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Elected officials given tour of Helena's North Hills Fire
Elected officials tour North Hills fire
Elected officials were given a tour of the North Hills Fire on Wednesday and had the opportunity to ask questions of the responders.
The tour went to the North Hills BLM access and the starting point of the fire.
There members of DNRC, Tri-lakes Fire Chief Bob Drake and Sheriff Leo Dutton explained the behavior of the fire by showing the fuel load in the area, and dangers first responders faced.
Tri-lakes Fire Chief Bob Drake explained battling the fire would not have been possible without local volunteers, law enforcement, state and federal agencies all working together.
"It's a shared burden that we work together," said Drake. "I know it doesn't happen everywhere, but in the tri-county area here we have a really great working relationship."
But even with that support, the dense forest with many dead trees made it almost impossible to effectively deploy personnel many areas.
Lewis and Clark County Commission Chair Jim McCormick said he's thankful for everyone who responded to the North Hills Fire.
"You know this was a tremendous opportunity to see what happened on the ground and in the trees up in the North Hills. It is also a reminder to us that the wildland-urban interface is real and we live in it," said McCormick.
McCormick added that with half of Lewis and Clark County being forested, there are a lot of areas that need constant mitigation attention.
"We have smaller communities that don't get the attention that here in Helena does, but all of our communities in Lewis and Clark County are in the wildland-urban interface," said McCormick.
Senator Steve Daines, R-Montana, told MTN the tour shows there needs to be more work done on proactively managing forests.
"Either we're going to manage our forests or our forests are going to manage us," said Daines. "For the sake of public safety, the sake of environmental stewardship, and the sake of jobs we need to be better stewards of our forests."
Daines has joined with Senator Dianne Feinstein, D-California, to create bipartisan legislation to help reduce the severity of wildfires by expediting and expanding the removal of dead, dying and hazardous trees in national forests.
"90 percent of human caused fires are within a half mile of roads. We would put a priority on thinning projects half a mile on either sides of the roads and that would be a big deal here in this fire outside of Helena," said Daines.
The senator also expressed frustration over lawsuits that have held up forest mitigation projects in the state.
"This becomes a public safety problem and it becomes and environment issue. I'm sick and tired of breathing the smoke like so many Montanans are," said Daines.
Daines said the legislation is currently going through technical review and plans on having the bill on the floor this fall.

redpajama_set_name: RedPajamaCommonCrawl


To whom do the peoples of the Underworld turn when mere strength-at-arms cannot avail them and the godlings are willfully deaf to their pleas?
It reminds me of the planned PC I have up my sleeve. Brock Veinsson, a monk/rogue dwarf whose parents were killed by a laughing drow with their own axes. Swearing vengeance, and to never wield an axe, he roams the Underworld clad in the hide of a dire bat.
We see what you are doing there. We see and we judge.


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Home Article DOING NOTHING ON CLIMATE CHANGE IS EXPENSIVE.
DOING NOTHING ON CLIMATE CHANGE IS EXPENSIVE.
My new employers sure seem to spend a lot of time publishing columnists who are critical of climate science and then publishing op-eds and arguments that essentially trash the take of the original columns. The latest example comes in response to a frustrating effort by Robert Samuelson that took issue with the uncertainty in the models climate scientists are using. Paul Krugman had a very elegant rejoinder to this over on his blog a few days ago. But today, the op-ed page published a reply from Kristen Sheeran and Mindy Lubber, and they make a point that deserves wider airing:
[Samuelson] assumes that all costs involved in mitigating climate change -- and there will be costs -- represent new costs, without acknowledging the massive error in our market system that equates the price of carbon emissions to zero. This fundamental error skews everything that follows, because if emitting carbon costs nothing on a balance sheet, all steps to reduce pollution count as "new costs."The real cost of carbon emissions is far from zero. Each new scientific report brings proof of a changing climate that promises to disrupt agricultural patterns, set off a scramble for dwindling resources, raise sea levels, propel population shifts and require massive emergency spending as we try to react to the growing crises. These are the costs of inaction.
Quite so. There's a legitimate space for constructive criticism of the speculative models that are used in the climate debate. Even the best models have problems. And there's no doubt that sharp questions can make them better, and thus improve the information that policy makers use to craft their response. But if your argument is going to be that climate economics needs to be more honest, then your assumptions have to be pretty transparent, too. And that means you need a transparent estimate of the costs of inaction.This is actually a pretty general problem in Washington. It's easy to show how "doing something" costs money. "Doing something" needs to be written into legislation. It needs to be scored by the Congressional Budget Office. It needs to be explained to the public. But, in general, there's no one who is specifically responsible for explaining how much "doing nothing" would cost. And no one ever has to vote to pass a "do nothing" bill. So they don't pay for the consequences of inaction, even as reformers bear responsibility for the outcome of reform. That makes "doing nothing" a relatively safe play because you never have to argue in favor of nothing. You only have to argue against something.But if we're going to be honest about the economics here, then you have to assess not only the costs of doing something, but also of doing nothing. And if you're going to argue against reforms, then you have to argue why the consequences of inaction are a preferable outcome, not merely why action might prove expensive or uncertain. Choosing the status quo is, after all, a choice.


