text:
Companhia do Metropolitano de São Paulo (CMSP) is a Brazilian mixed economy company, based in São Paulo, which most of its investments belong to the Government of the State of São Paulo. Founded by the Prefecture of São Paulo on 24 April 1968, the company is responsible for the development, project, construction and operation of the metropolitan transport system in the Greater São Paulo, specially the capital metro. Having most of its share control associated to the state government, it's subordinated to the Secretariat of Metropolitan Transports of the State of São Paulo.

The company is member of the National Association of Passenger Carriers on Rails (ANPTrilhos).

Evolution of the share control

See also
 ViaQuatro
 ViaMobilidade

References

External links

Companies based in São Paulo
São Paulo Metro
Railway companies of Brazil
Railway companies established in 1968

redpajama_set_name: RedPajamaWikipedia


I've attempted a Project 52, even tried 30 days of black and white... I got behind, tried to catch up, and then just threw in the towel. Taking pictures isn't the problem, its editing them on a daily basis when two little ones are almost always commanding and demanding my attention. I am not complaining, this is the life I have always wished for... so my new project is to celebrate the everyday and post the pictures as often as I can... no pressure, no timelines. Just make sure that I get lots of pictures and document our family doing the day to day stuff that I want to remember (and make sure that I am included in the pictures as well!). It is also important to remember to print those photos and put them where the kids can enjoy them. So do yourself a favor and try to remember to make sure you are documenting your own life, it is something you will cherish forever.


Map tracks post-election violence in U.S. - collected hundreds of reports in two weeks | No More Stolen Elections!
Ushahidi, a crisis tracking startup based in Nairobi, launched in 2008 after Kenya's disputed presidential elections descended into violence. Since then, the nonprofit has used crowdsourced reports to track and map sexual harassment in Egypt, earthquake relief efforts in Haiti, and the Arab Spring protests across the Middle East. Now, Ushahidi has begun tracking reports of post-election violence in the US, where the election of Donald Trump has incited a wave of racist harassment. And the outlook is pretty bleak.
On Monday, Ushahidi announced that it has mapped more than 300 incidents of "violence, hate speech, and harassment" across the US over the past ten days, including 148 reports of hate speech or threats. The organization receives reports through text messages, Twitter, and email, and works to confirm them with help from researchers at MIT and Harvard, as well as the writer and activist Shaun King. Its tracking software is open sourced, with every instance displayed on a detailed map.
Ushahidi had at first planned to track voter suppression efforts on Election Day, but it shifted its focus to hate crimes and threats in the wake of Trump's victory. Other organizations, including ProPublica and the Southern Poverty Law Center (SPLC), have launched similar efforts. On Monday, the SPLC said it has collected around 700 reports of "hateful incidents" since Election Day, noting that anti-immigrant harassment was the most commonly reported incident, and that nearly 40 percent of all reports occurred in schools or universities. In its blog post, the SPLC noted that there has been a drop-off in reporting as of late, with some 65 percent of all incidents occurring in the three days after the election, but the overall surge in violence and hate is nevertheless terrifying.
It's not exclusive to the US, either; hate crime surged in the UK following this year's Brexit vote in July, and remained high through September. And with far-right, anti-immigrant sentiment on the rise in France, Germany, and the Netherlands — which all hold elections next year — efforts to shed light on the world's darkest corners may be more important than ever.


