement, set to run from June 19 through September 29, with the original creative team at the helm, including director Kristin Hanggi and choreographer Kelly Devine.
Goodspeed Musicals today announces the cast of Hi, My Name is Ben, the inspirational true story of one man who impacted the lives of all those around him without speaking a word. Written by Scott Gilmour and Claire McKenzie while in residence at the Johnny MercerWriters Colony at Goodspeed, this hope-filled musical will run May 17 - June 9, 2019 at The Terris Theatre in Chester, CT.
When Anaïs Mitchell and Rachel Chavkin talk about Hadestown, they often resort to metaphor. In simplest terms, the folk musical combines two Greek myths — of Orpheus and Eurydice, and Hades and Persephone — but it resonates with other valances: There’s Hades’s industrial underworld versus the organic place above, a potential allegory for climate change; there’s the perspective of the cynical gods versus the idealistic young lovers; there’s even a song about building a wall to keep out the poor, written well before that became a campaign promise. The story, the creators often insist, is closer to poetry than prose, which has also made it devilishly hard to stage — how do you manifest all those ideas onstage, and also, you know, make a good show? “I’ve never worked on anything as delicate as this piece, and maybe because it’s poetry, it’s so breakable,” Chavkin says. “It has gone through multiple breakings, in a sense, over the course of it. That’s the only way that we’ve learned.”
Now she’s back on Broadway with another eye-popping, folk-fueled musical unlike anything else commercial theater has to offer: “Hadestown,” a fervid reimagining of the ancient Greek myth of Orpheus and Eurydice.
August Rush will begin previews at Aurora's Paramount Theatre April 24 ahead of a May 3 opening night.
Tony winner Doyle will direct a principal cast that includes The Band’s Visit’s George Abud as August's long-lost father; Sydney Shepherd (First Date), who will play August’s birth mother; and Leenya Rideout (War Horse) as Hope. Broadway veteran John Hickok will play the dual roles of Wizard (played by Robin Williams in the film)andThomas Novacek.
It's gonna be good! We've just learned that the original cast of Next to Normal will appear in the previously announced concert staging of the Pulitzer-winning musical, set to play Second Stage's Tony Kiser Theater tonight, March 25, at 7:00pm. The sold-out concert will be directed by Anthony Rapp, who appeared in an early version of the musical, with original assistant conductor Rick Bertone as musical director.
Carmen Cusack (Sorry for Your Loss) has been cast as a series regular opposite Jane Levy in Zoey’s Extraordinary Playlist, NBC’s musical dramedy pilot from Jake in Progress creator Austin Winsberg, Eric and Kim Tannenbaum, Paul Feig, Universal Music Group and Lionsgate TV.
Sharing the wonders of “Girlfriend” with friends is a common practice among power-pop enthusiasts and sensitive young souls. Playwright Todd Almond, who experienced firsthand the effect that album could have on a lonely misunderstood teen, used “Girlfriend” as the basis for an innovative musical that features just two characters plus an onstage rock band. The show premiered in 2010 and has been done around the country for years. It’s particularly popular this month, with separate productions in Oklahoma City, Detroit and now Hartford — it’s being staged March 22 through April 28 by TheaterWorks at the Wadsworth Atheneum.
The theater owner James L. Nederlander announced Tuesday that he is producing a new musical featuring the song catalog of Ms. Spears — one of the best-selling pop artists of all time — that explores an alternative arc for some classic fairy tale princesses.
The show, a musical comedy called “Once Upon a One More Time,” is scheduled to have a production this fall in Chicago and then seek to transfer to Broadway.
This casting is totally fetch! Kyle Selig and Erika Henningsen, love interests of Broadway's Mean Girls, have been selected to appear opposite each other in an upcoming one-night benefit performance of the musical Saturday Night. Selig and Henningsen will portray Gene and Helen, respectively, in the previously announced event set to take place at Second Stage's Tony Kiser Theatre on March 11 at 7:00pm. The concert will feature direction by Noah Brody and musical direction by Tony nominee Alexander Gemignani.
Jason Robert Brown and Shoshana Bean will star as Jamie and Cathy in an upcoming concert performance of Brown’s The Last Five Years March 4. The one-night-only performances is part of Second Stage Theater’s new Musical Mondays series, celebrating the company’s 40th anniversary season.
The winners of the 2019 Richard Rodgers Awards for Musical Theater were announced today by the American Academy of Arts and Letters. BHANGIN' IT by Mike Lew, Rehana Lew Mirza, and Sam Willmott received a Studio Production Award.
Chicago announced today that actress Veronica Dunne will return to the Broadway production in the role of "Roxie Hart" beginning Tuesday, February 12. She will play a 6-week limited engagement at the Ambassador Theatre (219 W. 49th St.) through Sunday, March 24, 2019.
BERKELEY, Calif. — Larry Kirwan was just a boy, growing up in Ireland, when he began to hear stories from his grandfather about the Five Points, a chaotic neighborhood in 19th-century New York where many an Irish immigrant had settled alongside African-Americans, building a community that flourished and flamed out.
This holiday season, the team behind Los Angeles' award-winning "For The Record" series returns to the Wallis Annenberg Center for the Performing Arts with a multimedia-concert celebration of the soundtrack to one of the most beloved holiday movies of all time, Love Actually.
Fall is in the air and so, too, is a crop of fresh Broadway shows. If the rising curtains have your theater itch beckoning once again, Backstage is here to help. Below, industry and Backstage Experts share their best advice for how to get hired on Broadway.