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Home 24/7 Newly-established Dataxet forges ahead with more than 40 new business wins in...
Newly-established Dataxet forges ahead with more than 40 new business wins in 3 months despite the pandemic
SINGAPORE – Media OutReach – 2 November 2020 – Dataxet, an integrated media intelligence group, headquartered in Singapore and established since July 2020, has successfully forged ahead with more than 40 new business wins — all in just 3 months after acquiring Sonar Platform, News and Ads Monitoring Agency (NAMA) and launching Truescope in Singapore.
Key wins include Carousell[i], Shiseido[ii], Telkomsel[iii], Mola TV[iv], LBS Bina Group[v] and MyIPO[vi] — organisations that are successful leading names within its respective industries in Asia. Notably, the winning portfolio also includes a highly-established regional bank institution along with several government agencies in Asia, validating the credibility of the company's offerings. Dataxet's expertise in media and data intelligence is expected to assist these new clients in augmenting their capabilities across various functions ranging from corporate communications, content strategy to performance marketing.
David Liu, Co-founder & CEO of Dataxet, shared, "From raising seven-figure pre-series A funding during the peak of the outbreak to ongoing regional acquisitions, Dataxet is clearly showing no sign of slowing its trajectory. We continue to chart a healthy revenue growth on a quarterly basis and recruited the best professional and experienced team to run all divisions of the Dataxet's businesses. There are plans in place to continue investing in technology and geographic expansion to further grow the organisation's capabilities in order to enhance the client experience. Dataxet is a new age professional services business supported by people and technology, nothing is more important than the client experience, an area which we are committed to invest."
Jason Lee, Co-Founder of Dataxet and CEO of Truescope Singapore said, "It is a strong testament to Dataxet's capabilities that we have managed to continue to secure these wins despite the COVID-19 economy."
Based on an industry report recently published by SpendEdge, the global media monitoring services market is still going strong and expected to register an incremental spend of about $2 billion, growing at a CAGR of 10.00% from 2019 to 2024. This affirms the growing trend of how data intelligence is expected to become the new 'oil' of the digital economy, with increasingly more organisations expected to invest in this area to derive new stream of opportunities to support their growth and power them through the COVID-19 crisis.
"Clearly, the pandemic has actually focused brands and organisations, more than ever, on the need for smart, timely and relevant data intelligence in order to stay on top of evolving trends and make better informed business and policy decisions. Our proposition – providing clients with comprehensive dataset with localised language insights supported by a cloud base delivery platform, is uniquely at the core of offerings that resonates with our customers." Lee adds.
Amien Krisna, Founder of Sonar Platform and CTO of Dataxet, shares that "certain industries such as Telecommunications, Entertainment Streaming, Gaming will be expected to thrive due to shifting consumer habits borne from the pandemic. For instance, our client – Telkomsel, the leading mobile telecommunications company in Indonesia, recorded a 40.3% YoY increase in data traffic due to an accelerated demand for its mobile data services, particularly during the lockdown. For other industries that are not as 'pandemic-resistant', it is necessary for them to arm themselves with the necessary intelligence in order to stay ahead, pivot and better respond to unexpected behavioural trends and consumption patterns in the new normal."
[i] Carousell is one of the world's largest and fastest growing classifieds marketplace platforms in Southeast Asia. Launched in August 2012, Carousell began in Singapore and now has a presence in eight markets.
[ii] Shiseido Company, Limited is a Japanese multinational personal care company, that is a skin care, hair care, cosmetics and fragrance producer. The company is headquartered in Tokyo, and is traded on the Tokyo stock exchange.
[iii] PT Telekomunikasi Selular, trading as Telkomsel, is an Indonesian wireless network provider founded in 1995 and is a subsidiary of Telkom Indonesia. Headquartered in South Jakarta, Telkomsel is the largest wireless carrier in the country with more than 160 million customers nationwide and providing communication access to 95% of the country's population.
[iv] Mola TV is the Indonesian group of television channels as well as the premium multiplatform cable television, satellite, IPTV, and video on-demand OTT streaming services available for Indonesia and Timor Leste viewers owned and operated by Polytron.
[v] LBS Bina Group Berhad is a Malaysia-based investment holding company and provides management services to its subsidiary companies.
[vi] MyIPO is an autonomous and corporatized agency responsible for the development and management of the intellectual property system i.e patents, trademarks, industrial designs, copyrights and layout designs of integrated circuits in Malaysia.
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Una Voce
Una Voce Archive
PNGAA Collection
Members Activity
Papua New Guinea Association of Australia
Vale December 1996
by president · December 20, 1996
BEARD, Enid Vivienne | BUTLER, Debra Ann | CATTANACH, Robert Gordon | FORD, R J (Ron) | GRIGG, Andrew Edward | MORRIS, Lewis Arthur (Len) | MOXON, Geoffrey Gordon (Geoff) | RYAN, Gwendoline Mary | STEWART, Eric James | SYMES, William (Bill) David | TONG, Timothy Kam Sing | WESTON, Bert | WOODMAN, Constance Margaret |
Enid Vivienne BEARD (28 September 1996, aged 77)
Enid passed away at her home after three months of gradual heart failure and, during this period, suffered considerable discomfort and pain. Her cremation was attended by many PNG friends.
Enid was destined for the Hospitality Industry from early womanhood, and in the mid-sixties, along with Ted, proceeded to PNG and took up managership, firstly at the Hotel Cecil in Lae. Years later, Enid's happy, smiling face could be seen at the Huon Gulf Motel, Lae and for the last two years at the Gateway in Moresby, finishing up just a few months prior to Independence. She contributed greatly with her training of local staff in the various hotel/motel sections, particularly in catering and administration.
Enid is survived by husband Ted. [The foregoing was written by Enid's husband, Ted. Ted is Treasurer of the Gold Coast Papua New Guinea Club.]
R J (Ron) FORD (9 May 1966, aged approx 69)
Ron arrived in PNG in 1958 after training as a motor mechanic. He joined the Department of Agriculture, Stock & Fisheries in the late 60s as an agricultural mechanic based at the Kila Kila workshop; he later transferred to Goroka as a Technical Officer, and later to Lae. His last position was with the Development Engineering Section of the Department of Primary Industry, based at Kila Kila. He left PNG in 1981 and settled in Coolangatta Qld in his old family home which he began renovating; however illness forced him to abandon his plans. Ron mixed very little with people, but loved dogs and always had one for company; his other love was his car. Joe Nitsche visited him every year while travelling to Queensland, and helped him maintain his links with PNG. Ron is survived by a sister who lives in New Zealand. Arch Dickson of Kapunda, SA, and Joe Nitsche
Lewis Arthur (Len) MORRIS (5 September 1996, aged 88)
Len Morris had a distinguished career in oil exploration in both Territories between 1938 and 1968. He arrived in Madang in 1938 to take up a position with Island Exploration which soon after became aligned with the Australian Petroleum Company (APC) based in Konedobu. Len served in ANGAU under Brigadier Donald Cleland. He became Managing Director of APC and was the Company's senior Territory based representative from 1958 to 1968. He died in Warrnambool following a heart attack.
Len is survived by his two daughters, Gwyneth (Gwen) Burnet and Megan Morris, three grandsons and one granddaughter. Ian Burnet (Len's son-in-law)
Bert WESTON (14 October 1996, aged 95)
Bert Weston, who left the family farm to dig for gold in Papua New Guinea, and stayed there to distinguish himself as an engineer, soldier and aviator, died in Sydney on 14 October, aged 95.
Soon after arriving in what was then a remote part of the Territory of New Guinea, Weston emerged safely from a night attack on his camp by local warriors, feared as cannibals. He escaped by crawling along a dry riverbed. Later he survived an even more dangerous encounter with Japanese forces when his aircraft was the only one of three to return from reconnaissance operations during the Milne Bay campaign.
At various times Weston raced motorcycles, beginning with a 500 cc Triumph. He won his last race at the old Maroubra track on a 1000 cc Indian of 1923 vintage. Bert Ernest Weston was a direct descendant of another fanner and soldier, George Johnston, who commanded the NSW Corps and deposed Governor Bligh in the "rebellion" of 1808.
Weston was born on 23 February 1901, in Albion Park, NSW, where his family had received a grant of land from Governor Macquarie. He attended the local school, about which he wrote entertainingly in the Herald more than 90 years later, and Wollongong High School.
Weston was supervising the building of airfields, lighthouses and various public utilities in New Guinea and on Nauru when World War II began. He was commissioned in the Royal Australian Engineers, and was often called upon to advise military officers in Papua and New Guinea about the terrain over which operations were to be conducted.
After the war Weston pursued a career as a civil engineer in Sydney, working on some major projects. He also found time to write extensively on local historical themes and issues in letters to the Herald. Even after he retired from business in his late 80s he continued writing. Earlier this year his short history, The Albion Park Saga, 1900-27, was published by the Albion Park Museum.
After a fall on a wharf near his Milsons Point home in July, his health deteriorated. He died in his sleep in Greenwich Hospital on 14 October, cuddling his Burmese cat, Puss.
Weston's wife, Constance, predeceased him. He is survived by his daughter, Shay Martin, and a sister, Thelma Stewart.
Bert Weston's last letter to the Herald from 23 September 1994: "The unfortunate town of Rabaul surely suffers enough [from volcanic eruptions] without having its name being given so many pronunciations by TV and radio newsreaders. In my many years residence in New Guinea, we always knew it as raBAL not raBAWL, raBOOL, or raBOWL (to rhyme with OWL). Also one newsreader spoke of 'cocker poo'. We always knew it as the district of Kokopo (cock a po)."
[Obituary and Bert Weston's last letter are reprinted from the Sydney Morning Herald dated 18 October 1996, with thanks.]
In the issue of the Herald dated 21 October 1996 in the "Postscript" column, Letters Editor Geraldine Walsh recalled a letter from Bert stating that over the years editors had published about 50 of his letters. Bert continued, "I hasten to add that ….I was an engineer and a very amateur scribe with my typing limited to the one finger 'hunt and peck' system. At present I have set my sights on the century." The item concludes, 'Sadly, Mr Weston, a treasured correspondent, didn't reach his goal. Vale Bert E. Weston, 1901-96 – Jana, Melissa, Antony and Geraldine.
Geraldine Walsh
William (Bill) David SYMES, MB BS, FRACMA, DTM&H, DPH (18 September 1996, aged 68)
Bill Symes was born in Adelaide on 4 April 1928 and graduated in medicine from the University of Adelaide in 1952. He went first to Norfolk Island, then to TPNG in 1954 and was posted soon after to Goroka. Bill met Wynne (Kit) Beck during his term on Norfolk Island and they were married at Goroka in 1955. Early in his career, he showed his thoroughness in clinical medicine and an interest in public health and health education.
Bill studied Tropical Medicine in Sydney in 1956 and returned to Goroka as the Regional Medical Officer during the consolidation period of the Highland health services. In 1958 he moved to Port Moresby with responsibility for the Papuan Region and from time to time was seconded as Assistant Director. His clinical interest continued with care of obstetrics at the St Therese Maternity Hospital at Badili. In 1962 he studied Public Health in London and in due course was promoted to Assistant Director of Medical Services. In 1968 he became one of the Founding Fellows of the Australian College of Medical Administrators.
Bill was involved in community work, particularly with St John's Ambulance, where he ran many first aid courses. He was awarded the 0 St J medal in the Queen's Birthday List in 1966. He was also a radio personality as Doctor of the Air, and a guest speaker on the ABC gardening session – his topic was 'Growing Tomatoes in the Tropics'.
In 1970, Bill became Director of Public Health and oversaw the final stages of the nationalisation process of the Department and the appointment of Dr Reuben Taureka the first National Director. He returned to Adelaide in 1973 and for some years held a senior position in the Public Health Section of the Health Commission of SA and after retirement continued for five years as Chairman of the Waste Management Committee.
Bill was at all times and in all ways a competent physician, sincere and thorough in his activities and a major contributor to the development of the health services of Papua New Guinea.
He retired in 1985 and in 1989 Kit and Bill moved to Queensland to be nearer their children and grandchildren. Bill died after a long fight with colon cancer. Bill is survived by his wife Kit, and daughters Lynda, Diane and Marie. Dr Roy Scragg, supplemented in a few places with additional information supplied by Bill's daughter Diane.
Timothy Kam Sing TONG (11 September 1996, aged 52)
Timothy Tong of Kavieng, formerly of Rabaul, died suddenly at Kavieng Hospital. He is survived by his wife Pauline, and children Gene Michael, Anthony, Ferris and Sharlene. No further details available
Robert Gordon CATTANACH (13 August 1996, aged 79)
Robert served in the 9th Division in the Middle East and PNG during World War II. His first posting to the PNG administration was as a tractor operator at the Keravat Government Sawmill in the later 1940s. In 1955 he was posted to Bulolo as a Senior Technical Officer where he was responsible for all the road construction and maintenance work in the extensive reforestation areas of Bulolo and Wau. He retired from Bulolo and 1972 and settled in Jacobs Well, south of Brisbane, where he enjoyed fishing and golf. His wife predeceased him. Don McIntosh
Gwendoline Mary RYAN (31 October 1996, aged 86)
Gwen was born in Port Moresby and lived there most of her life, except for the wartime period. She was the daughter of Horace and Helena Hides, who settled in Port Moresby in the early 1900s. One of her brothers was Jack Hides, the famous Papuan explorer. Before the war Gwen worked in the Government Secretary's Department. During her married life she lived in Samarai, Rabaul, Port Moresby and Lae. She left PNG in December 1973. Her husband, who was with Burns Philp, predeceased her. Gwen is survived by a son and two daughters and numerous grandchildren.
Andrew Edward GRIGG (17 September 1996, aged 81)
Andrew Grigg was employed in the Public Works Department in PNG. He retired in June 1971. No further details available.
Constance Margaret WOODMAN (21 September 1996)
Mrs Woodman was the wife of the late Harold Eustace Woodman. No further details available.
Geoffrey Gordon (Geoff) MOXON (21 August 1996)
Geoff Moxon of Salisbury, formerly of PNG is survived by his wife Elma. No further details available.
Eric James STEWART (18 October 1996)
Eric Stewart, late of Bribie Island Qld and previously of PNG, is survived by his wife Fiona and children Michelle and Raymond. No further details available
Debra Ann BUTLER (September 1996)
Debra Butler of Caloundra, formerly Rabaul PNG, is survived by her husband Noel, and children Jacob, Tahlia, Glen and Diane.
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PNGAA 68th ANNUAL GENERAL MEETING – 28 April 2019, Address by Incoming President – MAX UECHTRITZ
PNGAA 68th ANNUAL GENERAL MEETING – 28 April 2019, President's Report – ANDREA WILLIAMS
New name for PNGAA journal – entries due 14 January 2020
About the PNGAA Collection – Cheryl Marvell, 2019 PNGAA Christmas Luncheon
Bougainville poll supports independence
PNGAA
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President: president@pngaa.net
Secretary: admin@pngaa.net
Membership: membership@pngaa.net
Collection: collection@pngaa.net
Papua New Guinea Association of Australia Copyright 2014


