With the holiday season nearly upon us and in order to plan your activity in readiness for it, I have written a series of tips to help you on your way.
A good deal of stress comes from lack of preparation and being organised is the key to ensuring a stress-free and enjoyable couple of weeks. So use the list and tick things off as you go.
Tip 1: Going away abroad for Christmas. Have you ordered your foreign currency? Don't leave it until the last minute. Who will water the plants feed the fish and look after the house?
Tip 2: Give yourself a target to lose the 'X' number of pounds that you will probably put on over the holiday period. Lose it now and then you will have some kilos in hand! Don't even think about procrastinating!
Tip 3: Children soon breaking-up for holidays. What jobs do you need to do before they are at home 24/7? Save time and energy by setting tasks in order of priority. Less stress and certainly more smiles!
Tip 4: Finished buying presents or are you going to be a last-minute stressed-out shopper? Order online to save travelling to the shops and ask everyone what they want. Easier than them having to return goods afterwards! There is still time!
Tip 5: Having people over on Christmas day? Have your forgotten anyone? Some relatives or neighbours may be lonely. This is a time to put any past quarrels to one side and move on. It can be lonely time for many as well as fun for others.
Tip 6: Make a time to wrap your presents and don't leave it to the last moment. Have you bought the wrapping paper and cello tape? Do you need to buy any boxes for sending presents abroad?
Tip 7: Entertaining at home? Have you got in everything you need? Try and avoid the queues to save your stress levels. Shop early is the key to good stress management.
Tip 8: Get writing those last-minute cards. You have no time to waste! And don't forget that ecards or epostcards are a great way of keeping in touch.
Tip 9: Clear the house. Tidy your office at home. Tidy the kitchen and the living room and your bedroom wardrobes. If you havn't worn something for over two years — it is time to take it to the charity shop! Decluttering can make you feel really good!
Tip 10: Christmas party to go to? Make sure you don't regret your behaviour and indiscretions when you get back to the office! You still have to work with the boss and your colleagues in January! Office parties are still office activities, even though they may not take place on the premises.
Tip 11: Flying off somewhere? Don't forget to turn off your mobile phone and voice mail service. It's very expensive to pick-up calls when abroad! Call the credit card companies to tell them you will be away. Travel insurance up to date? Get your list together of things to take with you.
Tip 12: Laying the table for family and guests? Last minute things to do? Go through your check-list. Just ticking things off is very satisfying! Serviettes, table cloth and have you got enough cutlery and chairs!
Tip 13: Enjoy the festivities with friends or family. But spare a thought for others who may be lonely. Maybe pop into your neighbour with a home-made offering. If you've eaten too much, go for a 30-minute walk. If you have nothing to do, then maybe give your time to a charity or your local community. They will benefit and so will you!
Tip 14: Use your holiday time effectively so that your body can recharge its battery. How about going through your photographs and putting them into order on your computer and make sure they are all backed up!
The holiday period, like any other, needs planning and it is a good opportunity to tick those entries off of your 'nice to do' list. Those are the things that you never really get round to doing, so why not make this time of the year, an enjoyable, satisfying time and stress-free!


Being invited into that tiny slice of time in a couple's journey when they are waiting for their first baby to arrive still gets me each and every time. It's full of anticipation, excitement, nervousness and a whole lot of unknown. That's the way it should be. That's parenthood. A lot of unknown coupled with a whole lot of love that will get you through it all.
Maternity sessions are so fun for me. If it's a first child (as in this session), the session tends to be slow, relaxed and quiet with lots of time to chat and get to know each other. That's important, because when I come back and photograph that tiny little soul that's now part of your family, all of the introductions and nervousness is gone. I'm just a friend coming into your house to hang out with you for a few hours (with a camera) and we can pick up right where we left off. We also get a chance to go over all of the little details about the upcoming newborn session. I also love maternity photo sessions as they are a chance to try new things, play with light in fun and interesting ways and do a little bit of posing. Yes, I know, I usually go on and on about how posing isn't for me – but I do love the challenge of finding unique spots and beautiful light in a home. Little pockets of light. Then, when I get to add a Mama-to-be in that light, I'm a very happy photographer.
It's important for me to do maternity sessions in your home. Home is where your story unfolds, so it's only fitting that it's where we will document this new beginning. I want you to be surrounded by the things that you love. The things that have meaning to you. The nursery you've poured hours of work into, your fur babies, that chair you know you're going to spend endless hours in once your baby arrives. Show your baby how his story began. Because at some point, he will ask.
I'm looking forward to seeing this family again soon, meeting their little guy, and capturing his beautifully real family moments in the year to come. Thank you A & C for trusting me with capturing your journey.
Fiddle Leaf Photography offers maternity, newborn and family photography in Edmonton, Sherwood Park, St. Albert and surrounding areas. Send me a note using the "Let's Chat" tab and we can chat all about your beautiful growing family.
Interested in learning how to use your phone to capture your own beautiful moments? Sign up for the newsletter and receive a free copy of the e-book: You Family. Your Phone. Your Guide to Capturing Beautiful Memories. Be sure to follow along on Facebook and Instagram for all the latest news and images.


text:
"""
Handling of VM disk images by handler.
"""

import urlparse

from oslo.config import cfg
import stevedore

from nova import exception
from nova.image import glance
from nova.openstack.common.gettextutils import _
from nova.openstack.common import log as logging

LOG = logging.getLogger(__name__)

image_opts = [
    cfg.ListOpt('image_handlers',
                default=['download'],
                help='Specifies which image handler extension names to use '
                     'for handling images. The first extension in the list '
                     'which can handle the image with a suitable location '
                     'will be used.'),
]

CONF = cfg.CONF
CONF.register_opts(image_opts)

_IMAGE_HANDLERS = []
_IMAGE_HANDLERS_ASSO = {}

def _image_handler_asso(handler, path, location, image_meta):
    _IMAGE_HANDLERS_ASSO[path] = (handler, location, image_meta)

def _image_handler_disasso(handler, path):
    _IMAGE_HANDLERS_ASSO.pop(path, None)

def _match_locations(locations, schemes):
    matched = []
    if locations and (schemes is not None):
        for loc in locations:
            # Note(zhiyan): location = {'url': 'string',
            #                           'metadata': {...}}
            if len(schemes) == 0:
                # Note(zhiyan): handler has not scheme limitation.
                matched.append(loc)
            elif urlparse.urlparse(loc['url']).scheme in schemes:
                matched.append(loc)
    return matched

def load_image_handlers(driver):
    """Loading construct user configured image handlers.

    Handler objects will be cached to keep handler instance as singleton
    since this structure need support follow sub-class development,
    developer could implement particular sub-class in relevant hypervisor
    layer with more advanced functions.
    The handler's __init__() need do some re-preparing work if it needed,
    for example when nova-compute service restart or host reboot,
    CinderImageHandler will need to re-prepare iscsi/fc link for volumes
    those already be cached on compute host as template image previously.
    """
    global _IMAGE_HANDLERS, _IMAGE_HANDLERS_ASSO
    if _IMAGE_HANDLERS:
        _IMAGE_HANDLERS = []
        _IMAGE_HANDLERS_ASSO = {}
    # for de-duplicate. using ordereddict lib to support both py26 and py27?
    processed_handler_names = []
    ex = stevedore.extension.ExtensionManager('nova.virt.image.handlers')
    for name in CONF.image_handlers:
        if not name:
            continue
        name = name.strip()
        if name in processed_handler_names:
            LOG.warn(_("Duplicated handler extension name in 'image_handlers' "
                       "option: %s, skip."), name)
            continue
        elif name not in ex.names():
            LOG.warn(_("Invalid handler extension name in 'image_handlers' "
                       "option: %s, skip."), name)
            continue
        processed_handler_names.append(name)
        try:
            mgr = stevedore.driver.DriverManager(
                namespace='nova.virt.image.handlers',
                name=name,
                invoke_on_load=True,
                invoke_kwds={"driver": driver,
                             "associate_fn": _image_handler_asso,
                             "disassociate_fn": _image_handler_disasso})
            _IMAGE_HANDLERS.append(mgr.driver)
        except Exception as err:
            LOG.warn(_("Failed to import image handler extension "
                       "%(name)s: %(err)s"), {'name': name, 'err': err})

def handle_image(context=None, image_id=None,
                 user_id=None, project_id=None,
                 target_path=None):
    """Handle image using available handles.

    This generator will return each available handler on each time.
    :param context: Request context
    :param image_id: The opaque image identifier
    :param user_id: Request user id
    :param project_id: Request project id
    :param target_path: Where the image data to write
    :raises NoImageHandlerAvailable: if no any image handler specified in
        the configuration is available for this request.
    """

    handled = False

    if target_path is not None:
        target_path = target_path.strip()

    # Check if target image has been handled before,
    # we can using previous handler process it again directly.
    if target_path and _IMAGE_HANDLERS_ASSO:
        ret = _IMAGE_HANDLERS_ASSO.get(target_path)
        if ret:
            (image_handler, location, image_meta) = ret
            yield image_handler, location, image_meta
            handled = image_handler.last_ops_handled()

    image_meta = None

    if not handled and _IMAGE_HANDLERS:
        if context and image_id:
            (image_service, _image_id) = glance.get_remote_image_service(
                                                            context, image_id)
            image_meta = image_service.show(context, image_id)
            # Note(zhiyan): Glance maybe can not receive image
            # location property since Glance disabled it by default.
            img_locs = image_service.get_locations(context, image_id)
            for image_handler in _IMAGE_HANDLERS:
                matched_locs = _match_locations(img_locs,
                                                image_handler.get_schemes())
                for loc in matched_locs:
                    yield image_handler, loc, image_meta
                    handled = image_handler.last_ops_handled()
                    if handled:
                        return

        if not handled:
            # Note(zhiyan): using location-independent handler do it.
            for image_handler in _IMAGE_HANDLERS:
                if len(image_handler.get_schemes()) == 0:
                    yield image_handler, None, image_meta
                    handled = image_handler.last_ops_handled()
                    if handled:
                        return

    if not handled:
        LOG.error(_("Can not handle image: %(image_id)s %(target_path)s"),
                  {'image_id': image_id, 'target_path': target_path})
        raise exception.NoImageHandlerAvailable(image_id=image_id)

redpajama_set_name: RedPajamaGithub


Premium leather,sturdy support and rough-and-ready detail make the 6\ Premium Canvas Boot from Timberland® a choice for those who are serious about quality footwear.
Fully cushioned collar helps prevent ankle discomfort for all-day wear.
Lace-up closure for a customized and secure fit.
Mesh linings are made with 50% PET (recycled plastic bottles).
Leather-covered footbed with light cushioning delivers additional climate control and comfort.
Anti-Fatigue midsole uses geometric cone support to provide exceptional standing comfort and shock absorption.
Rubber lug outsole delivers traction and durability on varied terrain to maintain your sturdy stride.
Product measurements were taken using size 11.5,width D - Medium. Please note that measurements may vary by size.