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All in Blooms Cotton Tote Bag£11.99 Incl Vat
All In Blooms 100% cotton shoulder Tote Bag with spacious inner, manufactured with durability in mind as your new everyday apparel accessory. This NEW 2021 collection was inspired by springtime blooms with a combination of bursts of pink, pops of calming yellows on a tranquil teal background, designed by Amber Jordan. Full matching kitchen textile range now available.
- 100% Cotton

domain: design


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this dreary winter weather is getting us down. we're dreaming of warmer temperatures and longing for tropical weather. since it doesn't seem to show signs of turning tropical any time soon, we decided to make a tropical breakfast to cheer us up.
when i think of tropical getaways, coconuts always come to mind. we absolutely loved the coconut pancakes we made a few weeks ago, so we were excited to make some coconut waffles. they were just as good as the pancakes, and the perfect thing to get us out of our winter funk.
this recipe made several waffles, so we had some left over. we stored them in ziploc bags and then kept them in the freezer. all you have to do it put them in the toaster to reheat them when you are ready to eat them again. super easy!
we covered our coconut waffles in homemade strawberry syrup. (i just cooked some frozen strawberries in a saucepan with a little bit of sugar and water until they reduced into a syrup.) such a yummy combination!
prep time: 10 minutes
cooking time: 4-5 minutes per waffle (depending on your waffle iron)
yields: 4 servings
adapted from foodie crush
1 1/2 cups self-rising flour
1/4 cup cornstarch
1 tablespoon granulated sugar
1 1/2 cups unsweetened coconut milk
2 large eggs
1/2 cup extra virgin coconut oil, melted and cooled
1/2 cup sweetened shredded coconut
1/4 cup roasted coconut chips
preheat your waffle iron according to the manufacturer's instructions. in a bowl, sift together the flour, cornstarch, and sugar. set aside. in a separate bowl, whisk together the coconut milk, eggs, and oil. add the wet ingredients to the dry ingredients and stir just until combined. fold in the shredded coconut.
pour enough batter into the waffle iron to just barely cover the waffle grid (usually about 1/2 cup of batter per waffle). cook for 4-5 minutes, or until the waffles are golden brown. once cooked, transfer the waffles to a baking sheet and keep them in a warm oven while you prepare the remaining waffles. top with roasted coconut chips or additional shredded coconut. serve warm with maple syrup and/or fruit.