text:
Tag: Raymond Carver
"Waiting" by Raymond Carver
On October 23, 2015 October 20, 2015 By Christina's WordsIn Poetry4 Comments
Left off the highway and
down the hill. At the
bottom, hang another left.
Keep bearing left. The road
will make a Y. Left again.
There's a creek on the left.
Keep going. Just before
the road ends, there'll be
another road. Take it
and no other. Otherwise,
your life will be ruined
forever. There's a log house
with a shake roof, on the left.
It's not that house. It's
the next house, just over
a rise. The house
where trees are laden with
fruit. Where phlox, forsythia,
and marigold grow. It's
the house where the woman
stands in the doorway
wearing the sun in her hair. The one
who's been waiting
all this time.
The woman who loves you.
The one who can say,
"What's kept you?"
~ "Waiting" by Raymond Carver, from All of Us: The Collected Poems (Alfred A. Knopf).
"No Need" by Raymond Carver
On August 10, 2015 July 6, 2015 By Christina's WordsIn Poetry
I see an empty place at the table.
Whose? Who else's? Who am I kidding?
The boat's waiting. No need for oars
or a wind. I've left the key
in the same place. You know where.
Remember me and all we did together.
Now, hold me tight. That's it. Kiss me
hard on the lips. There. Now
let me go, my dearest. Let me go.
We shall not meet again in this life,
so kiss me goodbye now. Here, kiss me again.
Now, my dearest, let me go.
It's time to be on the way.
from All of Us
"I loved you so much once. I did. (Carver)
On May 5, 2015 April 20, 2015 By Christina's WordsIn Quote1 Comment
"I loved you so much once. I did. More than anything in the whole wide world. Imagine that. What a laugh that is now. We were so intimate once upon a time I can't believe it now. I think that's the strangest thing of all now. The memory of being that intimate with somebody. We were so intimate I could puke. I can't imagine ever being that intimate with somebody else. I haven't been."
– Raymond Carver, Where I'm Calling From
"Gravy" by Raymond Carver
On December 29, 2014 August 26, 2014 By Christina's WordsIn Poetry1 Comment
No other word will do. For that's what it was.
Gravy, these past ten years.
Alive, sober, working, loving, and
being loved by a good woman. Eleven years
ago he was told he had six months to live
at the rate he was going. And he was going
nowhere but down. So he changed his ways
somehow. He quit drinking! And the rest?
After that it was all gravy, every minute
of it, up to and including when he was told about,
well, some things that were breaking down and
building up inside his head. "Don't weep for me,"
he said to his friends. "I'm a lucky man.
I've had ten years longer than I or anyone
expected. Pure Gravy. And don't forget it.
~Raymond Carver
"Fear" by Raymond Carver
On November 24, 2014 November 9, 2014 By Christina's WordsIn Poetry
Fear of seeing a police car pull into the drive.
Fear of falling asleep at night.
Fear of not falling asleep.
Fear of the past rising up.
Fear of the present taking flight.
Fear of the telephone that rings in the dead of night.
Fear of electrical storms.
Fear of the cleaning woman who has a spot on her cheek!
Fear of dogs I've been told won't bite.
Fear of anxiety!
Fear of having to identify the body of a dead friend.
Fear of running out of money.
Fear of having too much, though people will not believe this.
Fear of psychological profiles.
Fear of being late and fear of arriving before anyone else.
Fear of my children's handwriting on envelopes.
Fear they'll die before I do, and I'll feel guilty.
Fear of having to live with my mother in her old age, and mine.
Fear of confusion.
Fear this day will end on an unhappy note.
Fear of waking up to find you gone.
Fear of not loving and fear of not loving enough.
Fear that what I love will prove lethal to those I love.
Fear of death.
Fear of living too long.
I've said that.
"Fear" by Raymond Carver from All of Us, 1996

redpajama_set_name: RedPajamaCommonCrawl


The soundtrack is now a available and features custom tracks to accompany the first issue of Alcheringa. Custom tracks have been created by a variety of talented artists such as Soft Parts, Radio Viral, Michael Dulaney, and Young Hunter. Check out the tracks while you read the official first issue of Alcheringa!