This paper investigates the performance of available models of acoustic surface loss for small grazing angles of incidence, and for lower wind speeds for which bubble formation is less likely to play a role. In order to investigate the expected importance of shadowing for these scenarios, a wave-type model has been run with a deterministic simulation of the surface profile, for a number of situations for which transmission has been confined to small angle arrivals. This modelling includes, implicitly, the effects of diffraction into the shadowed regions, and the effects of the varying levels of intensity of insonification in accord with the different surface slopes. The surface loss values inferred from these simulations are compared with those from the other models, and to the extent possible, with the apparent effects observed with available at sea data. In this work, attention has been paid to the angles of incidence at the surface which dominate the loss effects. To the extent possible, conclusions are drawn on the apparent accuracy of the various models, and the need for further work to ascertain their appropriateness at small grazing angles. © 2010 CROWN.
Jones, A. and Duncan, A. and Maggi, A. and Sendt, J. and Clarke, P. 2010. Modelling acoustic reflection loss at the ocean surface for small angles of incidence.


text:
Pseudohadena gnorima är en fjärilsart som beskrevs av Rudolf Püngeler 1906. Pseudohadena gnorima ingår i släktet Pseudohadena och familjen nattflyn. Inga underarter finns listade.

Källor

Nattflyn
gnorima

redpajama_set_name: RedPajamaWikipedia


Their efforts embodied 50 years of the Zambian National Team carrying the hopes and dreams of a nation. 50 years of potential almost realised, but never quite producing at the highest level, until AFCON 2012. Most of all, this was facing our loss and allowing it to heal by soldiering on in the very place where we had suffered an inconsolable pain, despite the odds stacked against us: we had to defeat more well-known and higher ranked African teams that had played at the World Cup, and the weight of sorrow could have burdened us and hindered us. Instead the Chipolopolo found a way to soar like the nkwazis (eagles) we Zambians all have the power to be, and raised our flag proudly in honor of those we lost, preserving their place in history by winning on their behalf.
As my beloved country turns 50, I am honoured to be able to give this gift to the people. I may have a turbulent relationship with the place of my birth, but the best relationships ebb and flow - there will always be that tug-of-war to remind you to be present and to make sure to give as much as you take. I thrive in the conflict that my Afropolitan identity creates as it clashes with some of the more static and stagnant elements in the Zambian environment. It allows my creativity to thrive by causing me to turn inward to figure out new ways to express myself in ways authentic to my soul and freeing to my spirit in order contribute to the communities I engage and/ or identify with. The moment it happened I knew I too could achieve some of my dreams through their success. I could finally become a filmmaker by documenting this seminal moment in history, and could go one step further by preserving this story for future generations. One of the recurring themes on this blog is legacy, the other is capturing an African experience in the 21st century and populating the internet with more content produced by the continent, so we can tell our own stories now and in perpetuity. As a media professional, and a passionate Afropolitan, I am taking advantage of the multiple ways afforded to me. Film is another way to do that. I formed my production company Purple Tembo Media because of how inspired I was watching the Chipolopolo continue to triumph despite being written off as the underdog. Triumphing when underestimated is one of my favourite things to achieve and to see unfold in others.


text:
Tag: hand-crafted footballs
About the Gridiron
Why is a Football Called a "Pigskin"?
Have you ever wondered where the term "pigskin" originated? Out of all the nicknames for a football, pigskin is probably…
About Big Game USA
Big Game USA Football Factory Featured on ESPNU's Road Trip
During the lead up to the College Football Playoff championship game earlier this month, ESPNU's Road Trip show stopped by…
Regulation Play Footballs
Customized Footballs Bring More Excitement to College Ball
Big Game USA is proud to be the premier manufacturer of official Football Bowl Subdivision (FBS) college game balls. Many…
Debate Intensifies as College Playoff Rankings Start Materializing
The first season in the new college football playoff system is entering its final stretch, which means the rankings set…

redpajama_set_name: RedPajamaCommonCrawl


text:
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                Toggle navigation

            </button>

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Get ready, this DIY is totally silly but I know you're going to love it! Who couldn't love this "Winey Juice" adult juice box creation? What way to enjoy some boxed chardonnay right?!?!
Remember the talented gal named Kayd that gave Hammers and High Heels a makeover last year? Well, I've been wanting to get her something and it was LONG overdue! Not just for the amazing blog design but she has helped me out here and there with all of my blog or social media questions. The girl's got mad skills I tell ya! I thought wine would be a nice thank you gift so I asked her what kind she liked and she said something like "whatever, I am not too particular", so I jokingly said "well okay, I'll just get you a box of the Franz (Franzia), so you can enjoy an adult juice box!"
We both got a laugh, but then I thought- hmmm, that would be pretty hilarious to turn a box of Franzia into an oversized looking juice box. I HAD to do it! But don't get me wrong I still got her a nice bottle of Malbec as a real thank you which I must admit felt pretty odd to purchase along with a box of Fanzia. I swear people judge you if you're buying that stuff, I felt like I had to explain to the clerk that I was making a giant juice box out of it... but figured that everyone would assume I was drunk and/or crazy with that explanation. Anyways, that's how this project came about. Now to how I made it!
To make it funny it had to really look like a juice box so I thought about all the juice boxes out there- Hi-C, Capri Sun, Juicy Juice, etc. Capri Sun wouldn't work unless I just covered the Franzia bag in tin foil, but that'd be a mess. Hi-C didn't have much of a title to work with so I chose Juicy Juice as my design inspiration and I got help from my friend Kellie on the title- Winey Juice. It was simple and the letters "Winey" fit nicely in place of "Juicy", perfect!
I put the design together using a combination of Photoshop and Illustrator. I found a Juicy Juice label image online and started tweaking it in Photoshop. I removed the Nestle logo, added Franzia in it's place, and instead of "100% All Natural Juice" I thought of nothing better and called it like it is "Cheap Chardonnay". Which is not meant to sound mean or snotty but it is true, five liters of wine for like $12.99 is in fact cheap.
When the design was ready, I measured the size of my Franzia box and made my own little packaging template in Illustrator. Then, all I had to do was print it, cut out the box shape from the template print out, cut out a hole for a straw, and tape the print out/faux juice box cover to my Franzia box using double sided tape.
For the straw, I found a large red and white stripe pattern, printed it, and rolled it diagonally until it looked like an oversized straw. I also put some thicker rolled up card stock inside the printed paper straw so it had some more structure to it.
I couldn't stop laughing at my Winey Juice Box creation once it was complete, I thought it was hilarious! Before presenting it to Kayd (along with the real wine) I proudly showed a few friends and it made everyone smile that saw it :) haha!
I know it is totally silly, but I think it's one of my favorite DIY's ever! It's just so stinkin' silly, super Head Over Heels for this one! How about you?!? Do you want to make your own Winey Juice Box too?


There's no doubt that plenty of alligators live in the Florida swamps but what about alligator men? No, not men who hunt alligators or train them but weird hybrids; crosses between man and alligator?
An impossibility you might think but wait until you see the mummified body proudly on display at a souvenir store in Washington State.
Nicknamed Jake the Alligator Man, the creature was found in the Everglades and reported in the Weekly World News back in 1982. The body was then purchased by Wellington Marsh Sr. and taken to his shop in Long Beach, Washington, to lure in customers. After all, who wouldn't want to see the alligator man?
Jake is around five feet long. His small, child-like head and shoulders are fixed upon a slender torso that tapers off into an alligator body. This whole dehydrated mess rests on stubby legs. A long, muscular tail adds the counterweight necessary to offset the seemingly out of place upper body. Webbing binds the space between his toes and the sheen of green scales still peeks out amongst the dehydrated flesh. Jake's mouth is still filled with once lethal, sharp teeth.
The legend of the alligator man didn't start in 1982. In fact, this isn't the only mention of alligator men in the Everglades. Stories associated with man-like reptiles date back to the 1700s. Some cryptologists speculate that these creatures are migratory and as such, may be connected to another hybrid creature, the New Jersey Gator Man. Old stories speak of these creature's communicating with one another using grunts and howls.
As for Jake's story, he met his demise after killing a Miami man though the exact details of who and when are so far proving elusive.