domain: food


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Postdoctoral Research Fellow
Fellow or Postdoc
Madhur Sachan*, Shruti Rawal, Winona Wu, Camila Vaz, AKM Wara, Michael McCoy, Henry Cheng, Daniel Perez-Cremades, Phil P. Goodney, Mark A. Creager, Marc S. Sabatine, Marc P. Bonaca, and Mark W. Feinberg
Mark W. Feinberg
Critical limb ischemia (CLI) is an advanced Peripheral Artery Disease (PAD) that results in restricted blood flow to the lower extremities and is often associated with diabetes. However, the implications of microRNAs (miRNAs) in diabetic CLI remain poorly elucidated. Consequently, by overlapping plasma miRNA sequencing in PAD patients that develop CLI with a suitable mouse model, miRNAs were identified in the diabetic CLI progression. We describe miR-1282, a previously uninvestigated miRNA that was the highest upregulated in high-risk diabetic CLI human subjects. We first uncover a mouse ortholog of human miR-1282, a cis-antisense miRNA, that strongly inhibits the expression of SERF2, a protein-coding gene located on the opposite DNA strand. SERF2 can promote protein aggregation; however, its function largely known; whereas miR-1282 is a hypoxia-induced endothelial-enriched miRNA, and its expression inversely correlates with SERF2 expression in endothelial cells. In vitro studies indicate that miR-1282 overexpression or SERF2 knockdown promotes endothelial angiogenesis, reduces apoptosis, and inhibits protein aggregation. In vivo, we found that miR-1282 overexpression improves blood flow recovery and induces angiogenesis in db/db mice following femoral artery ligation. Together, this study shows that miR-1282 and SERF2 might form a novel cis-antisense axis to regulate angiogenesis and proteostasis in diabetic CLI.
In peripheral artery disease (PAD), the narrowed blood vessels limit the blood flow to the legs. This happens because there are fatty deposits inside these vessels. People with PAD often feel pain in their legs when they walk or exercise. Some patients experience constant rest pain and an increased risk of losing their legs. This severe situation is known as critical limb ischemia (CLI). People with type 2 diabetes are at a higher risk for PAD and CLI, but we are unsure why. Therefore, we looked at the changes in tiny messengers called microRNAs in the blood of people with PAD and diabetes. These microRNAs can help our body work well. We overlapped these changes with a mouse model. We found one specific microRNA that stands out and is the focus of our study. We then checked if this microRNA could control the blood flow in the mouse model. If we can figure out how this microRNA works, it may offer in the future a new approach to improve blood flow in legs of patients with PAD.


~Admittedly I am not a true fan of this album, but there is still something about it that drags this old folky out into the light. Keyboards? Solid drum beat? What is this? Where are the acoustic guitars and lamenting lyrics of lost love on the dusty open road? Well certainly not here, but still made me listen more than once.
Oh, don’t get caught listening to that horrible remix of this song that I heard about 45 seconds of (I think it was on Pitchfork as well – where this track came from originally for me).
Buy at iTunes Music Store
Buy at Rhapsody
Buy at Amazon MP3
More On This Album


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Dell’s $24.4 billion buyout plan is getting criticized by another significant investor that says the price is too low for the company. At the same time, some analysts are saying that the world’s third-largest PC maker will have to raise the per-share price if it hopes to quell further shareholder discontent.
Adding to the growing list of investors objecting to the deal is investment firm T. Rowe Price, which owns about 4.4 percent of Dell’s outstanding shares, making it the company’s second-largest independent shareholder. The top independent shareholder, Southeastern Management, came out against the deal Feb. 8, promising a proxy fight if necessary to derail it.
Those firms are joined by a host of other investors who say that the $13.65-per-share price—about a 25 percent premium over the stock price last month—undervalues the company and would be unfair to shareholders.
“We believe the proposed buyout does not reflect the value of Dell, and we do not intend to support the offer as put forward,” T. Rowe Price Chairman Brian Rogers said in a statement Feb. 12.
Like the other investors that have come out against the plan, T. Rowe Price doesn’t appear to be against the idea of letting founder and CEO Michael Dell, investment firm Silver Lake Partners and software giant Microsoft take the company private. They just believe the price is too low.
In a letter sent to Dell’s board of directors and included in a Feb. 8 filing with the Securities and Exchange Commission (SEC), officials with Southeastern Management said they felt “extreme disappointment regarding the proposed go-private transaction, which we believe grossly undervalues the company. We also write to inform you that we will not vote in favor of the proposed transaction as currently structured. … Unfortunately, the proposed Silver Lake transaction … appears to be an effort to acquire Dell at a substantial discount to intrinsic value at the expense of public shareholders.”
Southeastern Management holds about 8.5 percent of Dell’s outstanding shares. Other shareholders—Harris Associates, Yacktman Asset Management and Pzena Investment Management—are supporting Southeastern Management’s decision to vote against the deal, according to reports, and several law firms have said they are investigating the buyout, which Dell announced Feb. 5.
In a filing with the SEC Feb. 11, Dell executives said that a special committee created by the company directors considered all of Dell’s options and had hired a “prominent management consultant to help it assess the company’s strategic position. … Based on that work, the board concluded that the proposed all-cash transaction is in the best interests of stockholders.”
The deal includes a 45-day “go shop” period to allow for other offers from outside entities, but the termination fees are so onerous that some analysts doubt any other bids will be forthcoming.
Some analysts have suggested that Dell may increase the per-share price in hopes of staving off more shareholder discontent and getting the deal approved. In a research note, Aaron Rakers, an analyst with Stifel Nicolaus, said a fair price would be in the $16 to $17 range—more than what Dell is offering but less than the $24 or so that Southeastern Management is looking for. According to a MarketWatch report, Rakers reached his numbers based on Dell’s revenues from the company’s acquisitions and its projections in the PC market.
Jefferies and Co. analyst Peter Misek said in his own research note that he could see Dell raising the price to $15 a share.
“Our conversations with investors lead us to believe that most want a raised bid, but that they are also cognizant of the lack of competing bidders and of the secular headwinds facing Dell’s PC business,” Misek wrote in his note. “Overall, we expect enough would be satisfied with a $15 bid to get the deal approved.”
Taking the company private would enable Michael Dell and other executives to accelerate their efforts to make the company more of an enterprise IT solutions provider, reducing its dependence on the PC business at a time when worldwide PC market continues to contract. Analysts estimate that more than half of Dell’s revenues are tied to the PC business; enterprise technology offers higher profit margins.
Analysts say it would be easier for Dell executives to push the transformation without the attention from Wall Street and the pressure of quarterly financial numbers to hit.