text:
crazyfirecrotch
Lance Bass Slams Chris Brown: 'The 'F' Word Is Just Like Calling You The 'N' Word'
Lance Bass is calling Chris Brown out — about a certain word the R&B star should toss from his vernacular.
After a history of the letting the word "f**got" fly, whether it be in his hit "Look At Me Now" or an alleged attack on a fan, Brown has again come under fire for the homophobic slur. In the wake of Brown's brawl with hip-hop artist Frank Ocean in late January, Ocean — who came out in late July — revealed to investigators that he was called the "f" word by a member of Breezy's crew during the fray. And that simply doesn't sit well with the openly gay Bass.
"Calling people faggot and that stuff, I mean, he may not even mean what he means, but it's a derogatory term that people throw out there and without even knowing why they are saying it," Bass told Celebuzz. "But when it comes to Frank Ocean and knowing that he's … very out … it was definitely meant to hurt him. It's never good to throw those words out there that mean so much."
And it upsets Bass all the more that the slur is being thrown around by a minority.
"[Brown] should understand that being a black man himself. He should know that the F word is just like calling you the N word in a very derogatory way," Bass said. "When you come from a minority like that, being gay or black or whatever, it's like there should be an understanding, like we all get each other. But you don't see that a lot, which is really sad."
The "f" bomb adds to Brown's already-lengthy track record of a bloody bar brawl, a foul-languaged Twitter feud, a controversial Halloween costume, and an ever-eyebrow-raising love life. And though Ocean opted not to press charges — and authorities will soon close the clash case — the "Don't Wake Me Up" singer landed in more hot water Tuesday when the Los Angeles Country district attorney's office accused him of falsifying court-ordered community service filings
Given Brown's brushes with the law — dating back to his 2009 felony assault of recently reconciled girlfriend Rihanna — Bass sees the singer striding down a bad path.
"I think there are a lot of people out there that have anger issues, and you can definitely see that in Chris Brown. I hope he gets the help he needs," said the former 'N Sync member, who now hosts a live SiriusXM radio show called Dirty Pop with Lance Bass. "I hope Rihanna understands what she is in. I see it happen so many times in couples, where it's like an abusive relationship and you don't know it's an abusive relationship."
http://www.celebuzz.com/2013-02-07/the-reason-chris-brown-shouldnt-use-the-f-word-and-no-its-not-the-one-you-think/
Tagged: chris brown
11491149 comments
goodassjob
Are you stupid? Clearly he was the one at fault in that instance. I was obviously listing opposite instances, where he kind of wasn't the one at fault yet was blamed for it anyway just because people don't like him.
noneformethanx
He can always quit twitter. But he comes back. It's because he's a spoiled child whos constantly expected to take responsibility for his bad behavior. When he's called out on it, he's the victim. I am not stupid by any means. I'm not living in a delusional stan world
Lol. He is entitled to have a twitter account like anyone else? What a stupid argument. He doesn't have to delete his twitter if he doesn't want to just because other people are harassing HIM. Taking responsibility for his behavior has NOTHING to do with people throwing bottles at him not does it excuse people HARASSING him. Calling out someone =/= replying to their every single tweet with disgusting hate messages on a daily basis, nor is it throwing foreign objects at peoples faces in clubs. And still, how does that make that HIS fault? What does any of this even have to do with stanning?
Chris beating Rihanna was wrong, yes. But whether you like it or not, that does NOT magically make it okay for other people to attack him or for him to be harassed. Nor does that make him at fault for instances where other people are attacking and harassing him.
aquaricom
i cant stand CB, and personally I do think he has a hard time taking responsibility but I understand what you are saying. Im not surprised he compared himself to Jesus Christ.
t_na
Every single famous person has multiple people constantly threatening their lives and attacking them and for nothing online.
Please feel free to show me what famous person has someone like Jenny Johnson harrassing them on a daily basis consistently and replying to every single tweet they make with extremely sensitive disgusting personal things.
ellenelles
every famous person? like....
autumn1234
........honestly wondering if you ever actually READ ontd or just comment here..
dubiously
Gurl I'd be surprised if even people in small local theater don't get at least one hater doing that to them everyday.
Kim Kardashian off the top of my head and I'm pretty sure by the same person and for much less than what Chris has done. So there you go.