text:
Attorney-at-Law
Taishoff Law
Don't Contact Me
Archive for July, 2017|Monthly archive page
PRO SE TAXPAYERS AND THE FORMS
In Uncategorized on 07/31/2017 at 16:18
On background, as those not wishing to have their personal peccadilloes and vendettas appear in the public print should specify, see my blogpost "Same Time, Next Year," 3/3/17. Therein, that repository of endless wisdom, the American Bar Association Tax Section, to which august assemblage I do not belong, belittled my suggestion that specifying a place of trial that bore some connection, however faint and attenuated, to the location of the petitioners, taxpayers, witnesses, physical evidence, experts or counsel might be a valid consideration to be addressed by a Tax Court Rule.
The sages opined that many petitioners, pro se of course, get even the present minimal Form 5 wrong. They do; functional illiteracy is a greater threat to the Republic than most of the horribles appearing in the media.
But today that Obliging Jurist, Judge David Gustafson, has a bad case of indigestion from Good Eats Corporation, Docket No. 26638-15, filed 7/31/17, a designated hitter. Thanks, Judge.
Besides not providing any information to IRS to cause them to change their position, expressed in the SNOD from which the Good Eater was petitioning, the Good Eater struck out on Form 6, completing which is materially less difficult than any Form 1120 I've ever encountered.
Judge Gustafson: "Petitioner has failed to file the disclosure statement despite the requirement of Rule 20(c) and our orders of October 26, 2015, November 8, 2016, and December 21, 2016." Order, at p. 2.
Note that the Ownership Disclosure Statement, Form 6 (rev. 05/2012) on the Tax Court website list of forms, poses but two (count 'em, two) questions, to both of which I daresay 98% of the corporations, partnerships and limited liability companies filing petitions could answer decisively "NONE."
Perhaps the American Bar Association Tax Section was right.
"A HOTLY-BURNING QUESTION WHAT HAS SWEPT THE CONTINENT" – REDIVIVUS
Or, IRS Blows a Remand
All y'all will recall Elizabeth M. Jacobson bailing from a whistleblower petition. OK, you don't; it's a Friday in summer time and all y'all want to head for a Gulf-and-Tango-with-a-twist. So check out my blogpost "A Hotly-Burning Question What Has Swept The Continent – Part Deux," 2/8/17.
So one can bail. But what about a remand in a blower case? Even though ex-Chief Whistler Steven Whitlock has gone off to OPR, the Ogden Sunseteers are still fumbling in the backfield.
Here's the story of Stanley H. ("Stan the Man") Epstein, Docket No. 28731-15W, filed 7/28/17, as told by Judge Lauber, who loves conundra like these.
To begin with the obvious, Stan the Man dropped a Form 211 on the Ogden Sunseteers and got bounced. So Stan the Man petitions.
Take it away, Judge Lauber!
"…the parties filed a joint Motion to Remand in which they represented that respondent's Whistleblower Office (Office) had reconsidered its determination as to whether petitioner is entitled to an award. In light of that development, the parties submitted that '[j]ustice would be served by reopening petitioner's claim.' … the Court continued the case; held the Motion to Remand in abeyance; and directed the parties to work toward possible resolution of the case.
"… respondent filed a Status Report in which he indicates that the Office is prepared to make a revised determination regarding petitioner's claim and is prepared to issue a new final determination letter. Respondent asked that the Court grant the Motion to Remand as a prelude to the Office's taking that step. …petitioner advised the Court of his position that a remand is unnecessary; that it would needlessly delay the case; and that the Court should simply direct respondent to issue a new determination letter. On this point we agree with petitioner." Order, at p. 1.
The usual story is where there's a trial de novo there's no reason to remand; it'll all come out in the Glasshouse wash. But where there's a question of abuse of discretion, there can be a remand if the administrative record is ratty or circumstances have drastically changed. I've blogged those cases.
Besides, once Tax Court gets jurisdiction, they keep it, even when the Ogden Sunseteers admit their first shootdown was a miscue. Remember Mica Ringo and the Incomparable Comparinis, whose set-tos with the Ogden Sunseteers have been exhaustively chronicled in this my blog.
So what's the big question? "In deciding whether remand would be appropriate in whistleblower cases, one relevant question would be the appropriate standard of review, that is, whether the matter we are asked to address is subject to de novo review or review for abuse of discretion. This Court has not yet decided the appropriate standard of review of a final IRS determination in a whistleblower case." Order, at p. 2.
I make abuse of discretion 8 to 5 in the morning line. But Judge Lauber gets shifty.
"Because we believe that a remand of this case would serve no useful purpose, we deem it unnecessary to decide these questions of first impression here." Order, at p. 2.
The Ogden Sunseteers say they'll issue a new letter. Stan the Man, like the famous sneaker, says "Just Do It." Judge Lauber has jurisdiction to review any "determination" the Sunseteers disgorge.
So why remand? Or decide if this is a case for remand? Or determine the standard of review that would permit a remand?
Go send the new final determination letter (hopefully appropriately labeled as such). If it solves everybody's problems, great, send in a stipulated decision; if not, Judge Lauber is holding short of takeoff and can rev up the judicial engines.
Of course, nothing herein contained precludes a remand in the right case.
AT HOME ABROAD – REDIVIVUS
Crestek , Inc. & Subsidiaries, 149 T. C. 5, filed 7/27/17, sounds off a lot, but not so's you'd hear it. Crestek makes and sells ultrasound equipment and semiconductors. And though they're a DE C Corp with HQ in OH, they echo Rudy Kipling's 1899 school song: "Each degree of Latitude/Strung about Creation/Seeth one or more of us… Keen in his vocation." That is, they have a bunch of CFCs in Malaysia, The Netherlands, Denmark and Germany.
Well, Crestek got intercompany cash advances that might be loans from their CFCs. And they also got a loan from the Bank of Islam, which apparently is a Malaysian lender, who gets a guarantee from one of the local CFCs.
And the CFCs also had a bunch of trade receivables for stuff they sold to their US shareholder, Crestek. IRS claims those are in excess of the Section 956(c)(2)(C) cutoff "…the amount which would be ordinary and necessary to carry on the trade or business of both the other party to the sale or processing transaction and the United States person had the sale or processing transaction been made between unrelated persons * *." 149 T. C. 5, at p. 14. IRS wants summary J, but it's pretty obvious that's a facts-and-circumstances gig.
All these goodies, except maybe some of the trade receivables, are US property, per Section 956, says IRS.
No doubt the offshoreniks are all CFCs. Crestek and its Stateside wholly-owneds own 100%, directly or indirectly, of all the voting and other stock of the offshoreniks.
First hurdle, SOL. Well here's substantial omission because Crestek didn't pay tax on millions, so 6SOL, and IRS beats the clock.
Next batter. "…petitioner observes that most of the proposed section 956 inclusions are attributable to investments in United States property that the CFCs had made in tax periods before FYE 2008. In petitioner's view, the IRS was obligated to make any adjustments under section 956 for the year in which the CFCs first acquired the United States property in question, not for any later period. Petitioner cites no authority for this submission, and it has no merit." 149 T. C. 5, at p. 17.
Section 956 inclusion is year-by-year. If IRS missed a year, well, that's baseball, but nothing stops IRS from hitting another year. If they do, IRS must credit the onshore with any tax previously paid on the same money. Well, since Crestek didn't pay tax on most of the alleged omitted income, it's fair game.
Third, Crestek claims Section 6214 requires IRS to look at the onshores' previous years. No, says Judge Lauber, this is about the CFCs' tax attributes, not the parents'. And since Crestek and IRS stipulated the CFCs' previously taxed (and thus not taxable again) income, there's nothing else to look at.
Well, says Crestek, the intercompany loans were all paid off. Prove it, says IRS. Judge Lauber says to defeat summary J on this point, allege some facts. Can't rest on denials, y'know. Crestek has only the Michael Corleone gambit on this one.
As for the guarantee, IRS claims that the Malaysian guarantor also pledged some of its US parents' stock, as well as guaranteeing payment. Crestek says the guarantee/pledge was window dressing, as the Malaysian's stock was worthless.
Judge Lauber doesn't care. "At the outset we have difficulty seeing the relevance of this argument. Section 956(d) provides that a CFC shall be considered as holding an obligation of a United States person if the CFC 'is a pledgor or guarantor of such obligation.' Petitioner concedes that CUM was a 'guarantor.' Under the subpart F regime as enacted by Congress, that is the end of the inquiry. Neither section 956(d) nor the regulations interpreting it inquire into the relative importance that the creditor attaches to the guarantee." 149 T. C. 5, at pp. 25-26.
Besides, a Malaysian bank like Bank of Islam, when making an $11 million loan to a US Corp, might want a local on the hook as well, especially as local law might have strong sanctions for welshing. Anyway, no Islamic banker provided an affidavit.
And although Crestek claims the Malaysian sub was under water, (a) what relevance is that as the guarantee was in place, and (b) there's no proof that the Malaysian sub was insolvent. And the IRC doesn't require that the guarantor be likely to be called upon to perform.
As for what part of the trade receivables are over the line, one batch accrued to an out-of-business entity, so clearly that isn't necessary to carry on a trade or business. The other batch, in the hands of an operating entity, remained a more or less constant amount, so maybe so it was excessive. But we need a trial for that.
UAPL – PART DEUX
This gets me annoyed. Seriously annoyed.
I don't know what the CA laws might be, but I expect they have some enactment, promulgation or keep-off-the-grass as to UAPL.
Oh, for the civilians amongst you, UAPL is unauthorized practice of law. Here in the Empire State, we have both civil and criminal penalties for so doing.
But out in La-La Land, whatsoever their enactments, promulgations etc., may be, we have Timothy F. Debevec & Janette Debevec, Docket No. 10141-17, filed 7/27/17. Except it isn't at all about Tim & Jan; they petitioned, for sure, but they didn't sign the petition their own selves.
Ch J L. Paige ("Iron Fist") Marvel tells the story.
"That petition seeks review of a purported February 2017 notice of deficiency allegedly issued to Vincente Rosas for taxable year [X]. That petition was captioned: 'Timothy F. Debevec & Janette Debevec, Petitioners v. Commissioner of Internal Revenue, Respondent'. That petition was not signed by Mr. and Mrs. Debevec. Rather, that petition was signed only by Vicente Rosas. … respondent filed a Motion To Dismiss for Lack of Jurisdiction, at docket No. 10141-17, on the ground no notice of deficiency or other notice of determination was issued to Mr. and Mrs. Debevec for taxable year [X] …that would permit them to invoke the Court's jurisdiction in this case. Among other things, in his motion to dismiss respondent states/indicates that: (1) Vincente Rosas apparently filed the petition at docket No. 10141-17 using the petition that Mr. and Mrs. Debevec filed at docket No. 8771-17S… challenging the notice of deficiency… issued to Mr. and Mrs. Debevec for taxable year [Y]…; and (2) however, Mr. Rosas in the petition at docket No. 10141-17 incorrectly captioned that petition in the names of Mr. and Mrs. Debevec, instead of in Mr. Rosas' own name. In our Order To Show Cause… we directed Mr. and Mrs. Debevec and respondent each… to show cause, in writing, why the Court, on its own motion, should not dismiss so much of this case at docket No. 10141-17 relating to Timothy F. Debevec and Janette Debevec for lack of jurisdiction on the ground the petition was not properly executed by or on behalf of Mr. and Mrs. Debevec." Order, at p. 1.
Could be the typical pro se, trying a cut-and-paste from a form he got from the Glasshouse files. Public info, and all that.
But it isn't, hence the title of this rant.
"…respondent filed a Response to Order…. Among other things, in his Response respondent states/indicates that: (1)… respondent's counsel received a telephone call from Raul Armendariz, an unenrolled tax return preparer who purported to represent both Mr. and Mrs. Debevec, and Vincente Rosas; (2) Mr. Armendariz informed respondent's counsel that he (Mr. Armendariz) prepared the petition filed in this case at docket No. 10141-17 using the same petition that Mr. Armendariz prepared for Mr. and Mrs. Debevec at docket No. 8771-17S; (3) however, Mr. Armendariz incorrectly captioned the petition filed at docket No. 10141-17 in the names of Mr. and Mrs. Debevec, rather than in the name of Vincente Rosas; and (4) respondent agrees that the Court should dismiss so much of this case at docket No. 10141-17 relating to Mr. and Mrs. Debevec for lack of jurisdiction on the ground the petition in that case was not properly executed by or on their behalf. … Mr. and Mrs. Debevec filed a Response to Order….. …Vincente Rosas-De Jesus filed a Motion To Change or Correct Caption. Among other things, in his motion Mr. Vincente Rosas-De Jesus states that the petition at docket No. 10141-17 was incorrectly captioned in Mr. and Mrs. Debevec's names, instead of in Mr. Vincente-De Jesus' name." Order, at p. 2.