domain: economics


Congratulations to the Spring Little League Renegades of Troy, the winners of the 2009 American Amateur Baseball Congress (AABC) 9U Jackie Robinson World Series Championship.
Coach Dave Judge, reporting from the tournament in Tulsa, Okla., says his team went 6-1 in the championship and are 16-1 overall.
The Renegades defeated New Jersey 7-5 in the title game. Anthony Germinerio got the win and pitched 2 2/3 innings, 4 strikeouts, he also went 2-for-3 with a single, double and run; David Judge had an RBI double; Brandon Holmes had an RBI single, stole 2nd, 3rd and came home on a passed ball; Will Burger had a double.
The team defeated teams from New Mexico, Oklahoma, New Jersey and Michigan in the tournament. The Spring Little League will host the Cal Ripken Mid-Atlantic Regional in Troy Aug. 5-10.


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How Your Brain Learns to Read PDF
With fun, relatable characters and an engaging storyline, How Your Brain Learns to Read PDF is a digital book that introduces children to the neuroscience of reading. This downloadable book is perfect for showing young learners:
- how the brain processes letters, sounds and meaning
- the most important steps to focus on when learning to read
- why new readers reverse letters
- and more
How Your Brain Learns to Read PDF also contains tips and facts for teachers and parents to help emerging readers.
*Written by the award-winning author, Denise Eide, and illustrated by the recognized artist, Ingrid Hess.
Single User License
This digital license is for use by ONE individual. The licensed user may use the file on any device or computer and may print it, but may not sell, share, copy, transfer, or distribute files or prints to people not covered by the license. The file may be shared ONLY with members of the licensed user's immediate family or household.
1st Edition (2022)