text:
HomeAirscape – L'Esperanza (Armin Van Buuren's Rising Star Mix)
Airscape – L'Esperanza (Armin Van Buuren's Rising Star Mix)
Fun Jio November 20, 2020
http://www.blackholerecordings.com/music/albums/airscape-lesperanza-s-g-2009-remix/
Subscribe to Black Hole Recordings TV: http://bit.ly/SubscribeToYoutube
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Some classics keep their strength for decades. We can safely say that Airscape has already firmly established that notion, hence the fact that ten years after its initial release, the original producers behind this anthem, Johan Gielen and Sven Maes, decided to give "L'Esperanza" an incredible state of the art makeover. The S&G 2009 Remix of "L'Esperanza" is a true powerhouse version, that will impress both the party people who were there when it all happened and most certainly the current trance aficionados. The 2009 remix delivers a truly symphonic rendition, complete with harder beats, new percussion and thick layers of ripping strings that carry the heart wrenching theme to new heights. The DJs that will play this version during their live sets should brace themselves for an ecstatic dance floor where everyone will raise their hands in the air all the while totally enjoying the touching and overwhelming deep trance sound of the song. To complete the full history of "L'Esperanza", we have included the excellent but hard to find 1999 original version plus the remixes by Tiësto and Armin van Buuren. Airscape with "L'Esperanza" in the S&G 2009 Remix is a monster track that will last for another decade! More Info: http://www.myspace.com/johangielen
Airscape,Esperanza,Armin Van Buuren,Johan Gielen,Tiesto,Svenson
చేసేటప్పుడు పెద్దగా ఉంటది చేసాక చిన్నగా అవుతాది ఏంటి || Harika Smiley || Pataka talks
(134 Mistakes) In Total Dhamaal – Plenty Mistakes In Total Dhamaal Full Hindi Movie – Ajay Devgn
My First Date (ft:Vinay Kuyya) || Telugu Standup Comedy || Kuyya Talks


Education is closely associated with social enrichment and inclusion, the upgrading of human capital, increased opportunities, and enhanced freedom and welfare. That is why it is very high on the current Pakistani government's agenda.
ISLAMABAD – The importance of education – and especially schooling – cannot be overestimated. Not only has the expansion of primary and secondary education been linked to accelerated economic growth, poverty eradication, and improved income equality, but education also appears to be closely associated with social enrichment and inclusion, the upgrading of human capital, increased opportunities, and enhanced freedom and welfare. That is why, as Pakistan's prime minister, I have placed universal access to education very high on the national agenda.
Education influences the way people perceive the world around them, understand issues, and find solutions to their problems. It makes them more aware of their rights and duties and affects how they interact within their communities and with the state and its institutions. Above all, it enables them to think critically and question established wisdom, thereby enabling them to rise above prejudice, myth, and restrictive historical legacies.
In this sense, education is a major driver of social progress. And it is the key to fulfilling my promise, made when I took office two years ago, to create a new framework for social change in Pakistan, one that ensures equal opportunities and social justice for everyone and stops the exploitation of the poor and harnesses their potential.
Muhammad Nawaz Sharif is Prime Minister of Pakistan.
Your say certainly matters and this is indeed a great initiative by you to speak publicly on this important subject. It is hoped this will not be just a one timer but a constant push from you which is indeed a dire need to streamline affairs of our country's education sector.
I want to draw your attention towards a very significant aspect visavis education for all i.e., the laws by our provincial governments for Right to Education (RTE).
Dear PM, its been over five years since insertion of Article 25-A in the Constitution of Pakistan which promises free and compulsory education to children of the age of five to sixteen years across Pakistan. Except the province Khyber-Pakhtunkhwa (KP), other provinces have introduced laws under the Article 25-A. However the rules of business are still missing owing to which the implementation of these laws is impossible. The need is to push the KP government to introduce the RTE law and others to introduce rules of business at the earliest.
Dear PM, we already missed most of the six EFA goals and now is the time to gear up for the post-2015 agenda and to ensure that we achieve as many goals as possible by the year 2030.
The rule of thumb: spending more is the solution to the education rut in Pakistan.
Some recommendations which will bring betterment and save some money and time and bring good results. Frist of, education should be taken back from Provinces. As it has left them totally confused and given the excuse to the poorer provinces that a well off Punjab has the luxury of spending more which the remaining three provinces cannot afford. Secondly, education should be a national issue in Pakistan. It is high time that the Federal Government should take the responsibility of universalizing the education in Pakistan under the aegis of the United Nations and making it to the standard of OECD countries instead of regionalizing it in running the schools through different mediums, i-e Urdu, Balochi, Punjabi and other regional languages.
The system is so different that students from Sindh learn from their curriculum the Constituent Assembly Address of Quaid which tells them their identity of religion vanished the day Pakistan came into being and they have to continue as Pakistanis onward. While in Khyber Pakhtunkhwa the birthday cakes and triangle shaped trees are removed under the impression that it will help preach Christianity in the students.
We have the second largest out fd school population in the world. What have you done? Your (party's) provincial government has used up unspent education funds for building roads and dodgy contracts for infrastructure.
This is just a case of making the right noises before the summit. We Pakistanis know your commitment to the cause.