OK, so we had CPAs, not USTCPs or attorneys, making motions in Tax Court, until I blew the whistle on that little game. Not to be outdone, we have unenrolled tax return preparers, whose credentials, experience, competence and integrity are unknown and unexamined, to say nothing of their being admitted either to any Bar or to the US Tax Court, preparing petitions in Tax Court, and purporting to represent taxpayers in litigation, but doing it under the radar. I must assume Mr Armendariz and others of his ilk are not doing any of this for free or through any LITC. Nor have they any credential beyond unenrolled status.
So what does Ch J L Paige ("Iron Fist") Marvel do?
She plays the clerk, and orders as follows: "Mr. Vincente-De Jesus's Motion To Change or Correct Caption, filed at docket No. 10141-17 on July 24, 2017, is granted and the caption of this case is amended to read: 'Vincente Rosas-De Jesus, Petitioner v. Commissioner of Internal Revenue, Respondent." Order, at p. 2.
How about maybe so a referral to the CA authorities for UAPL for Mr. Armendariz, the founder of this particular feast? Here's a link.
http://www.calbar.ca.gov/Portals/0/documents/forms/2015_UPLComplaintFormrevised4
The end of a long trail, with sixteen (count 'em, sixteen) lawyers for Eaton Corporation and Subsidiaries, 2017 T.C. Memo. 147, filed 7/25/17, versus nine for IRS. Spoiler alert- Eaton's advance pricing agreements shouldn't have been canceled by IRS.
Judge Kerrigan has a lot more about circuit breakers than most of us want to know. Eaton also has a bushelbasketful of offshore subsidiaries in the Cayman Islands and Switzerland, with branches in the Dominican Republic and Puerto Rico, the latter fueled by the old Section 936 incentives to go to Puerto Rico.
In addition to breaking circuits, Eaton and the gang were base eroding and profit shifting to beat the cliché, so Eaton entered into advance pricing agreements with IRS, pursuant to a couple Rev. Procs. (hi, Judge Holmes).
Well, the unguided Congressional largesse to Puerto Rico evaporated (along with Puerto Rico's economy), so Eaton shifted hardware and IP to the Dom Rep via a batch of Section 351 tax-frees.
IRS wanted to hit the whole shebang with a Section 482 unscramble, so IRS and Eaton negotiated the advance pricing agreements (APAs).
If you want to have your head spun real good, read about Eaton's accounting and reporting methods, and how the comparable uncontrolled price (CUP) method for working out the intercompany hand-offs was derived. I cannot figure this stuff out, but I tipped off a certain blood relative who probably can.
Briefly, "Before its proposal to use a CUP method, petitioner used the cost-plus method. The cost-plus method evaluates whether the amount charged in an intercompany sale is arm's length by reference to the gross profit markup realized in comparable uncontrolled transactions. See sec. 1.482-3(d)(1), Income Tax Regs. The CUP method evaluates whether the amount charged in a controlled transaction is arm's length by reference to the amount charged in a comparable uncontrolled transaction. See id. para. (b)." 2017 T. C. Memo. 147, at p. 35.
But when it came to negotiating the APAs, each side assembled a team, and the resulting negotiations were slightly, but only slightly, less convoluted than certain peace talks of recent memory.
And of course there was "trust, but verify," built in.
And also, of course, there was a second round of negotiations, with the same mind-numbing complexity, which resulted in APA Number Two.
Next, as we would expect, it turned out that some ratty data got into the mix and the APA numbers were off. When lawyers, accountants and economists work out these wonderful formulations, no one talks to the in-the-trenches grunts who have to make all this applesauce work. So there were more "error" lights at Eaton than at a Brooklyn Cyclones game.
IRS lost patience, claiming "…failure of a critical assumption, misrepresentation, mistake as to a material fact, failure to state a material fact, failure to file a timely annual report, or lack of good faith compliance with the terms and conditions of the APA." 2017 T. C. Memo. 147, at p. 112.
IRS dumps the APAs, and nine-figure SNODs rain on Eaton.
Meanwhile, Eaton buys out a DE C Corp that makes some kind of gizmo it needs, which said gizmo-maker has a sub in the Emerald Isle, home of leprechauns and tax dodges. And some of the sub's high-priced execs have stock options out of which they have to be bought.
But the buying-out didn't take place simultaneously with the buying-out of the rest of the DE C Corp, so Eaton tried to amend its return for the year in question, but IRS said the buying-out bonuses had to be capitalized under Section 263, not as payment of compensation and thus expensed.
As for the bogus APA reports, Eaton claims "whoops, so sorry." IRS claims "dirty pool."
APAs are like PLRs, a deal between taxpayer and IRS to prevent an annual argy-bargy about comparables, software and arcana well beyond the scope of mortal intelligence. There are six (count 'em, six) methods to work out whether intercompany give-and-goes are truly comparable to arms'-length, love-with-the-proper-stranger deals. Judge Kerrigan lists them all at p. 129-131, to which I refer any among you still reading this and suffering from terminal insomnia.
The test here is what the now-defrocked Judge Kroupa decided back in 2013: abuse of discretion. See my blogpost "Advance and Retreat," 6/26/13.
So Judge Kerrigan trudges through all the negotiations, who said what, what numbers were real and what was "constructed" (mach gresser, mach veiniger, as we say). And IRS got whatever it asked for. If IRS was unhappy, it should have asked for more. Eaton didn't sandbag.
Yeah, Eaton blew it. But.
"All of petitioner's seven errors were computational or related to inadvertence, and all were corrected in the amended APA annual reports. These errors were not deliberate. The errors were discovered only because petitioner did a comprehensive review after determining that its first error was not an anomaly caused by interim calculations. Without petitioner's reporting its errors, they would not have been discovered.
"We do not agree with petitioner's interpretation that the revenue procedures provide a dividing line regarding the type of error and what type of action should be taken. Each error needs to be analyzed to determine whether it is material. The revenue procedures require, upon examination, that the taxpayer may be required to show supporting data and computations; and if this does not occur, the Associate Chief Counsel (International) may decide to enforce, revise, cancel, or revoke the APA consistent with the revenue procedures. See Rev. Proc. 96-53, sec. 11.03(2) and (3); Rev. Proc. 2004-40, sec. 10.03(2) and (3). Respondent's cancellation letter stated: 'The material deficiencies in APA compliance include numerous examples of noncompliance with the terms and conditions of APA I and APA II, errors in the supporting data and computations used in the transfer pricing methodologies ("TPMs") specified in APA I and APA II'." 2017 T. C. Memo. 147, at pp. 175-176.
Except that when you do the numbers, none of the seven make a material difference.
And IRS can't identify any Section 367(f) outbound intangibles Eaton and the subs were throwing around in their multifaceted 351s.
Oh yes, the Emerald Islanders were employees, entitled to be paid. That was salary and wages, not acquisition costs.
And now an old friend is going to buy me a drink. I need it.
THE GRAEV IN MR. ROGERS' NEIGHBORHOOD
All y'all (as my Texas dear ones would say) remember John Rogers, the architect of the great DADS debacle, where he matched Brazilian bad debts with big-ticket US capital gains, and got blasted. No? See my blogpost "There Goes the Neighborhood," 9/3/13, which has links to certain of the accounts of Mr. Rogers' delictions.
Today we're back with another of Mr. Rogers' little dodges, Derringer Trading, LLC, Jetstream Business Limited, Tax Matters Partner, et al, Docket No. 20872-07, filed 7/26/17. That's right, this doozy is ten years old. The interest must be more than any eventual deficiency.
Judge Wherry, he who was slapped by Judge Posner for lame humor four years ago as in my hereinabove-cited blogpost set forth (as my wealthier colleagues on the beach in the Hamptons would say), forswears witticisms today, sustaining the FPAAs against the pistol-packing Momma from Massachusetts, who opposes same. The deals are the same; it's the same Brazilians, the same phony partnership, the same tax game.
But this case blips my transponder because of the chops: IRS wants either 40% overvaluation or 20% accuracy.
So what? Should be a slam dunk, no? As my canty readers have already cottoned on, there's a Graev in Mr. Rogers' neighborhood.
Here's Judge Wherry to tell you all about it.
"As noted above, the FPAAs also determine accuracy-related penalties under section 6662, which include the 40% gross valuation misstatement penalty under section 6662(h). If we were to find that Warwick [another Rogers phony] and Derringer acted with reasonable cause and in good faith, we would not sustain an accuracy-related penalty. Sec. 6664(c)(1). We make this determination at the partnership level, taking into account the state of mind of the general partner. Therefore, Mr. Roger's subjective intent is the focus here, since he was the sole ultimate owner and the only director of Jetstream, which was the managing member of both Warwick and Derringer." Order, at p. 8. (Citations omitted).
Well, Tax Court decided long ago that Mr. Rogers was a prankster of low degree, with state of mind to match, so chop away, IRS.
"But since we decided Superior Trading, the Court has issued its opinion in Graev v. Commissioner, 147 T.C. __, _ (slip op. at 12) (Nov. 30, 2016), interpreting section 6751(b)(1), which requires, as a prerequisite for sustaining the assessment of an accuracy-related penalty, the personal written approval of the immediate supervisor of the individual who had made 'the initial determination of assessment.' Graev is appealable to the Court of Appeals for the Second Circuit, which has held that the Graev dissent rather than the majority 'got it right.' Chai v. Commissioner, 851 F.3d 190, 216 (2d Cir. 2017), aff'g in part, rev'g in part T.C. Memo. 2015-42. The Graev dissent, which the Second Circuit endorsed, would require in this case that written supervisory approval of the penalties determined in the FPAAs should have been obtained "prior to the initiation of Tax Court proceedings." Chai v. Commissioner, 851 F.3d at 216; see also Graev v. Commissioner, 147 T.C. at slip op. at 29." Order, at p. 8.
Note that Judge Wherry was out to lunch when the Graev Boss Hoss kerfuffle went down in Tax Court last November. Back then I praised Judge Gustafson's dissent and said that if ever a full-dress T. C. needed to be appealed, that one should have been. It was, and Judge Gustafson and I were right.
Now maybe the summary J IRS wants here should be limited to the FPAAs; the Section 6751(b) Boss Hoss signoffs aren't in the record, and anyway the chops haven't been assessed (but do they need to be? Aren't they computational, and don't need partner-level proceedings?). Likewise, Derringer isn't Golsenized to 2 Cir., so maybe Judge Posner and the 7 Cir. gang might want a whack at this one. So what's the rush? Hey, it's only been ten years; some of the Kersting cases are over 30 years old, and still undecided.
Judge Wherry wants to move this one.
"Regardless, to afford respondent an opportunity to establish that he can in fact satisfy the Graev dissent's requirement for sustaining the penalties determined in the FPAAs, we will deny respondent's motion for summary judgment with respect to those penalties. We encourage the parties to stipulate to the authenticity of whatever documents respondent may be able to produce in this regard, and submit the penalties issue to the Court under Rule 122." Order, at p. 9.
Summary J on the FPAA, chops in abeyance.
CDP – WHO KNEW IT COULD BE SO COMPLICATED?
I've made my political comments on today's events elsewhere, so I'll turn to a designated hitter off the bat of that Obliging Jurist and puzzlemaster Judge David Gustafson. Today Judge David Gustafson is confronting IRS looking for mootness in ASG Services, LLC, Docket No. 14945-16L, filed 7/25/17.
It's a CDP, and ASG paid up, so why not just toss the petition?
Well, ASG wants to fight about liability. You remember it was only yesterday that Dean Matty Vigon sent that hare through the thicket; well, if you don't remember, see my blogpost "Crafty – Akin to the Weasel," 7/24/17.
But ASG isn't quite in Dean Matty's mukluks. So Judge Gustafson, always a man for a bargain, poses three questions, rather than the customary four.
First, IRS isn't playing cagey when it comes to withdrawing a lien or forswearing future collection action. ASG just coughed up. So isn't that like Greene-Thapedi, where, the liability being satisfied, Tax Court has nothing to adjudicate?