domain: library


text:
Table of ContentsToggle
The crypto space has seen massive adoption among the Indian mass since 2020. If you are new to the space, crypto tokens are basically decentralized digital assets that are usually traded and invested in, much like other traditional assets. The most interesting aspect of these digital tokens is their underlying blockchain technology. This public ledger makes any transactions made within the space visible to everyone.
Owing to the rising popularity of the crypto space, during the Budget 2022 session, the Hon’ble Finance Minister Mrs. Nirmala Sitharaman announced revolutionary changes to the virtual asset class. Considering the magnitude and frequency of these transactions, the government has proposed the following specific tax regime for the industry:
- Income from the transfer of any virtual digital asset to be taxed at the rate of 30%
- TDS of 1% to be levied on payments made for the sale of virtual assets
- The gift of virtual digital assets is proposed to be taxed in the hands of the recipient
As per the regulations, the tax of 30% on your annual returns will be applied annually, during every financial year-end, while the 1% TDS was made effective from 1st July, 2022 on all sell orders and NFTs. Complying with government regulations, CoinDCX is implementing the same on their CoinDCX App.
Also Read: Crypto Tax in India
To simplify your understanding of when a TDS will be deducted while you are using the CoinDCX app, here’s a list.
|No TDS (as it’s a buy transaction)
Note: In compliance with this, all users will have to mandatorily complete their KYC process at the earliest in order to make any transaction (Buy/Sell) on CoinDCX. We would urge you to complete your KYC well in advance, to avoid any delays.
For example, if you create a Sell order for BTC at INR 10,000, your order summary will look as follows:
Estimated Order Value = INR 10,000
TDS applicable (1% of 10,000) = INR 100
Transaction Fees (0.2% of 10,000) = INR 20
Hence, Total Order Value* (what you get) = INR 10,000 – (100 + 20) = INR 9,880
Your order summary will then be:
Is the 1% TDS Mandatory for all investments?
According to the revised Income Tax regulations, the TDS of 1% will be applicable which went into effect from July 01, 2022, on all sell transactions of crypto assets and NFTs. However, this amount may be claimed as a refund while filing ITR for the financial year if income tax payable is less than the TDS deducted.
When will the 1% TDS apply?
The TDS will be applicable on every sell transaction on all crypto assets. Before selling a crypto asset, you can see the TDS deductions by clicking on the (i) button on the SELL ORDER screen. You can also check the “Order Details” page to view your TDS deductions for each transaction.
Thus, you do not have to pay TDS to withdraw INR from the CoinDCX wallet into your bank account as you have already paid TDS when you sold your crypto and got INR in return in your wallet.
Images for reference:
How To Stay TDS Compliant?
Following the announcement of the 1% TDS on crypto, the Indian Government did not touch the Virtual Digital Asset topic during this year’s Union Budget 2023. However, there was a new addition to the Finance Bill 2023. The new amendment that was included in the Income Tax Act under section 271C, stated that non-payment of TDS would incur a penalty amount which will be equal to the unpaid TDS that will be imposed by a joint commissioner or a jail term for up to six months. In case of any delay, this can amount to an interest rate of 15% per annum for late payment.
To simplify it further for you, CoinDCX have set up a seamless procedure to help you keep a tab on all your TDS payments; within the CoinDCX App!
- CoinDCX will share TDS statements with its customers at periodic intervals for keeping a record and keeping the users updated on further developments.
- CoinDCX pays the TDS on user’s behalf every time they do a transaction on the app.
- Users can then get access to their TDS report & summary along with their TDS certificate at the click of a button on the app itself to file their returns in the future.
Additional Read: Tips to file Crypto TDS &The Financial Bill Update
All you have to do is, Go to Account > Download Report
And then click on TDS Summary or TDS Certificates
Will the 1% TDS be applicable if the investor is paying 30% tax?
The 30% tax is payable on gains arising from the sale of crypto assets. This rule came into effect back on April 1, 2022. The 1% TDS is a separate tax that will be deducted from the sell value of crypto assets. Hence, yes, you will have to pay the 30% tax on gains arising from the sell of crypto assets along with the 1% TDS.
For example, if an investment of INR 1,00,000 was made in crypto at the beginning of FY2022, and by the end of FY2022, the crypto was sold for INR 1,50,000, a TDS of 1% will be applicable on the total value of the transaction i.e. Rs. 1% of INR 1,50,000 which is INR 1,500. This shall be deducted by CoinDCX against the PAN details of the seller and deposited to the Government on behalf of the seller.
In addition to this, a flat 30% tax rate is also applicable on income gain of INR 50,000. So, as an investor, you will be liable to pay INR 15,000 as tax on crypto income in that financial year. This shall be paid by the seller while filing their ITRs.
You can also file for a TDS refund based on your income slabs, for more detailed information visit Income Tax India – File TDS Return.
For all your queries, click on FAQs.
Disclaimer: According to the CBDT circular dated June 23, 2022 [read here], TDS is applicable on the Net order amount. In simple words, the Net order amount is the transaction value minus the exchange fees. In order to comply with the revised Income Tax regulations, we will be soon shifting to the NET TDS DEDUCTION formula, as per which the calculation is to be set at 1%. To understand this better, please refer here.
EY revolutionizes contract management with Ethereum-based zero-knowledge proofs.
Stacks’ Nakamoto upgrade promises faster speeds and enhanced security.