I would like to make the following rule but haven't had any success in the variations I have tried.
Essentially if a false alarm occurs and the system is reset I want the system to send another text. I have tried several variables of disarmed and arming or becomes disarmed but none seem to work.
Rules trigger at the moment when an event happens, such as the alarm going off, or the system going from armed to disarmed state. That is, a change of state takes place. The change-of-state condition needs to be the first thing that the rule tests. So you can't have a rule that says "If System is alarming". That's a state, not a change from one state to another. You are trying to write a rule that captures two events that happen at different times: the alarm going off, and the system being disarmed.
One solution is to break things down into multiple rules that catch the change of state, and use phantom outputs to "remember" that the other condition exists.
You might also be able to do it this way. I forgot that you can test for an alarm being active in an AND clause. So the trigger is the change of state from armed to disarmed, and the secondary (AND) condition is that the system was already in the alarm state.
Edited by RAL, 25 February 2018 - 03:01 PM.
Thanks for the reply. I will give the first option a try tonight and see how it works. I think your description of how rules work is accurate as to why my programming failed.
I attempted to do your second option when I was programming and it didn't seem to work. I will try it again as well. Will let you know & thanks again.
I think the second method may not work as a single rule for the following reason: The rule triggers when the system changes from armed to disarmed state. The AND clause is evaluated a moment later, and when it checks to see if an alarm is currently active, it evaluates to FALSE because disarming the system took it out of alarm state and the condition is no longer valid.
By using an output to remember that the system was in alarm state, it allows the condition to carry over and evaluate correctly even after the alarm is disarmed.


text:
Spain to mourn virus victims for unprecedented 10-day period
Spain will be observing its longest mourning period in democratic times starting Wednesday to recognize the nearly 27,000 people who have died with the novel coronavirus in Spain
By ARITZ PARRA Associated Press
World Health officials warn of 2nd peak as Brazil's cases soar
Thousands more infections and hundreds more deaths from COVID-19 have been reported in Brazil as American plans to ban all travelers from the country except U.S. citizens.
MADRID -- The Spanish government has declared 10 days of mourning starting Wednesday for the nearly 27,000 people who have died with the novel coronavirus in Spain, the longest official mourning period in the country's 4-decade-old democracy.
Flags will be hoisted to half-staff in more than 14,000 public buildings across the nation and on Spanish naval vessels until June 5, under the declaration made Tuesday. King Felipe VI, as Spain's head of state, will preside over a solemn memorial ceremony once the country emerges from the lockdown imposed 2 1/2 months ago, the government said.
The dead are "men and women whose lives have been suddenly cut short, leaving friends and family in great pain, both from the sudden loss and from the difficult circumstances in which it has occurred," government spokeswoman María Jesús Montero said following the Cabinet meeting where the grieving period was approved.
Opposition parties had criticized Prime Minister Pedro Sánchez's left-wing coalition government for not paying tribute to the virus pandemic's victims as Spain's death toll - the world's fifth-highest after the United States, the United Kingdom, Italy and France - became a point of political debate.
Arguing that some unconfirmed virus cases had been erroneously counted, Spanish health authorities reduced the country's official mortality figure by 1,918.
Montero said that 80% of Spain's virus-related deaths were people age 70 or older, "those who helped build our country as we recognize it today, and ultimately laid the foundations of our democracy."
"They might not accompany us physically, but they will remain forever in our memory," she said.
Flags at half-staff and other expressions of grief have become common around the world during the pandemic.
In Italy, the military's aerobatic team honored the dead over the past few days, saluting cities such as Codogno, Milan and Turin with flybys. Nightly or weekly applause and singing to honor medical personnel working to save lives has been the most clear expression of collective unity amid personal losses and the isolation of lockdowns.
No other country so far has announced an observance on the scale of Spain's 10-day mourning period, an event unprecedented since the country reinstated democratic rule in 1978. Three years earlier, when dictator Gen. Francisco Franco died, a 30-day mandatory mourning period was declared. Three days of mourning were observed in March 2004 for nearly 200 victims of Al-Qaeda-inspired attacks on Madrid commuter trains.
COVID-19 deaths have become a touchy issue for Sánchez's government since it imposed a strict lockdown on March 14 with the aim of slowing the spread of the virus. In the ensuing 10 weeks, the death toll climbed from 120 to 26,800, and confirmed infections in Spain grew from 4,200 to over 230,000.
Spanish politicians across the political spectrum, left and right, have raced to capitalize on the collective loss.
National flags with a black-ribbon have appeared on the balconies of apartment buildings and in the hands of right-wing protesters, a symbol of the country's loss and of anger over the government's handling of the pandemic.
Authorities in the hard-hit Madrid, a stronghold of the conservative opposition, put gigantic displays of black ribbons at some of the Spanish capital's main landmarks. As a permanent tribute to COVID-19 victims, local officials installed a cauldron with a gas-powered flame in front of City Hall. A plaque, surrounded by floral bouquets, reads, "Your flame will never go out in our heart."
In recent weeks, strict home-confinement orders and bans on public activity have eased across the country.
"They should have declared the mourning days ago," Madrid resident Conchita Hernández, 77, said. Her husband, Agustín Álvarez, 77, compared the Spanish capital's nearly 9,000 virus-related deaths to the casualties during times of war.
"The mourning would have made more sense when we were all homebound, but I still think it makes a lot of sense," Álvarez said.
AP reporters Bernat Armangue in Madrid and Colleen Barry in Rome contributed to this report.