Second, "Without the existence of any possible prospect of future collection activity as to the liabilities at issue, this case would seem to become a mere suit for refund of the taxes alleged to have been overpaid. In further entertaining the case, we would be determining liability not incident to proposed or possible collection, as section 6330(c)(2)(B) contemplates, but solely for deciding whether ASG is entitled to a refund. Pursuant to section 6512(b), such a refund claim might be pursued in a deficiency case even after the IRS had conceded the deficiency that was the jurisdictional foundation of the case; but in the CDP context, no equivalent statute exists to permit the Tax Court to entertain a refund claim even where all collection issues have been conceded or have become moot." Order, at p. 2. (Citation omitted) (Emphasis by the Court.). So how can Judge Gustafson keep this case alive?
Third, even supposing all we have here is a refund case, isn't ASG wanting Judge Gustafson to assume facts not in evidence? "Section 7422(a) would seem to require the filing of a timely administrative claim for refund, and section 6532(a)(1) would seem to require the petitioner to await the IRS's issuance of a notice of disallowance (or the passage of 6 months)-but ASG has not alleged compliance with either of these jurisdictional prerequisites. (And once ASG had met those prerequisites, it could presumably file a conventional refund suit in U.S. District court, pursuant to 28 U.S.C. sec. 1346(a)(1), or in the U.S. Court of Federal Claims, pursuant to 28 U.S.C. sec. 1491.)" Order, at p. 2.
So let ASG go file the refund claim and, if they don't get it, sue in USDC or USCFC, right?
ASG claims the payment wasn't a payment, but a deposit to stop interest.
OK, says Judge Gustafson, go for it, ASG. But make it good.
"ASG shall file a supplemental response to the IRS's motion, in which ASG shall state whether it persists in opposing the IRS's motion to dismiss on grounds of mootness and, if it does so persist, shall (1) respond to the hypotheses stated above, (2) explain whether it contends the…remittances were 'deposits' (and, if so, shall explain the effect on mootness), and (3) make any other response it wishes to make." Order, at p. 3.
"KATIE, BAR THE DOOR!"
No, this is not a re-make of the 1437 Scots ballad about brave Catherine Douglas and the slain King James I. This is the unavailing argument of the FedEx driver that he couldn't enter the Glasshouse on the Magic Day to deliver the petition in Organic Cannabis Foundation, LLC. d.b.a. Organicann Health Center, Docket No. 10593-15, filed7/25/17.
And the Organicanns aren't just blowing smoke; there's better than a million bucks' worth of deficiencies here. Source unspecified, but maybe business deductions potted by Section 280E.
First the Organicanns claim the SNOD was sent to the wrong address, because the P. O. Box number was omitted. The ZIP+4 puts paid to that one, as the USPS website says the SNOD got to the P. O. Box with 78 of the 90 days remaining. Plenty of time to file a petition.
Next is the hook for today's sermonette, the mailed-is-filed, or maybe not, rule.
The Organicanns overnighted their petition via FedEx "First Overnight." FedEx "First Overnight" is now one of the "blessed communion, fellowship divine," anointed by John ("Kosi") Koskinen, Boss Hoss at 1111 Constitution Ave., NW. Except it wasn't when the Organicanns sent in their petition. FedEx "First Overnight" didn't make the cut for another two weeks thereafter.
So the Organicanns are out? Yes, but. They have one last dive at the goal line. But Judge Pugh stifles that one too.
"Petitioner urges the Court apply Guralnik v. Commissioner, 146 T.C. 230 (2016), to conclude that the petition was timely filed because the Clerk's office was not accessible to the FedEx delivery driver on the last day for filing. In Guralnik, the taxpayer's statutorily prescribed filing deadline ended on a day the Court was officially closed due to a snow emergency. Id. at 233-234. We concluded that the 'timely mailed, timely filed' rule did not apply because the taxpayer used the FedEx First Overnight service (as petitioner used here), which service was not then listed among the designated private delivery services under section 7206(f). Id. at 240-241. We also declined to give Notice 2015-38 retroactive effect. Id. at 241. However, we applied Rule 6(a)(3), Federal Rules of Civil Procedure, to hold that when the Clerk's office is inaccessible because of inclement weather, government closings or for other reasons, the time for filing is extended to the first accessible day that is not a Saturday, Sunday, or legal holiday. Unlike the snow emergency closing in Guralnik, here, the Court's Clerk's office was open during its normal business hours and was not inaccessible the entire day due to inclement weather, government closings, or other reasons. We, therefore, find Guralnik distinguishable and we decline to expand our holding in Guralnik to cover circumstances where an unspecified event may have blocked access for a period of time but the Clerk's office is not inaccessible due to closure for the entire day." Order, at p. 5.
Y'all will remember Felix Guralnik from my blogpost "Neither Equity Nor Designation," 6/2/16. As usual, you read it here first.
Takeaway 1- Get the current list of the "blessed communion, fellowship divine" private delivery services and post a copy on every flat surface you can find.
Takeaway 2- Upon receipt of SNOD or NOD, pull a Form 2 petition off the Tax Court website, fill in a barebones "I object to everything" and send in same with a check. By the time you get the motion to strike for failure to state a claim, you've bought enough time to amend.
Takeaway 3- Unless it's a DC public holiday or the Glasshouse is totally inaccessible all day, keep banging on the door. Katie Barlass is long gone.
"CRAFTY – AKIN TO THE WEASEL"
A phrase that brings back happy memories of my little girl laughing as she describes some story takes me to the present with Dean Matthew Vigon, 149 T. C. 4, filed 7/24/17.
IRS is being very crafty, and definitely kin to the weasel.
But Dean Matty is no angel, either; apparently he's currently in a Canadian slammer.
Surely you remember Dean Matty and his Forms 1041, each of which IRS claims should get the $5K Section 6702 chop? What, no? See my blogposts "Robosigner?" 6/23/16, and "Not Moot Court," 5/17/17. There now, you're all caught up.
Once again that Obliging Jurist David Gustafson upends IRS. IRS seems to be trying to do an end-run around a bunch of missing Section 6751(b) Boss Hoss signoffs. These should have been obtained before IRS chopped Dean Matty. First IRS asked for and got a remand back to Appeals to get the Boss Hosses. IRS came back from Appeals and claimed they had them, but Judge Gustafson wasn't convinced. My blogpost "Robosigner?" above-cited delves into the dubiety of the Boss Hosses asserted.
Remember Judge Gustafson trashed IRS' summary J motion and ordered a trial.
So IRS gets truly crafty, akin to the weasel. "Instead, the Commissioner moved for a continuance, explaining: that the IRS would abate the penalties at issue; that the process of abating those liabilities is almost complete; that the process of releasing the liens at issue has been initiated; and that once those processes have been completed, the IRS intends to file a motion to dismiss the case on grounds of mootness." 149 T. C. 4, at pp. 6-7.
OK, says Judge Gustafson, that's cool, but what about underlying liability? Isn't Dean Matty entitled to a finding on underlying liability, as Section 6702 chops are non-assessible and he didn't get a prior chance to contest?
No sweat, says IRS, there's no statute of limitations on Section 6702 chops, so when we chop Dean Matty again, he gets another CDP. And we aren't saying we won't chop Dean Matty again.
And the famous release of lien says "With respect to each assessment below, unless notice of lien is refiled by the date in column(e) [i.e., dates in 2021 and 2022], this notice shall constitute the certificate of release of lien as defined in IRC 6325(a)." 149 T. C. 4, at p. 8.
So IRS claims it can refile four years from now, and go after Dean Matty, no doubt after it has gotten Section 6751(b)s from every Boss Hoss up to and including Com'r John ("Kosi") Koskinen or his successor.
Tax Court review of a CDP determination is exactly that…the determination, not the NITL or NFTL, but what Appeals did and what Appeals found. And that means the underlying liability, if appropriate. Abating penalties and releasing the lien is all very well, but liability wasn't determined.
Tax Court's jurisdiction is determined when it is first invoked. Of course, circumstances may have changed since then. If a tax is paid, or if a lien is released and the statute of limitations has run such that the lien cannot be refiled, then the case is moot and should be dismissed.
Except here it isn't.
"The Commissioner asserts, however, that the section 6702 penalty for 'Frivolous Tax Submissions', unlike the income tax, cf. sec. 6501(a), has no statute of limitations in the Code. For purposes of the Commissioner's motion to dismiss, we so assume. The Commissioner has abated the previous penalty assessments against Mr. Vigon; but, as the Commissioner observes, if this case is dismissed, the IRS claims the right to reassess against and collect from Mr. Vigon identical section 6702 penalties for the same nine alleged frivolous submissions. Here, abatement is a tactical retreat but not a surrender." 149 T. C. 4, at p. 19.
IRS says, "yeah, but Dean Matty gets the whole NFTL and right to a new CDP, so he can fight it out again."
Judge Gustafson assumes for the purposes of this case that there is no SOL for Section 6702 chops.
"We assume this is true, but we see in the Commissioner's position no reason that he could not do it again–abate the second set of assessments, moot the second CDP case, and lie in wait. Mr. Vigon's supposed remedy depends on his recognizing the second lien notice, timely requesting a CDP hearing before IRS Appeals, challenging the liability in that hearing, and then timely filing a Tax Court suit when IRS Appeals issues an adverse determination–all while he is incarcerated. Our CDP jurisdiction is littered with the sad tales of taxpayers who, even when not in prison, stumble on one or more of those requirements. But if Mr. Vigon did succeed in putting his reassessed liabilities before this Court in a future, second CDP case, the Commissioner has, in his view, the unilateral power to render the second case moot by abating the penalties, while retaining the prospect of reassessing yet again at any future time." 149 T. C. 4, at pp. 20-21. (Footnote omitted, but IRS might be right about this one, because 6702s are about filings, not about "taxable periods to which the filing relates.")
Don'tcha just love this stuff? It's like the endless epistolary volleying between blowers and the Ogden Sunseteers. This could go on for decades.
Except Judge David Gustafson says "enough already."
IRS' weasel-wording and sleight-of-hand merely left the case sleeping, not dead. IRS doesn't say they irrevocably release the lien or say they will not ever again assert the Section 6702 chops.
IRS, the case is not moot. Tax Court has jurisdiction.
Now about those Section 6751(b) Boss Hoss signoffs….
A WORD TO A COLLEAGUE
I had a word or two with a fellow practitioner (CPA-type) at the Jersey Boys' CPE-on-CDP confab yesterday, as we sipped soft drinks during a break. I mentioned my view on unciteables, namely T. C. Sum. Op.s and orders.
These should be read, marked and inwardly digested; while Rule 50(f) bars citing orders for anything but preclusion and law of the case in the particular case wherein the order was issued, and Section 7463(b) says Sum. Op. small-claimers can't be cited as precedent, you can copy any statute, reg, T. C. or T. C. Memo cited in any thereof, and lift the reasoning, even by cut-and-paste. It's not allowed to be cited, so you can't. But the reasoning and the law, regs, etc., from whatever source derived, are either valid or invalid. And if naught else, you can see how a Judge will decide an issue, maybe so.
My colleague was dubious at first, but I think I persuaded him. And if my powers of persuasion were insufficient advocacy, here's that Obliging Jurist, Judge David Gustafson, with a designated hitter, second-seating me.
"…petitioner filed a motion to compel production of documents. We will order respondent to file a response and petitioner to file a reply. In preparing that response and reply, the parties may wish to reflect on our non-precedential orders addressing motions to compel in another whistleblower case—Insinga v. Commissioner, No. 9011-13W (July 27, 2016 (Doc. 109), and January 27, 2017 (Doc. 161)). These orders are not precedential, see Rule 50(f); we do not expect the parties to cite them, distinguish them, or rely on them; and we have not considered petitioner's instant motion sufficiently to conclude that they actually involve the same questions. However, the orders may be helpful to the parties in showing the undersigned judge's thinking about this area. The parties are invited to correct that thinking where they think it may be in error." Order, at p. 1.
Y'all surely remember Fighting Joe Insinga. What, no?! Well, scope the old chap out on this my blog. I think I posted Fighting Joe's set-tos with the Ogden Sunseteers ten times over the last four years.
And this order involves a newcomer to my blog, who came on the scene just two weeks ago. It's Loys Vallee, Docket No. 13513-16W, filed 7/21/17. See my blogpost "General Knowledge, Private Information," 7/7/17.
Thanks, Judge Gustafson.
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An author, teacher, advocate and trusted advisor, Lew Taishoff is a New York City-based attorney with 53 years of experience in corporate and individual tax and real estate matters. He is admitted to practice before the United States Tax Court. He was formerly, for ten years, an Enrolled Agent, examined ... Continue reading →