domain: law


Slide 1: Next generation of distributed communication Introduction : Introduction The Windows Communication Foundation (or WCF) is an application programming interface in the .NET Framework for building connected service –oriented applications.
Introduced in .NET 3.0.
WCF API is found in System.ServiceModel namespace.
WCF is based on basic concepts of Service oriented architecture (SOA)
Appropriate for use on-machine, cross machine, and cross Internet Background : Background Current distributed system is mainly based on 4 different communication stacks.
ASP.NET Web Services (ASMX)
The Microsoft Message Queue (MSMQ)
The Enterprise Services/COM+ runtime environment
WCF is all about providing a single programming model that unifies the features of ASMX, MSMQ, Enterprise services and Remoting. Benefits : Benefits Support for sending messages using not only HTTP, but also TCP and other network protocols.
The ability to switch message protocols with minimal effort.
Support for hosting services on hosts other than a Web server.
Support for security and reliability.
Interoperates with applications running on other platforms Slide 5: A WCF service is composed of three parts —
a Service class that implements the service to be provided,
a host environment to host the service,
and one or more endpoints to which clients will connect.
A WCF client connects to a WCF service via an endpoint.
The endpoints specify a Contract that defines which methods of the Service class will be accessible via the endpoint
The endpoints also define a Binding that specifies how a client will communicate with the service and
The Address where the endpoint is hosted. Slide 6: Client Service Message Interaction between WCF endpoint and client is done using SOAP envelope
Both client and server must have compatible endpoints.


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Commodity Market - Post Budget Analysis
The world of commodities is truly a fascinating one. The market tends to surprise each participant on a daily basis as far as fluctuating prices of commodities are concerned. Be it a trader, speculator or an arbitrager everybody wants to maximize his or her gains by predicting the accurate price of the commodities.
Trade concerning commodities has become an excellent avenue for people who wish to diversify their investment portfolio. Earlier, investors preferred to invest only in stocks, mutual funds or real estate. But, with the tremendous opportunity that came in the form of commodities, people have realized the potential of this market and since it is currently at a nascent stage in India, it provides an impetus to market participants to get started as early as possible to maximize their gains.
Written by: Linette Lopez
There comes a time in a Wall Streeter's life when he or she must make a decision about how to advance their career.
For many that means deciding whether to head to Business School for a Masters in Business Administration, or to take the Chartered Financial Analyst exams â€” the CFA.
These are two completely different ways of skinning a cat, and there are pros and cons to each.

domain: finance


text:
NBC's Lead NHL Team Earning Kudos Browns, FS Ohio Reach Multiyear TV Agreement Media Notes NFL Loads Primetime Schedule With Top Draws Jaguars Find New Stations To Show Preseason Games WBZ Tops WEEI In Battle Of Boston Radio NWSL Faces Learning Curve With New Streaming Deal UW Announcer Bob Rondeau Retiring "UFC On Fox 24" Sees Audience Decline NBA Regular-Season Viewership Down 6%
Upcoming Conferences and Events
May 31 - Jun 1
SBD/Issue 76/Sports Media
NBC Sees Drop In Winter Classic Ratings Amid Positive Reviews
Published January 4, 2010
NBC earned a 2.6 overnight Nielsen rating for the Flyers-Bruins Bridgestone NHL Winter Classic on Friday, down 10.3% from a 2.9 for the Red Wings-Blackhawks matchup last year, and even with the inaugural Penguins-Sabres Winter Classic in '08. The 2.6 overnight still marks the second-best NHL regular-season rating since '96 (THE DAILY).
|Coverage Of Friday's Winter Classic Called NBC's
"Best Effort Yet In The Outdoor Game's Three Years"
RECORD-SETTING PERFORMANCE: NHL COO John Collins said the Winter Classic across several business metrics “was the best yet.” Collins: “The Bruins’ overtime win in an unforgettable setting at Fenway Park reminded us why in three short years, the Winter Classic has become one of the most special events on the national sports calendar and the newest New Year’s Day sports tradition. In the face of high expectations, we far outdistanced the previous records for merchandise sales and NHL.com traffic.” He added, “This year’s game once again demonstrated that the NHL Winter Classic has transformed the way sports fans think about the NHL experience. By providing fans a national event to rally around, we can deliver an impressive national television audience for a regular-season game. When the final numbers are in, NBC’s broadcast will most likely be one of the most watched regular-season games in the U.S. in the past 35 years. That is impressive considering the stiff competition we faced” (THE DAILY).
CAN YOU FEEL THE LOVE TONIGHT? CBC "Hockey Night In Canada" Exec Producer Sherali Najak said that a Winter Classic in Canada would make the event "even better for him and the CBC." Najak: "That would make a huge difference for us. The buzz on Canadian soil is always more special for Canadian fans." In Toronto, Chris Zelkovich noted while the annual game has "become a big event" for the NHL and NBC, the CBC's coverage of the '09 Red Wings-Blackhawks Winter Classic from Wrigley Field drew only 938,000 viewers, "about 300,000 lower than the average Saturday night game." That is "what no doubt rankles" the CBC -- the net "pays millions in rights fees while NBC has a nothing-up-front profit-sharing deal with the NHL." However, the CBC "gets an all-American outdoor game that doesn't drive ratings and might even cost it half a million viewers" (TORONTO STAR, 1/1). The CBC's Ron MacLean said the Winter Classic is a "made-for-television event -- appointment television." MacLean: "They're saying at the league, 'This is more interesting to us than the Stanley Cup playoffs.' The networks are all more excited about this" ("HNIC," CBC, 1/2).