text:
Jarne Verbruggen had a heavy part last March called "PROFESSIONAL LIFE." Jarne talks about struggling with alcohol, back to back video parts and the flowerpot incident.
──JARNE VERBRUGGEN (ENGLISH)
[ JAPANESE / ENGLISH ]
Photos_Guillaume Perimony
VHSMAG (V): So for the readers that don't know, could you tell me where you're from?
Jarne Verbruggen (J): I'm from Belgium. I was born in Mechelen. It's a little town between Antwerp and Brussels. It's really the middle of the country. It's not that big of a city but it's close to Antwerp and Brussels, which was pretty cool.
V: You're currently living in France?
J: Exactly. I live in Biarritz now.
V: Why did you move there?
J: Because my good friend Phil Zwijsen, he lives here. Romy Bertrand is a good friend of mine too. She used to work for Element. I came on a holiday here to meet them, and then I stayed for six months. Then after six months I found my own place with my good friend, Rafa Corts from Madrid. And now we live in Biarritz.
V: You had "What Paradise?" part last year, which was amazing. You were talking about struggles you had to go through with alcohol. How long were you fighting with it?
J: Since a while, actually. I had this since I was 17 or 18. I realized I had a problem. Took me a while to really reach out for help. A couple years I was drinking a lot, and knowing that I had a problem but not really admitting it to myself. I wouldn't want to involve other people into it because if you reach out for help, it's a big step and it becomes a real thing. And you also have to do something about it, you know? You have to first want to do something about it, and then you got to ask for help, which are two difficult things. Then when I did that, people around me were all really aware of it, but they really understood it. It was actually the best thing I ever did to myself, to tell my mom and stepdad about it, and then to all my close friends.
V: I heard you went to rehab center as well.
J: I actually went three times in the span of two and a half years. I filmed that part straight out of my last rehab in January of 2019. That's why we've built up the part like that, I guess. Moving out of Belgium changed me as a person, made it a lot easier for me and my drinking problem, which I still have. I know I'm going to have it through all my life. Yeah, it's just a way to handle it, with the right people. I'm feeling pretty good about it now.
V: What inspired you to come back on track?
J: Skateboarding and my family. My family was pretty devastated at one point, because I reached out for help and then I went down under again. I can't really do this to them and my friends. It was pretty selfish what I did, actually.
I saw how it feels to lose it all. And that made me really realize what I have.
V: You went pro for Element in 2016, right? What happened to that?
J: Well, when I was skating for them they paused my contract and it hit me right in the face, "Okay, I'm really losing it." And yeah, I talked to Nike and I was like, "I really don't want to lose everything." They believed in me, that I really wanted to get off of it. That was a big boost for me to really step it up again and not just throw my life away.
V: What did you gain from that struggle?
J: I saw how it feels to lose it all. And that made me really realize what I have, and I should really cherish it. It sounds a bit cliché, but not take anything for granted because I used to really do that. I think because I'm skating since I was 12, and I'm getting sponsored since 14, and I'm going on trips since I'm 15, and I've been getting stuff for free. At one point, I was just used to not pay for anything, so I never really got this thing of having to work in my life. I was never experienced with how it is to really work for something, but I really learned that. I'm lucky to have this life, you know?
V: You overcame your demons and you made that part.
J: I was still a bit demonic during that part though. But yeah, that was the way.
V: One thing I wanted to ask about that last trick... you do that thing down the brick bank with the crack in the middle... and then there's this pretty girl... There was a subliminal phone number thing. Who's number was that?
J: That was my number.
V: Did you get a call from that girl?
J: Well, actually, yeah.
V: You did? No way!
J: I think somebody told her and she texted me. That bank is in Barcelona and she was studying in Antwerp, I think. That was crazy. It was a year ago or something. I texted a bit with her but I actually never saw her. She was in Antwerp but I think I was in Croatia on a trip or something. I was like, "Well, you're studying in Antwerp. I live in Belgium. It's super crazy." But I never got to see her. We never hooked up. I have a different number now. She's probably been reaching out to me, but...
V: After "What Paradise?" part you never stopped. You had the Spitfire "One Week With Jarne." That girl Maité is in all your videos and she's got a great vibe.
J: Yeah, exactly. She's from Antwerp. She's amazing. She's actually as amazing in person as you see her in videos. She's really a special girl. She's really, really cool. She's what skateboarding needs at this moment too, I think. I'm happy to call her a good friend. I used to know her since she was really small. She was 10 maybe, I think she was doing handplants already. As you say, great vibes around her, you know? She's a smart girl, and it's cool to talk with her about stuff. She's not a brainless skater or whatever.
V: Let's talk about your new part, "Professional Life." That was super heavy 12 minutes.
J: Thanks. Actually, the first part of the part is all in Croatia, because my mom moved there. Then I went there with Guillaume Perimony on a trip, and we filmed there a lot. We went there seven or eight days and we filmed the whole Croatia part. I had this idea in mind to do a VX part and a HD part in a single part. And then do some funny skits in between. Try to be funny, you know? But I was putting a lot of pressure on myself because I wanted to step myself up. And it didn't come easy. I had so many tricks I didn't land. It wasn't the funnest time to be honest. I became kind of cranky about skating, or whatever. And then the flowerpot thing happened. Because I wasn't having the best vibes about my skating, you know what I mean?
The guy hit me with the flowerpot. I went dark in my head and I woke up at the bottom of the stairs.
V: Yeah, that flowerpot clip was insane. What exactly happened?
J: We came to the spot and I was trying the hippie jump. Then the guy opened his window and started yelling. I was like, "I think I can do this fast. We're going to go in five minutes, don't worry." And he went back inside, and I was trying, and all of a sudden, he came with a flowerpot. He just started throwing and he almost hit Guillaume. I was super scared to do the trick, and then there was a guy aiming at me with a flowerpot so it was pretty intense.
V: Yeah, we could all feel that vibe by just watching the video.
J: There was a lot of cars coming through too. My two friends were looking for the cars. It was the most stressful session ever. But I knew I could do it, so I was like, "Fuck it, I'm not going to stop." And then the guy hit me with the flowerpot. I went dark in my head and I woke up at the bottom of the stairs. I didn't really know what happened. I didn't know I hit the wall.
V: Oh, you didn't know you hit the wall...
J: Yeah, and then the neighbors knew the guy was kind of crazy so they called the cops on him. I think he's alone, you know? He lives alone, and if people are alone too long you just go berserk. It's not healthy, you know? I felt sad for him, although he tried to kill me. So the cops came, and they came to us and asked if we were okay. I told them I got hit and they went to talk to the guy because the neighbors called him for attacking us. Then the cops went inside so we had three or four more tries to do it without the guy throwing anything. He was also throwing sticks and stuff, anything he could find in his apartment.
V: It wasn't just the flowerpot…
J: Then I did it. And exactly when I did it, different cops came for us and they were like, "What the fuck are you doing? You're on a private property. You shouldn't be doing this." And then the first cops came to talk from the apartment and they were arguing with each other. The cops that came for the flowerpot guy were like, "These guys were not doing anything wrong. They were not even on private property. They were doing the right thing with having guys on the street, watching the street." So they saved us from these pair of cops. They asked me if I wanted to sue the old guy, but I didn't want to go to the police station after that. I was just over it. And I was happy I did the trick. I was really satisfied, I guess. And then the guy came down and he was screaming about the mess. We were like, "Fuck man, what you did is so stupid." He was still mad.
V: So nothing really happened to the old guy? Not even arrested?
J: No. But we watched the footage at home and I saw that I hit the wall... I was like, "Fuck man, that dude actually could have killed me. Fuck that guy." And Guillaume said, "Yo, look at how he lives, look how he acts. He's already punished enough by his own life." You know what I mean? And it's true. I was like, "Whoa, yeah, that's actually true. What are we going to do about it?" You know? If you're doing that shit you're already pretty fucked up.
V: Yeah, that sucks...
J: It's kind of sad... But that was pretty insane. I probably have a little bit of brain damage but that's probably from other shit. I'm fine, so whatever, it's all right. We got the trick and Guillaume filmed the whole thing, he wasn't scared. That was crazy because I was fucking scared. And he was just looking through his camera, not even looking up. He could go work for National Geographic, lions and shit like that.
V: He deserve a Pulitzer.
J: And then, another crazy shit happened. I was in Paris, and I still wanted to get a trick. I tried something and I broke my foot really bad. I was hurting myself for a while trying to get these parts, and it was enough actually. I kept going, I couldn't stop. I think it was a sign telling me, "You got to chill."
V: The music was nice too.
J: We didn't get the music right for the last song. So Guillaume tried to learn piano to make the song. And after a while he was like, "It's too hard to do it in this amount of time. This is crazy." So he actually did it on his computer with software which is pretty insane too. He actually made the song. He always finds a solution. It's pretty dope and that's why I really like him. He's always positive. It's really cool to work with him.
V: That's awesome.
J: Wait, I just realized I have my earphones for nothing.
V: What?
J: I couldn't hear you through the earphones. I was looking all professional up in here, but it wasn't plugged to my phone (laughs).
V: Get rid of that (laughs). Which trick from the part are you most stoked on?
J: I think half cab up and then back three down the stairs. Because I never really did back three down stairs, and probably never will again. I had a bet with Guillaume. If I don't land it now, I got to pay up $50. And in the end, I was betting my car on it. Then I broke my board and had to go get a board because there are no skate shops in Croatia. So Guillaume owned my car and he was always telling me like, "Yo, your car is mine." I was like, "Fuck, I have to do this trick." I also wanted to do the trick so it was like a double motivation to land the trick. Then the next day, we went back and I got the trick and my car back.
V: That's funny.
J: We do a lot of these bets, actually. He was like, "Yo, I never come out with winning. This has got to stop." That's why he got the little duck toy in the part. It gives you electric shock. He was like, "If you don't do it now, you got to push the duck once or twice."
V: Those clips and skits are fun to watch. What about that very first clip from your new part? That frontside wallride where you're saying you're going to do a treflip after that? Was that also a skit?
J: Yeah. That was a skit. Sometimes it just comes up to my head. I just think it's just fun to do it. We laugh about it while we do them. I guess it's just fun. It doesn't always have to make too much sense. Too much thought can get weird.
V: What about for skating? You have unique approach. It seems like you adapt really well to spots.
J: I don't know. I guess if I try to be too prepared, it doesn't really work. I just try to skate and not really think too much.
V: So you said you broke your foot. How is it now?
J: It's better but I'm not really skating yet. It was a pretty fucked injury. I want to take my time to heal really good and then start skating, and not mess it up.
V: Plus with the coronavirus, are you guys staying home and doing the social distancing? What's the situation over there like?
J: I'm living with Rafa. Our situation is pretty good, actually. We go around the block sometimes and we have a garden which is good. And we live next to the ocean, but the beaches are closed. But it's good air. You can go outside. They let you out for an hour a day, so if you want to walk you can. But the cops are pretty strict. I went to the pharmacy and Rafa had his board, and the cop came to us and he was really arrogant. He asked Rafa, "What are you doing with the board?" Rafa was like, "Oh, you can do workout, right? One hour a day, 500 meters from your house." And then he said skateboarding is not a workout or a sport. We were like, "Yo, this is in the Olympics and you know it."
V: What a dick. So what are you guys doing in this downtime?
J: We did a little project. We made boards which we're pretty stoked about. There's Rekiem Skateboards, which is a French company here, and the guy makes boards himself. So we're pretty stoked to be doing that. Just trying to make the best of it.
V: Nice. After your foot heals, and this whole bullshit is cleared up, what's your plan after that?
J: I just want to start skating again and start feeling good on my board. I want to just go for a month on a trip, when I can skate again. Maybe go to the States, if that is possible. Go to San Francisco, skate there, that would be dope. And maybe film Double Impact 2 with Phil.
V: Looking forward to that. Anything you left out?
J: Hey, actually I have one sentence that I came up with. When you asked me how I approach a spot, I want to add this. "I don't approach the spot; the spot approaches me."
V: That's the ender right there (Laughs).
J: Sick man. Ciao.
Jarne Verbruggen
@jarneverbruggen
Born in 1992 in Mechelen, Belgium. Attacking spots with his unique approach to skating, Jarne currently bases himself in France aiming for the next project after the quarantine clears up.
植木鉢直撃事件の裏側も収録
──JARNE VERBRUGGEN - PROFESSIONAL LIFE RAW
植木鉢直撃! アーバンチャンピオンかよ
──JARNE VERBRUGGEN
祝・中毒脱出
──JARNE VERBRUGGEN - WHAT PARADISE? RAW
※閲覧注意! 衝撃の12分
──JARNE VERBRUGGEN - PROFESSIONAL LIFE
NEWCOMER OF THE ///
──FRANKIE SPEARS (ENGLISH)
DESTRUCTION & CREATION
──THOMAS CAMPBELL (ENGLISH)
GREATEST LEGACY IN SKATEBOARDING
──GUY MARIANO (ENGLISH)
BRINGING BACK THE '90s
──JOHN SHANAHAN (ENGLISH)
EAST COAST STYLER
──BUGGY TALLS (ENGLISH)