Lives. Translated from the original Greek, with notes, historical and critical, and a life of Plutarch.
Lives, translated from the original Greek; with notes, historical and critical; and a life of Plutarch.
Plutarch's Lives, tr. from the original Greek; with notes, historical & critical; & a life of Plutarch.
Plutarch's lives; translated from the Greek, with notes and a life of Plutarch, by Aubrey Stewart...and the late George Long.
London, G. Bell & Sons, 1900-01.


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Q: Show that $\sigma(S(C))=\sigma(C)$. Let $ S(C)$ be an algebra generated by $C$ and let $\sigma(S(C))$ be a sigma algebra generated by $ S(C)$. Show that $\sigma(S(C))=\sigma(C)$.
I can show $\sigma(C) \subset \sigma(S(C))$ this is actually very trivial. How about the other direction.

A: $S(C) \subset \sigma(C)$ since $\sigma(C)$ is an algebra containing $C$ and $S(C)$ is the smallest algebra conatining $C$.Then $\sigma(S(C)) \subset \sigma(\sigma(C))=\sigma(C)$
Explanation of equality:
if $\cal A$  is a $\sigma-$ algebra then $\sigma(\cal A)=\cal A$

redpajama_set_name: RedPajamaStackExchange


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Sajószentpéter is een plaats (város) en gemeente in het Hongaarse comitaat Borsod-Abaúj-Zemplén. Sajószentpéter telt 12 758 inwoners (2007).

Geboren
 Anikó Nagy (1970), handbalster

Stad in Hongarije


San Francisco, California – MacAppware, a division of 128bit Technologies, announced today the addition of 2 new fonts to its commercial use 1000 OpenType Fonts collection for creative Mac users. For a limited time, the updated font collection is also available for only $29.99, a discount of 70% from the regular price of $99.
Looking to give your font collection a boost? Tired of using the same fonts in all your design projects? Need fonts you can use royalty free on commercial, for-profit projects? Get creative with a new collection of 1000 OpenType fonts for commercial use. The font collection includes 240 unique font family styles, with 1000 total fonts. An excellent addition to any font collector's library for use in graphic and logo design, web design, scrapbooks, presentations, invitations, promotional material, advertisements, and more.
Each font in this collection is unique, so you will not find them anywhere else. This collection is completely different from the Premium Fonts and Free Fonts collections also offered by MacAppware.
The updated 1000 OpenType Fonts collection is now available on the MacAppware website, or on the Mac App Store, for a limited time discount of $29.99 (USD), a savings of 70% off the full price of $99.
MacAppware is a division of 128bit Technologies and a dedicated Mac software developer currently offering Mac software, graphic design bundles and unique commercial use fonts. Copyright (C) 2014 128bit Technologies LLC. All Rights Reserved. Apple, the Apple logo, Mac OS X, and Macintosh are registered trademarks of Apple Inc. in the U.S. and/or other countries. All other trademarks are the property of their respective owners.


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Polizei is een lied van de Nederlandse rapper Jebroer. Het werd in 2019 als single uitgebracht en stond in hetzelfde jaar als dertiende track op het album Jebroer 4 life.

Achtergrond
Polizei is geschreven door Tim Kimman en Max Oude Weernink en geproduceerd door Oude Weernink. Het is een nummer uit de genres nederhop en hardstyle. Het is een nummer dat een protestlied is van de zanger, ten opzichte van zijn tegenstanders en de politie. Er was veel ophef om de videoclip toen deze werd uitgebracht. In deze videoclip wordt een scene van televisieprogramma Wegmisbruikers nagedaan, waarin de rapper vlucht voor de politie nadat hij is aangehouden en over de snelweg racet. Vlak voordat Jebroer de video uitbracht, lekte de clip uit, waarna verschillende media dachten dat de rapper daadwerkelijk voor de politie was gevlucht. Toen de clip later werd uitgebracht, werd het door sommige omschreven als een onjuiste actie en door anderen als een goede publiciteitsstunt. Verschillende reacties van de media zijn te horen op de twaalfde albumtrack Skit - Polizei.

Voor deze muziekvideo had Jebroer een politiewagen en politie-uniformen geleend van de Nederlandse politie. De politie had met de rapper afgesproken dat het de auto niet op de openbare weg mocht en er geen beledigende teksten werden gebruikt ten opzichte van de politie en politiek. Toen de politie zag dat Jebroer zich niet aan de afspraken had gehouden, overwogen ze om juridische stappen te ondernemen. Dit werd uiteindelijk niet gedaan, maar de regels voor het uitlenen van politiekleding en -voertuigen werden wel verscherpt voor toekomste aanvragen.

Hitnoteringen
De rapper had weinig succes met het lied in de hitlijsten van Nederland. Het had geen notering in de Single Top 100 en ook de Top 40 werd niet bereikt; het lied bleef steken op de twintigste plaats van de Tipparade.

Single uit 2019
Nummer van Jebroer


As already seen, the reactions of OH, N03, and CI with alkanes generate alkyl radicals. We shall see in the subsequent sections of this chapter that the production of alkyl radicals of various types is a general characteristic of organic oxidations. Here we will trace the atmospheric fates of typical alkyl radicals formed in OH, N03, and CI atom oxidations of alkanes. However, the principles are general and can be applied to those formed by the reactions of other organics such as alkenes as well.