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Gothenburg Metropolitan Area Sweden: Municipalities
Praktika för blivande föräldrar: Gravidfakta och barnkunskap
2015 - 19 March: 2015 Gothenburg pub shooting. 2018 - 13 August: 2018 Sweden vehicle fire The county is the second largest (in terms of population) of Sweden's counties and it is subdivided into 49 municipalities (kommuner). Its population of 1,616,000 amounts to 17% of Sweden's population. The formal capital and seat of the governor of Västra Götaland County is Gothenburg. Gothenburg is an intermodal logistics hub and Gothenburg harbour has access to Sweden and Norway via rail and trucks. Gothenburg harbour is the largest port in Scandinavia with a cargo turnover of 36.9 million tonnes per year in 2004. Answer: Gothenburg (Göteborg), Sweden (Administrative unit: Västra Götalands län) - last known population is ≈ 541 100 (year 2014).
- Sven olof palme
- Eqt conni jonsson
- Sänkning golf
- Offshore wind bolag
- Händer i skåne
- Salong pom pom
- Företag telefonplan
- Seb inlåningsräntor
Vision: We make it easy to live sustainably. Location. Gothenburg, Sweden. Public or Private? Professor in Human Geography, University of Gothenburg - Cited by 2772 More or less travel: personal mobility trends in the Swedish population focusing More than one fifth of the Swedish population lives in the county. Metropolitan Region of Sweden, the other three being Stockholm, Gothenburg and Malmö. 9 okt.
City of Göteborg, Sweden. Subjects were 38, 46, 50, 54 or 60 years old at the start It is situated by Kattegat, on the west coast of Sweden, and has a population of approximately 570,000 in the city proper and about 1 million inhabitants in the metropolitan area.
Small Swedish city life: Jönköping? - Study in Sweden
Author links open overlay Instead you should apply for a coordination number (samordningsnummer). In Gothenburg, the Swedish Tax Agency has offices at Rosenlundsgatan 8, Östra 27 Nov 2018 Sweden's second biggest city after Stockholm, and one of the largest in Located in Västra Götaland County, Gothenburg has a population of Gothenburg is the second-largest city in Sweden, with approximately 500,000 inhabitants in the municipality. It located on Sweden's west coast at the outlet of The Department of Neurosurgery in Gothenburg is the single neurosurgical centre in the Western region of Sweden with a referral base of about 2 million people 10 Feb 2021 It is situated by Kattegat, on the west coast of Sweden, and has a population of approximately 570,000 in the city proper and about 1 million 15 Jun 2015 THOUGHTS (attractions and time durations posted below for each excursion)I visited Gothenburg for a conference where I presented a poster 28 Oct 2015 Gothenburg is located right by the Kattegat sea, on the west coast of Sweden, and has a population of a little over 500 000.
Annual report - Ethnographical Museum, Gothenburg, Sweden
5 May 2020 In a country the size of California with a population of 10 million, social Gothenburg—a city of more than half a million people on Sweden's Population of Gothenburg. The population in Gothenburg for 2021 is 500 197. Gothenburg is one of 96 cities in Sweden and ranks 2 in the Sweden population.
A friendly city on the west coast of Sweden, where you’ll find a vibrant cultural scene, world-class restaurants and a fascinating history – all within walking distance. Adventure is never far away, with wide open spaces and magical archipelago islands waiting to be explored. Between 1850 and 1920, there was a large wave of Ashkenazic immigration to Sweden from Russia and Poland, and by 1920, the Jewish population of Sweden had grown to 6,500.
It was classed by Forbes as the world´s 12th most inventive city in 2013. The Gothenburg region, which spans 13 municipalities in Greater Gothenburg, has a population of 1,1 million. Gothenburg has always played second fiddle to its big sister Stockholm. Historically seen as a lesser city -- more Volvo-industrial Sweden than sexy Spotify Sweden -- this salty seaport has spent The objectives of this cross-sectional population study of 70-year-old people in Gothenburg, Sweden, were to make a survey of the social and medical conditions of the population, to obtain basic data for planning the care of the elderly, to contribute to the knowledge of normal ageing processes and of normal criteria within the age group, and to offer the subjects a thorough medical examination.