text:
package com.siyeh.ig.naming;

import com.intellij.psi.PsiClass;
import com.intellij.psi.PsiIdentifier;
import com.intellij.psi.PsiMethod;
import com.siyeh.InspectionGadgetsBundle;
import com.siyeh.ig.BaseInspection;
import com.siyeh.ig.BaseInspectionVisitor;
import com.siyeh.ig.InspectionGadgetsFix;
import com.siyeh.ig.fixes.RenameFix;
import org.jetbrains.annotations.NotNull;

public class MethodNamesDifferOnlyByCaseInspection extends BaseInspection {

    @NotNull
    public String getID() {
        return "MethodNamesDifferingOnlyByCase";
    }

    @NotNull
    public String getDisplayName() {
        return InspectionGadgetsBundle.message(
                "method.names.differ.only.by.case.display.name");
    }

    @NotNull
    public String buildErrorString(Object... infos) {
        return InspectionGadgetsBundle.message(
                "method.names.differ.only.by.case.problem.descriptor",
                infos[0]);
    }

    public BaseInspectionVisitor buildVisitor() {
        return new OverloadedMethodsWithSameNumberOfParametersVisitor();
    }

    protected boolean buildQuickFixesOnlyForOnTheFlyErrors() {
        return true;
    }

    protected InspectionGadgetsFix buildFix(Object... infos) {
        return new RenameFix();
    }

    private static class OverloadedMethodsWithSameNumberOfParametersVisitor
            extends BaseInspectionVisitor {