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Women's Soccer History and Records
Support UMBC Women's Soccer
Women's Soccer Takes on Stony Brook in Rematch of 2013 Title Game
Stony Brook (3-8-1, 0-2-1 AEC) 0 1 0 0 1
UMBC (8-3-1, 0-1-1 AEC) 0 1 0 0 1
2nd - 54:47 - Morris, Destinee (UMBC)
2nd - 58:16 - Good, Maddie (Stony Brook)
G: Good, Maddie - 1
A: Edwards, Raven - 1
Sh: Grogan, Shannon - 3
Sv: Castanio, Ashley - 2
G: Destinee Morris - 1
A: Jessy Brown - 1
Sh: 2 Players (#8, #11) - 2
Sv: Jen Nance - 3
BALTIMORE – The UMBC women's soccer team returns home on Sunday, Oct. 5 when it takes on Stony Brook in a rematch of the 2013 America East title game. Game time is set for 1 p.m. at Retriever Soccer Park. All the live action is available, free of charge, at UMBCRetrievers.tv, courtesy of the America East digital network.
Retriever Soccer Park Promotions
-Camp Day – wear your UMBC camp t-shirt and get into the game free with a paying adult.
-Ellicott City Soctoberfest – Join Ellicott City SC and enter a free raffle for a $50 gift card to Ellicott City's Sports Restaurant, The Diamondback Tavern.
-Lot 17 scarves will be available for a $10 discounted price at the UMBC Sports Marketing table along with some other fun black and gold giveaways.
Scouting the Retrievers (8-3-0, 0-1-0 AEC)
-UMBC snapped a three-game win streak by dropping its 2014 America East opener against Vermont on Thursday afternoon. The Retrievers let the Catamounts take a 2-0 lead before senior midfielder Lilly Rydon (Adelaide, South Australia/Concordia College) scored her team-leading sixth goal of the season, but UMBC was unable to complete the comeback.
-Freshman forward Lisa Nanov (Mechanicsburg, Pa./Cumberland Valley) is the reigning America East and ECAC Rookie of the Week after a four-point effort last week. Nanov registered her seventh point in the last four games with an assist on Rydon's goal versus the Catamounts, the fourth time this season the duo has connected for a score. Nanov leads the conference (0.63) and entered the week 24th in Division I in assists per game.
-Junior goalkeeper Jen Nance (Millersville, Md./Severna Park) allowed her first goal in 367 consecutive minutes of play in the loss on Thursday, snapping a streak of three straight blank sheets from the Maryland native. Nance entered the week 23rd in the nation in save percentage (.872) and 28th in goals against average (.611).
-The Retrievers' program-record eight non-conference wins and an 8-2 record heading into America East play put UMBC back into the top-10 of the NSCAA/Continental Tire Northeast Region Poll at No. 10. The Retrievers ranked as high as No. 6 in the Northeast region back on Sept. 2, but fell out of the top-10 following a loss to Saint Joseph's.
Scouting the Seawolves (3-8-0, 0-2-0 AEC)
-Stony Brook has dropped five of its last six contests, including its first two America East contests of the season. The Seawolves were last season's regular-season co-champions with the Retrievers.
-SBU is coming off a 1-0 home loss to Maine on Thursday, despite holding a 15-10 shots advantage in the contest.
-The Seawolves are paced offensively by a pair of third-yard plays in Raven Edwards and Tessa Devereaux. Edwards, a red-shirt sophomore forward, has punched home a team-best four goals, while Devereaux, a junior midfielder, has dished out five helpers to go with one goal.
Inside the Series
-Stony Brook holds the all-time series record at 9-5-1, but UMBC is unbeaten in its last three matchups versus the Seawolves, including a pair of double-overtime contests.
-Last season, UMBC defeated Stony brook in the regular season matchup, 2-1, as well as a 2-1 victory in the America East Tournament Finals.
June 23, 2015 UMBC Women's Soccer Adds Transfer for 2015 Campaign
March 10, 2015 Women's Soccer Adds Six for 2015 Campaign
January 21, 2015 Women's Soccer's Brown Acknowledged as a Semifinalist for the Wooden Cup
December 17, 2014 Women's Soccer's Brown Named to NSCAA Scholar All-East Region Second Team
December 4, 2014 Women's Soccer's Brown Earns Spot on NSCAA All-Northeast Region Second Team
November 26, 2014 Women's Soccer Earns NSCAA Team Academic Award
November 25, 2014 Boretti Named to Capital One Academic All-America First Team
November 2, 2014 No. 2 UMBC Women's Soccer Ends 2014 Campaign in PKs Versus No. 3 New Hampshire
October 31, 2014 No. 2 Women's Soccer Hosts No. 3 New Hampshire in America East Semifinal Action on Sunday
October 30, 2014 Boretti Earns Spot on Capital One Academic All-District Team
October 29, 2014 Brown Highlights UMBC Women's Soccer's Eight Conference Honors
October 27, 2014 Women's Soccer's Brown Named a Nominee for the MAC Hermann Fans' Choice Vote
October 26, 2014 Women's Soccer Drops Heartbreaker to Binghamton in Double Overtime, 1-0
October 25, 2014 Women's Soccer Controls Destiny in Regular-Season Finale Against Binghamton
October 23, 2014 Women's Soccer's Jen Nance Named Nominee for AEC Fans' Choice Player of the Year
October 23, 2014 Women's Soccer Takes Over a Share of First Place in the AEC Standings with 1-0 Win at Albany
October 22, 2014 Women's Soccer and Albany Battle for AEC Seeding on Thursday
October 20, 2014 Women's Soccer's Virginia Moyer Earns First America East Rookie of the Week
October 19, 2014 Moyer's First Collegiate Goal Helps Women's Soccer Down First-Place Hartford, 1-0
October 18, 2014 Women's Soccer Travels to First-Place Hartford on Sunday
October 16, 2014 Three Straight Goals Lift UMBC Women's Soccer Past UMass Lowell, 3-1
October 15, 2014 Women's Soccer Welcomes UMass Lowell to Retriever Soccer Park on Thursday
October 12, 2014 Women's Soccer Edges Maine 1-0 for First Conference Win
October 11, 2014 UMBC Women's Soccer Hosts Maine in Homecoming Matinee
October 9, 2014 Women's Soccer Blanks New Hampshire in Scoreless Draw
October 8, 2014 Women's Soccer Hits the Road for AEC Action Thursday at New Hampshire
October 5, 2014 Women's Soccer and Stony Brook Draw in 2013 Title Rematch, 1-1
October 3, 2014 Women's Soccer Takes on Stony Brook in Rematch of 2013 Title Game
October 2, 2014 Women's Soccer Comes Up Short in AEC Opener Versus Vermont, 2-1
September 30, 2014 UMBC Women's Soccer Starts Title Defense at Vermont on Thursday; Retrievers Return to Northeast Top-10 Ranking
September 29, 2014 Women's Soccer's Lisa Nanov Earns Second AEC and ECAC Rookie Honor
September 26, 2014 Brown's Goal Lifts Women's Soccer Past Robert Morris, 1-0, on Friday
September 25, 2014 Women's Soccer Travels to Robert Morris for Non-Conference Finale Friday
September 23, 2014 Three First-Half Goals Lift Women's Soccer Past American, 3-0
September 22, 2014 Women's Soccer's Jessy Brown Named America East Player of the Week; Retrievers Take on American on Tuesday
September 19, 2014 Jessy Brown's Five Points Propels Women's Soccer Past Delaware State, 4-0
September 17, 2014 Women's Soccer Looks to Get Back on Track at Home Against Delaware State
September 14, 2014 Women's Soccer's Falls in Battle of Baltimore Finale at Towson, 2-0
September 13, 2014 Women's Soccer Concludes Battle of Baltimore at Towson on Sunday
September 12, 2014 Women's Soccer's Offensive Explosion Downs Mount St. Mary's, 6-0
September 10, 2014 Women's Soccer Opens Battle of Baltimore Against Mount St. Mary's
September 5, 2014 UMBC Falls, 1-0, Against St. Joe's on Friday. Fall to 4-1 on the Year
September 4, 2014 Undefeated UMBC Women's Soccer Returns Home to Host Saint Joseph's on Friday
September 2, 2014 Women's Soccer's Lisa Nanov Named America East Rookie of the Week
September 2, 2014 A Pair of First-Half Goals Helps UMBC Women's Soccer Past Bucknell, 2-1; Nanov Adds ECAC Rookie of the Week to Honors
September 2, 2014 Women's Soccer Climbs in Regional Ranking; Jessy Brown Named One of 30 Candidates for Senior Class Award
September 1, 2014 Women's Soccer Looks to Continue Momentum at Bucknell
August 29, 2014 Rydon's Lone Goal Lifts Women's Soccer Past Howard, 1-0
August 27, 2014 Women's Soccer Ranked Ninth in the Region; Retrievers Hit the Road to Take on Howard on Friday
August 25, 2014 Nanov's Two Scores Guide Women's Soccer to Come-From-Behind Victory Versus Loyola, 3-2
August 23, 2014 Women's Soccer Continues Home Action Versus Local-Rival Loyola
August 22, 2014 Juniors Guide Women's Soccer Past Navy for 11th-Straight Home Victory, 1-0
August 21, 2014 Women's Soccer Hosts Navy in 2014 Season-Opener
August 20, 2014 UMBC Women's Soccer 2014 Season Outlook
August 13, 2014 Women's Soccer Picked to Repeat as Champs
August 7, 2014 Sandiford Joins Women's Soccer Coaching Staff
July 16, 2014 Women's Soccer Releases 2014 Slate


umpkin lanterns, candy, and all kinds of grotesque creatures and ghosts, this is the "Ghost Festival" Halloween. On this day, the department store industry will also enhance their brands and images through various images and activities.
A painter only needs to look at the palette in his hand before painting, and the photographer's palette is the entire shooting scene. It is not easy to find the right color that can serve your work from such a palette.
originality, the soul as well as life of shopwindow and advertisements.
Originality is the soul as well as life of shopwindow and advertisements. Top fashion brands always impress people by their endless and amazing originality. Swimming pool, a very popular window style is exactly the example of originality.
When display goods, the store should be divided into different areas according to the style and colors of the brand, and tries to make every set of clothes show the sense of design.
Shopping on weekends, I saw a clothing store on the upper floor of the mall designed and produced the "IN ART WE LIVE" series of windows. Characterized by art, the theme of dreams is to convey the business philosophy of the mall to consumers.
UNIQLO has opened global flagship store in Europe and the United States, and recently it opened a new store in Ginza, Tokyo. The store has designed a 12-story glass curtain wall window as the brand display of UNIQLO.
The presentation and display of the merchandise play an important role in attracting the customers into the store and prompting them to buy the products.
Hermes always surprise and impress people by its wonderful color matches.


ADESA Specialty Auctions are the place to purchase or sell a wide variety of trucks, equipment and specialty vehicles.
Throughout the United States, we have ten auctions dedicated to heavy-duty trucks and equipment and 23 to recreational vehicles, marine and powersports. We offer multiple sales channels: in-lane, online and even mobile auctions.
ADESA offers powersports at several specialty auctions throughout the U.S., Canada and Mexico. You'll find wholesale inventory consisting of motorcycles, ATVs and other light recreational and utility vehicles from top consignors such as Harley-Davidson Financial Services and American Credit Acceptance. Don't forget, if you can't attend an actual powersports auction, participate online with DealerBlock or bid live with LiveBlock.
ADESA offers marine products including all types of boats—from towables to documented vessels—at several specialty marine auctions throughout the U.S, Canada and Mexico. Remember, if you can't attend an actual Marine auction site, log in online to DealerBlock or participate in live auctions via LiveBlock. That way you'll never miss out.
ADESA offers used heavy-duty and medium-duty trucks, trailers and equipment at select specialty auctions throughout the U.S, Canada and Mexico. If you can't make it to the actual heavy equipment and truck auction, participate online with with DealerBlock or bid live with LiveBlock.
ADESA features several specialty RV auctions throughout the U.S., Canada and Mexico. These sales are a great opportunity for dealers to acquire hard-to-find inventory. Remember, if you can't attend an actual RV auction site, participate online with DealerBlock or bid live with LiveBlock. That way you'll never miss out.
With the new mobile unit from ADESA, we bring the auction to you. Check-in and sell units, collect payment, work titles and release the vehicles, all from your lot. Perfect for municipalities that want to off-load aging inventory.


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Q: PHP Slideshow Won't Work on Internet Explorer I edited the slideshow on my Drupal site's landing page by accessing the PHP "page.tpl.php" directly and now the site won't work on IE8. It functions correctly on Mozilla and Chrome (by allowing for mouse over and links for the slideshow) but malfunctions with Internet Explorer. I only edited a small portion of the code to allow for basic HTML tags instead of just slideshow images. I changed this:

                <?php
                if($lang_name == "en"){
                ?>
                    <img src="<?php print $base_path . $directory; ?>/images/slideshows/ENGreplacementworkingoncomputer.png" width="950" height="355" alt="Legal Logik"/>
                    <img src="<?php print $base_path . $directory; ?>/images/slideshows/ENGreplacementhandshake.png" width="950" height="355" alt="Legal Logik"/>
                    <img src="<?php print $base_path . $directory; ?>/images/slideshows/ENGreplacementgirlstanding.png" width="950" height="355" alt="Legal Logik"/>
                <?php
                }else{
                ?>
                    <img src="<?php print $base_path . $directory; ?>/images/slideshows/FRreplacementworkingoncomputer.png" width="950" height="355" alt="Legal Logik"/>
                    <img src="<?php print $base_path . $directory; ?>/images/slideshows/FRreplacementhandshake.png" width="950" height="355" alt="Legal Logik"/>
                    <img src="<?php print $base_path . $directory; ?>/images/slideshows/FRreplacementgirlstanding.png" width="950" height="355" alt="Legal Logik"/>
                <?php
                }
                ?>

To this:

                <?php
                if($lang_name == "en"){
                ?>

                    <img onmouseout="this.src='<?php print $base_path . $directory; ?>/images/slideshows/IncorporationENG1.png'" onmouseover="this.src='<?php print $base_path . $directory; ?>/images/slideshows/IncorporationENG2.png'" src="<?php print $base_path . $directory; ?>/images/slideshows/IncorporationENG1.png" width="950" height="355" alt="Legal Logik"/>

                    <img onmouseout="this.src='<?php print $base_path . $directory; ?>/images/slideshows/TransactionsENG1.png'" onmouseover="this.src='<?php print $base_path . $directory; ?>/images/slideshows/TransactionsENG2.png'" src="<?php print $base_path . $directory; ?>/images/slideshows/TransactionsENG1.png" width="950" height="355" alt="Legal Logik"/>

                    <img onmouseout="this.src='<?php print $base_path . $directory; ?>/images/slideshows/ServicesENG1.png'" onmouseover="this.src='<?php print $base_path . $directory; ?>/images/slideshows/ServicesENG2.png'" src="<?php print $base_path . $directory; ?>/images/slideshows/ServicesENG1.png" width="950" height="355" alt="Legal Logik"/>
                <?php
                }else{
                ?>

                    <img onmouseout="this.src='<?php print $base_path . $directory; ?>/images/slideshows/IncorporationFR1.png'" onmouseover="this.src='<?php print $base_path . $directory; ?>/images/slideshows/IncorporationFR2.png'" src="<?php print $base_path . $directory; ?>/images/slideshows/IncorporationFR1.png" width="950" height="355" alt="Legal Logik"/>

                    <img onmouseout="this.src='<?php print $base_path . $directory; ?>/images/slideshows/TransactionsFR1.png'" onmouseover="this.src='<?php print $base_path . $directory; ?>/images/slideshows/TransactionsFR2.png'" src="<?php print $base_path . $directory; ?>/images/slideshows/TransactionsFR1.png" width="950" height="355" alt="Legal Logik"/>

                    <img onmouseout="this.src='<?php print $base_path . $directory; ?>/images/slideshows/ServicesFR1.png'" onmouseover="this.src='<?php print $base_path . $directory; ?>/images/slideshows/ServicesFR2.png'" src="<?php print $base_path . $directory; ?>/images/slideshows/ServicesFR1.png" width="950" height="355" alt="Legal Logik"/>
                <?php
                }
                ?>

And left everything else the same. If anyone has any solutions or can point me in the right direction it would be much appreciated.
P.S. the ($lang_name =="en") is because the site has a translation module installed.