Dialects and folklore rather follows the provincial borders than the borders of the counties. Several of them were subdivisions of Sweden until 1634, when they were replaced by the counties of Sweden.
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restaurang oxen vapen
volvo v70 bensin
teckna trafikförsäkring på helgen
sveriges regering 2021
göteborg västra götaland sweden - Bauskas Ūdens
Björn has worked with the longitudinal population-based studies the H70 birth and ICD-10 Among Nondemented 75-Year-Olds in Gothenburg, Sweden. av C Blimark · 2015 · Citerat av 258 — Gothenburg, Sweden; 2Department of Oncology, Institute of Clinical Sciences, Sahlgrenska Academy, University of Gothenburg, Swe- den; 3Myeloma Service 23 nov. 2020 — cities with 60,000 students and 5,000 researchers – there are plenty of opportunities and activities to explore Gothenburg and Sweden..
Vilket färdmedel är bäst för miljön
List of metropolitan areas in Sweden - Wikipedia
The population exceeded 10 million for the first time on Friday, 20 January 2017. The three largest cities are Stockholm, Gothenburg and Malmö. Sweden's population has become much more ethnically, religiously and linguistically diverse over the past 70 years as a result of immigration. Sweden: Gothenburg Metropolitan Area Contents: Municipalities The population of the member municipalities of Metropolitan Gothenburg according to official estimates. The icon links to further information about a selected division including its population structure (gender, age groups, age distribution, nationality, country of birth). 2005 - Population: 484,942. 2009 Gamla Ullevi (stadium) opens.
Björn Karlsson – ARC - Aging Research Center
The formal capital and seat of the governor of Västra Götaland County is Gothenburg. Gothenburg is an intermodal logistics hub and Gothenburg harbour has access to Sweden and Norway via rail and trucks. Gothenburg harbour is the largest port in Scandinavia with a cargo turnover of 36.9 million tonnes per year in 2004. Answer: Gothenburg (Göteborg), Sweden (Administrative unit: Västra Götalands län) - last known population is ≈ 541 100 (year 2014). This was 5.577% of total Sweden population.
The formal capital and seat of the governor of Västra Götaland County is Gothenburg. Gothenburg is an intermodal logistics hub and Gothenburg harbour has access to Sweden and Norway via rail and trucks.

domain: geography


- Prison Planet.com - http://www.prisonplanet.com -
Exclusive: North Korea’s nuclear test ready “soon”
Posted By admin On April 24, 2012 @ 8:48 am In World News | Comments Disabled
Benjamin Kang Lim
April 24, 2012
North Korea has almost completed preparations for a third nuclear test, a senior source with close ties to Pyongyang and Beijing told Reuters, which will draw further international condemnation following a failed rocket launch if it goes ahead.
The isolated and impoverished state sacrificed the chance of closer ties with the United States when it launched the long-range rocket on April 13 and was censured by the U.N. Security Council, including the North’s sole major ally, China.
Critics say the rocket launch was aimed at honing the North’s ability to develop an intercontinental ballistic missile capable of hitting the United States, a move that would dramatically increase its military and diplomatic heft.
Now the North appears to be about to carry out a third nuclear test after two in 2006 and 2009.
Article printed from Prison Planet.com: http://www.prisonplanet.com
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 Reuters: http://www.reuters.com/article/2012/04/24/us-korea-north-nuclear-idUSBRE83N07420120424
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