        @Override public void visitMethod(@NotNull PsiMethod method) {
            if (method.isConstructor()) {
                return;
            }
            final PsiIdentifier nameIdentifier = method.getNameIdentifier();
            if (nameIdentifier == null) {
                return;
            }
            final String methodName = method.getName();
            final PsiClass aClass = method.getContainingClass();
            if (aClass == null) {
                return;
            }
            final PsiMethod[] methods = aClass.getMethods();
            for (PsiMethod testMethod : methods) {
                final String testMethodName = testMethod.getName();
                if (!methodName.equals(testMethodName) &&
                        methodName.equalsIgnoreCase(testMethodName)) {
                    registerError(nameIdentifier, testMethodName);
                }
            }
        }
    }
}

redpajama_set_name: RedPajamaGithub


The Eleventh Circuit vacated the Tax Court's finding that a taxpayer was a bona fide resident of the U.S. Virgin Islands because the facts the Tax Court relied on were insufficient to demonstrate bona fide residency.
In Estate of Sanders, 144 T.C. 63 (2015), the Tax Court, as part of its larger determination that the IRS's notices of deficiency to Travis Sanders for 2002-2004 were time-barred because the statute of limitation on assessment had expired for his U.S. tax returns for those years, found that Sanders was a bona fide resident of the U.S. Virgin Islands in 2002-2004.
In making its decision regarding Sanders's residency, the Tax Court applied the 11 factors set out in Sochurek, 300 F.2d 34 (7th Cir. 1962): (1) intention of the taxpayer; (2) establishment of a home in the foreign country for an indefinite period; (3) participation in activities; (4) physical presence in the foreign country; (5) nature, extent, and reasons for absences from his temporary foreign home; (6) assumption of economic burdens and payment of taxes to the foreign country; (7) status of the resident contrasted to transient or sojourner; (8) treatment accorded his income tax status by his employer; (9) marital status and residence of his family; (10) nature and duration of employment; and (11) good faith in making the trip abroad. The Third Circuit has further grouped these 11 factors into four broad categories: (1) intent; (2) physical presence; (3) social, family, and professional relationships; and (4) the taxpayer's own representations (Vento v. Director of V.I. Bureau of Internal Rev., 715 F.3d 455 (3d Cir. 2013)).
[Sanders] had the intent to be a bona fide resident because he intended to remain indefinitely or at least for a substantial period. . . . He had a physical presence in the USVI and was employed by a USVI business and listed as a partner on their Schedules K-1 for tax years 2002-04. He conducted banking in the USVI and had checks with a USVI address. [Sanders] was married in the USVI and reported his address as the USVI on his marriage license. [Sanders] identified himself as a resident of the USVI and paid USVI taxes. . . . Therefore, [Sanders] was a bona fide resident of the USVI for tax years 2002-04 and he properly filed tax returns with the VIBIR for those years.
The IRS appealed the Tax Court's decision to the Eleventh Circuit, arguing again that under the Sochurek/Vento factors, Sanders was not a bona fide resident of the U.S. Virgin Islands.
The Eleventh Circuit vacated the Tax Court's decision and remanded the case for further consideration of whether Sanders was a bona fide resident of the U.S. Virgin Islands. The court held that in the absence of additional findings of subsidiary fact by the Tax Court, the facts it had relied on were insufficient to demonstrate Sanders's bona fide residency.
In its opinion, the Eleventh Circuit discussed each reason the Tax Court gave to support its finding of bona fide residency and why they failed to provide sufficient support for that determination. First, the court stated it agreed with the Tax Court that Sanders had a physical presence in the U.S. Virgin Islands, and stated that this was an especially important factor. However, it averred that what mattered was not the mere fact of physical presence but its nature and extent. Because the parties disputed how much time Sanders had spent on the island in the years in question, and the Tax Court had not resolved the dispute, it had failed to decide the nature and extent of his presence, and could not have properly weighed this factor.
The Eleventh Circuit explained that the fact that Sanders was employed by a U.S. Virgin Islands business, and was listed as a partner in the business, should be accorded little weight in the residency determination because the Tax Court had failed to make findings of fact regarding Sanders's relationship with the business and whether his relationship to it had economic substance. The IRS argued that Sanders's relationship with the business had no economic substance, and thus his activities with respect to it should not be considered contacts. The Eleventh Circuit agreed that the IRS would be correct if Sanders's relationship with the business had no economic substance, but noted that in some situations a taxpayer's activities related to a business might be considered contacts even if the taxpayer's relationship with that business had no economic substance.
The Eleventh Circuit determined that the fact that Sanders conducted banking in the U.S. Virgin Islands and had checks that listed a U.S. Virgin Islands address supported his claim of bona fide U.S. Virgin Islands residency only to a small extent. The court observed that banking in the U.S. Virgin Islands was not a strong indicator of residency because banking can be conducted almost anywhere using modern technology. It found the checks were not compelling evidence because the address on them was for Sanders's business, not for his place of residence. Likewise, the court determined that Sanders's marriage was "fairly unconvincing" evidence of residence, noting that the location of one's wedding is not necessarily any indication of where one resides. It further pointed out that Sanders's wife lived in Florida after their marriage and never claimed residency in the U.S. Virgin Islands.
The Eleventh Circuit did not give much weight to Sanders's self-identification as a U.S. Virgin Islands resident because he had not done so consistently. In certain instances, as in the case of his marriage license, he listed himself as a resident of the U.S. Virgin Islands, but in many others, including some related to his various business entities, he represented himself as a resident of Florida. The court explained that Sanders's representing himself as a resident of Florida on a number of occasions did not render his representations that he was a U.S. Virgin Islands resident meaningless, given the possibility that a person can have multiple residences, but it did considerably weaken the record evidence with respect to his representations regarding a U.S. Virgin Islands residency.
Finally, the Eleventh Circuit addressed Sanders's payment of U.S. Virgin Islands taxes. The court asserted that this could be an indicator of residency, but, if the IRS was correct in its belief that Sanders merely pretended to be a U.S. Virgin islands resident so he could pay taxes there, it would be expected that he would pay taxes there. The Eleventh Circuit found that, given the IRS's allegations, and substantial supporting evidence that Sanders masqueraded as a U.S. Virgin Islands resident so that he could pay taxes there, it should accord his payment of taxes to the U.S. Virgin Islands little weight in the absence of findings favorable to Sanders on the economic substance issue. The appeals court vacated the Tax Court's decision that Sanders was a bona fide U.S. Virgin Islands resident and remanded the case.
Although the Tax Court did not discuss the issue, the Sanders estate also argued that that if a taxpayer files a tax return with the U.S. Virgin Islands, but not the IRS, in the good-faith belief that he is a U.S. Virgin islands resident, the limitation period should start to run even if the taxpayer is not, in fact, a bona fide resident. The Eleventh Circuit rejected this argument, finding that it was unlikely that Congress had intended that residency status would turn on the taxpayer's subjective beliefs.