A: I think this has to do with the HTML output of your PHP script, not the actual PHP itself.
Adding a semicollon might fix the problem.
<img onmouseout="this.src='<?php print $base_path . $directory;?>/images/slideshows/TransactionsFR1.png';"


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ONKYO TX NR696 Home Theatre Receiver
ROTEL RC 1572MKII Preamplifier
AUDIOLAB Omnia All-In-One Music System
From CDs and vinyl to state-of-the-art hi-res network streaming, the audiolab Omnia is the all-in-one, just-add-speakers hi-fi system that does it all, and does it in style.
Great. Universal.
For its newest creation, Audiolab has distilled its know-how across these component categories into a single chassis. The result is an all-in-one, just-add-speakers music system dubbed the Omnia.
Housed in a beautifully engineered aluminium enclosure with a crisp, minimalist aesthetic, the Omnia caters for a music lover's every need - from digital streaming to physical CD and vinyl collections. It sports and integrated CD player, extensive inputs for external sources - including a phono stage for a turntable - hi-res network streaming, the ability to form part of a synchronised multi-room system and high-quality amplification to make the most of whichever speakers or headphones the user chooses to partner it with. Most importantly, the quality of its internal design - right down to each individual circuit component - ensures that however you use it, the Omnia delivers a level of sonic performance more readily expected of bulkier and more expensive multi-component hi-fi systems.
The ideal system for every music source
Streaming has become the predominant way in which many people listen to music, which is why contemporary all-in-one music systems often focus on this aspect. This is a critical part of the Omnia's design too, with hi-res network streaming supported over dual-band Wi-Fi and Ethernet cable, alongside Bluetooth for wireless connection to smartphones, tablets and so on. But Audiolab recognises that plenty of people continue to own, and wish to listen to physical music collections - however you choose to listen to your music, the Omnia has it covered.
These days, an integrated CD player is rare to find in a single-box system. The Omnia's transport mechanism is engineered to make the most of any still-treasured CD collection, incorporating a high-precision optical system and low-friction loading tray, with an electronic data buffer and sturdy aluminium base and chassis to tackle vibration.
For vinyl lovers, the integral MM phono stage features a high-quality, low-noise, JFET-based circuit with precise RIAA equalisation - just add your chosen turntable. Other external sources can be connected via a range of digital (asynchronous USB and S/PDIF) and line-level analogue inputs, utilising the Omnia's high-performance DAC, analogue preamp and power amp stages. Further versatility is provided by the ability to bypass the separate amp stages, giving the option to connect an external preamplifier or power amplifier.
Inlaid in the centre of the Omnia's aluminium front panel is a 4.3in full-colour screen, ready to display all sorts of information including system settings, format data and track details. It can even be set to display a VU meter in 'analogue' or 'digital' form, showing real-time decibel levels for the left and right channels - a satisfying graphical representation of the music as it plays.
Digital delights
Despite its attractive simplicity, the Omnia sports cutting-edge sophistication beneath the skin. At the heart of its digital circuitry nestles the ES9D38Q2M - a top-spec, new-generation chipset from the eminent 32-bit Sabre family - accompanied by proprietary circuitry to make the most of ESS Technology's HyperStream II architecture and Time Domain Jitter Eliminator for ultra-low noise and high dynamic range.
No company knows more about making the most of this technically excellent, but challenging to implement DAC technology than Audiolab - the universally acclaimed M-DAC was one of the first audio components to incorporate a chip from the ESS Sabre family back in 2011, and the company has been honing its implementation ever since. One critical element is the post-DAC active filter; Audiolab's design team has paid great attention to this circuit, using op-amps specially selected for their synergy with the Sabre DAC. All digital sources benefit from the DAC's quality, from CDs and audio streamed over Wi-Fi or Ethernet to devices connected via the USB and S/PDIF inputs.
PCM audio is supported to 32-bit/768kHz, alongside DSD to 22.5MHz (DSD512). Every significant hi-res and lossless audio format is catered for, including FLAC, ALAC, AIFF and WAV, as well as compressed legacy formats.
The Omnia also delivers full decoding of MQA, the hi-res streaming technology. This means that the complete 'three unfold' decoding process is performed internally, as opposed to just the final unfold in the manner of an MQA 'renderer', which makes the Omnia an excellent system choice for anyone who subscribes to Tidal's Hi-Fi Plus tier.
Engineered for awesome audio
With many generations of award-winning designs under its belt, Audiolab knows a thing or two about amp design. The Omnia's analogue circuits harness this wealth of experience to compelling sonic effect, its preamp and power amp stages incorporating short, direct signal paths and high-quality components to preserve sonic purity.
Volume is adjusted in the analogue domain under microprocessor control, outputting directly to the Class AB output stage. This delivers 50W per channel into 8 ohms, with maximum current of 9 Amps into difficult loads - sufficient to drive whichever speakers the user chooses to pair with the Omnia.
Many all-in-one streaming systems use Class D amplification, favoured for its space-saving, cool-running power and efficiency. However, Class D designs can sound somewhat hard and sterile; Audiolab's Class AB amp circuitry gives the Omnia a sonic advantage, coupling engaging energy with subtlety and warmth.
The output stage uses a CFB (Complementary Feedback) topology, ensuring superior linearity and excellent thermal stability, as the idle current is kept independent of the temperature of the output transistors. A substantial 200VA toroidal transformer, followed by 4x15000uF reservoir capacity (60000uF in total), helps the Omnia to maintain firm control of the music whilst enabling excellent dynamic range.
Much effort has gone into the physical layout of the Omnia's circuitry, protecting the sensitive preamp section from noise interference. This, plus the use of independent low-noise power supplies for critical stages, helps to give Omnia a clear sonic edge over other comparably priced all-in-one systems.
A streamer's dream
Network streaming is powered by DTS Play-Fi; an app-controlled platform enabling high-quality, whole-home wireless audio, capable of streaming hi-res music up to 24-bit/192kHz and supported by a greater range of established audio brands than any other wireless platform.
The Play-Fi app (available for iOS, Android and Kindle Fire devices, Apple and Android smartwatches, and Windows PCs) is an intuitive gateway to a wealth of music servers, including Spotify, Tidal, Amazon Music, Deezer, Qobuz, Audacy, TuneIn, iHeartRadio and SiriusXM. It is also your trusty music butler, able to serve up a streaming library stored on a DLNA-compatible NAS drive or media server.
Favourite playlists and internet radio stations can be assigned as shortcut 'presets' within the app, while Works With Alexa support enables voice-controlled playback when the Omnia is paired with any Amazon Alexa-equipped device.
In standard mode, which is optimised for multi-room bandwidth, Play-Fi streams at up to 16-bit/48kHz - akin to CD-quality. By engaging Play-Fi's Critical Listening Mode, hi-res audio up to 24-bit/192kHz may be streamed to the Omnia over Wi-Fi or Ethernet cable, without transcoding or down-sampling.
There are ways to stream music wirelessly to the Omnia other than using the Play-Fi app. Users can play directly from the Spotify app thanks to Spotify Connect, and stream from smartphones and tablets without connecting to the local Wi-Fi network via Bluetooth - the Omnia is Bluetooth 5 compliant for optimum quality, reliability and range, and includes decoding for aptX, LL, AAC and SBC.
The Omnia is also officially "Roon Tested", meaning it has been put through its paces rigorously by Roon and certified for use in a Roon audio environment.
As well as the integral CD player and wireless streaming over Wi-Fi and Bluetooth, the Omnia offers a comprehensive selection of cable inputs for analogue and digital sources. Two USB inputs, Type A and Type B, cater for connection to PCs, Macs, smartphones, tablets and digital storage devices, complemented by four S/PDIF digital inputs (two coaxial and two optical) and an Ethernet port for network connectivity. Four stereo-RCA analogue inputs are supplied - three line-level, plus one MM phono input for a turntable.
In addition to a set of high-quality, gold-plated binding posts to connect the user's chosen speakers, headphone fans are served by a front-mounted 6.3mm headphone output fed by a dedicated amp; with its current-feedback design and high slew rate, a dynamic and detailed performance with all manner of headphones is assured. Other outputs include a stereo-RCA pre-out option, as well as coaxial and optical digital outputs.
With Play-Fi multi-room functionality, full MQA compatibility, Roon Tested, and an onboard ESS Sabre DAC (capable of 32-bit/768kHz and up to DSD512), Omnia wipes the floor with its competition.
Wireless Streaming Player
DAC Headphone Amplifier
Digital Stage
CD Player: Tray loading mech with precision optical and anti-vibration systems
DAC Chipset: ESS Sabre ES9038Q2M
Max Sample Rate (USB): 768kHz
Max Sample Rate (Wi-Fi/Ethernet): 192kHz
Max Sample Rate (Coaxial/Optical): 192kHz
DSD: DSD64/128/256/512
MQA: Full decoding via Wi-Fi, Ethernet, USB, coaxial and optical inputs
iOS, Androis, Kindle Fire, Apple Watch and Wear OS App compatibility
Windows PC and Mac compatibility
Spotify Connect
Play from USB Storage
Multi-room functionality
Roon tested
Amp stage
Class AB Amplifier
50W per channel into 8 Ohms
Dual-band Wi-Fi; Ethernet
Bluetooth 5l aptX, aptX LL, aptX, AAC, SBC
Digital inputs:
Asynchronous USB-B (PC/Mac); USB-A (external storage):
2x coaxial + 2x optical
Analogue inputs:
3x line-level RCA-stereo
1x MM Phono
Gold-plated speaker binding posts
6.3mm headphone socket
1x coaxial
1x optical
Analogue outputs:
1x RCA-stereo pre-out
12v trigger in/out
440W x 156H x 327D
"Omnia should be on your shortlist of products to consider."
- Andrew Robinson
While 16-but, 44.1kHz is only a fraction of the resolution on offer with the all-new Audiolab Omnia, it is an integral part of this all-inclusive entertainment package. Because the humble Compact Disc is still in high demand with music lovers the country over. And, according to the recent review by Andrew Robinson, Audiolab's Omnia is "a fantastic all-in-one integrated amp with an incredibly capable CD player built in."
Audiolab 6000CDT CD Transport Player
Audiolab 6000A Integrated Amplifier
AUDIOLAB MDAC Plus (M-DAC+) Digital to Analog Converter
Audiolab DC Block Power Conditioner
AUDIOLAB 6000N Play Network Streamer