text:
University of georgia concepts
Unit 3. animal structure and
The body's systems
8.2 Digestive system (Page 4/32)
8.2 Digestive system 5
Accessory organs
Review MCQ Questions 3
Critical Thinking Questions 3
Glossary / Key Terms 21
The organs discussed above are the organs of the digestive tract through which food passes. Accessory organs add secretions and enzymes that break down food into nutrients. Accessory organs include the salivary glands, the liver, the pancreas, and the gall bladder. The secretions of the liver, pancreas, and gallbladder are regulated by hormones in response to food consumption.
The liver is the largest internal organ in humans and it plays an important role in digestion of fats and detoxifying blood. The liver produces bile, a digestive juice that is required for the breakdown of fats in the duodenum. The liver also processes the absorbed vitamins and fatty acids and synthesizes many plasma proteins. The gallbladder is a small organ that aids the liver by storing bile and concentrating bile salts.
The pancreas secretes bicarbonate that neutralizes the acidic chyme and a variety of enzymes for the digestion of protein and carbohydrates.
Art connection
The stomach has an extremely acidic environment where most of the protein gets digested. (credit: modification of work by Mariana Ruiz Villareal)
Which of the following statements about the digestive system is false?
Chyme is a mixture of food and digestive juices that is produced in the stomach.
Food enters the large intestine before the small intestine.
In the small intestine, chyme mixes with bile, which emulsifies fats.
The stomach is separated from the small intestine by the pyloric sphincter.
The human diet should be well balanced to provide nutrients required for bodily function and the minerals and vitamins required for maintaining structure and regulation necessary for good health and reproductive capability ( [link] ).
For humans, a balanced diet includes fruits, vegetables, grains, protein, and dairy. (credit: USDA)
Concept in action
Explore this interactive United States Department of Agriculture website to learn more about each food group and the recommended daily amounts.
The organic molecules required for building cellular material and tissues must come from food. During digestion, digestible carbohydrates are ultimately broken down into glucose and used to provide energy within the cells of the body. Complex carbohydrates, including polysaccharides, can be broken down into glucose through biochemical modification; however, humans do not produce the enzyme necessary to digest cellulose (fiber). The intestinal flora in the human gut are able to extract some nutrition from these plant fibers. These plant fibers are known as dietary fiber and are an important component of the diet. The excess sugars in the body are converted into glycogen and stored for later use in the liver and muscle tissue. Glycogen stores are used to fuel prolonged exertions, such as long-distance running, and to provide energy during food shortage. Fats are stored under the skin of mammals for insulation and energy reserves.
Proteins in food are broken down during digestion and the resulting amino acids are absorbed. All of the proteins in the body must be formed from these amino-acid constituents; no proteins are obtained directly from food.
Practice MCQ 3 FlashCards 3 Key Terms 21
Circulatory and respiratory systems Online Chapter
Homeostasis and osmoregulation Online Chapter
University of georgia concepts Online Course
Source: OpenStax, University of georgia concepts of biology. OpenStax CNX. May 28, 2013 Download for free at https://legacy.cnx.org/content/col11526/1.2
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English Composition 2 Final Practice
5 AP 05 Integumentary System Essay
19 AP 18 Cardiovascular System Blood Essay
Human A&P 2- Final
15 AP 15 Autonomic Nervous System Essay
©flickr: Abraham
2 Biology 2
By Sarah Warren
5 AP Key Terms 05 The Integumentary System
Start Key Terms
Biology Chapter 9
By Michael Sag
32 Biology 32 Plant Reproduction MCQ
7 BOD Urinary Tract quiz


We are happy to announce that MIVAL Jr. has received its first grant for $810 from Mercer Island Community Fund (MICF).
The grant for MIVAL Jr. is to encourage and enable art exhibition opportunities, foster mentorship and develop a community network of young artists; also to provide visual arts demonstrations and educational experiences.
The benefit of the grant will ensure youth engagement in three planned visual arts projects. The first project is the art exhibition at Covenant Shores Lighthouse Gallery, April 30 to June 3 for youth, sixth grade to 12th grade. The second is the MIVAL Jr. Art Show, a juried show during July's Summer Celebration at the Wells Fargo Bank. This attracts youth from K through 12th grade to show their talent and meet other artists. The last project is MIVAL Jr.'s Holiday workshop in December; a family fun, hands-on art event, that educates and engages children in the community.
All the events are organized and managed by volunteers from MIHS high school students, MIVAL member artists and community members. We believe this continues to strengthen community's knowledge about the value of visual arts in our everyday lives. Thank you MICF for your support in funding MIVAL Jr.


Registration is now open. Participants can pick up their registration materials at the onsite registration desk. MAA does not mail registration materials. Note: If registering online anytime after July 19, 2019, then badges will have to be printed on site and may not be immediately available for collection at the front desk. Please consult the registration staff for guidance.


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text:
Q: What is the probability that $^{\text{n}}\text{C}_{7}$ is divisible by $12$?
What is the probability that $^{\text{n}}\text{C}_{7}$ is divisible by $12$? Where $n$ can be take the values of all the natural numbers.

The number should be divisible by both $3$ and $4$ for this purpose. What I could do is individually find out which were divisible by 3 and which by 4 but wasn't able to find out the disjoint of those sets.
This was on my test, and the solution given is this, which I don't get a thing of:

A: Look that $\binom{n}{7}=\frac{n!}{7!(n-7)!}$, and $12^2||7!$, so you need to look for an $n$ such that $\frac{n!}{(n-7)!}$ is at least a multiple of $12^3$, and it is easy to see that it occurs for $n\geq 12$. Now as the possible range for $n$ is $7\leq n \leq \infty$, so the numbers which do not satisfy $n$ are $7,8,9,10,11$. So as pointed out by Servaes, the probablity is equal to $0,1$ depending on the value of $n$

redpajama_set_name: RedPajamaStackExchange


text:
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cumulolimbo studio produces architecture, research and urban actions.
The relational field that emerged in the City of Paris during May '68 [#M68] was made of a dynamic myriad of invisible bonds and spatial layers of communication and empathy. The complexity of this emotional environment translated into physical, urban space through the act of taking to the streets and appropriating urban furniture, building barricades, and, most fundamentally, through the constant ap- pearance of written testimonies on the walls of Paris in the form of grafitti, spontaneous slogans or urban calligrams. Streets gave up their predominant role as transit sites in order to become dissident spaces of discussion, appropriation, transformation and debate. Normative, Euclidean space was imbued with countless layers of affectivity, social conflict, use, activity, energy, as well as the expansion of bodies in space. Because these intangible layers transform space, they interfere with the spatial response that may be provided by any architectural project. Thus, dealing with such subjective spaces within an urban environment entails the challenge of creating new unveiling devices that can unmask the interactions between emotional and physical bodies. Arguably, through the act of unmasking and revealing relational space, these could provide an insightful approach to the possibilities of the invisible in the field of contemporary architecture and urban space.


We're honored to have you join us by giving any amount today. Every gift counts!
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text:
147 T.C.
147 T.C. 179 (2016)
WEISS v. COMMISSIONER
Docket No. 13643-11L.
147 T.C. No. 6
CHARLES J. WEISS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
United States Tax Court.https://leagle.com/images/logo.png
Filed August 17, 2016.
Daniel J. Pilla , for petitioner.
Jonathan E. Behrens , for respondent.
LAUBER, Judge.
In this collection due process (CDP) case petitioner seeks review, pursuant to section 6330(d)(1),1 of the determination by the Internal Revenue Service (IRS or respondent) to uphold a notice of intent to levy. The IRS served the levy notice on petitioner in an effort to collect his unpaid Federal income tax liabilities for 1986, 1987, 1988, 1989, 1990, and 1991, which exceeded $550,000 in the aggregate. Petitioner contends that the period of limitations on collection of these liabilities expired in July 2009. He bases this contention on the assertion that he intentionally filed his request for a CDP hearing one day late, such that he was entitled only to an "equivalent hearing" rather than to the CDP hearing that the IRS afforded him. If petitioner's contentions are correct, the collection period of limitations would not have been suspended during the CDP process, and his tax liabilities in that event would appear to be uncollectible.
Respondent contends that petitioner's request for a CDP hearing was in fact timely because it was filed within 30 days of the date on which the IRS mailed him the notice of levy. See sec. 6330(a)(3)(B). Respondent acknowledges that the date appearing on the levy notice was at least two days earlier than the mailing date but argues that the mailing date dictates the start of the 30-day period where (as here) it is the later of the two dates. Cf. Bongam v. Commissioner, 146 T.C. 52, 58-59 (2016). On this point we agree with respondent. Because petitioner has raised no other meaningful challenge to the settlement officer's determination, we will sustain the proposed collection action.
Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated by this reference. Petitioner resided in Pennsylvania when he filed his petition.
In 1994 petitioner filed delinquent returns for 1986-1991. In October 1994 the IRS assessed the tax liabilities shown on those returns along with additions to tax under sections 6651(a)(1), 6651(a)(2), and 6654. Between 1994 and 2009 petitioner filed for bankruptcy three times; these filings served to suspend the 10-year period of limitations on collection set forth in section 6502(a)(1).2 After factoring in the suspensions for these bankruptcies, the collection period of limitations for the tax years at issue was set to expire in July 2009.
With a view to collecting petitioner's outstanding liabilities, the IRS assigned a Revenue Officer (RO) to his case. The RO prepared a Letter 1058A, Final Notice of Intent to Levy and Notice of Your Right to a Hearing. The RO generated this levy notice using the IRS Integrated Collection System (ICS), which affixed February 11, 2009, as the date on the letter. The RO appended to the levy notice copies of IRS Publication 1, Your Rights as a Taxpayer; Publication 1660, Collection Appeal Rights; Publication 594, What You Should Know About the IRS Collection Process; and Form 12153, Request for a Collection Due Process or Equivalent Hearing. The RO concurrently generated a separate Letter 1058A, concerning a joint income tax liability for 2001, that was addressed to petitioner's wife, Betty Hockenbury.
The RO made a "field call" later that day in an effort to hand-deliver the two levy notices to petitioner's residence. He was deterred by a dog blocking the driveway; he left without delivering either notice, opting to send them by certified mail instead. The RO completed his other field calls that afternoon and went home without returning to his office.
On February 12 the RO conferred with an IRS colleague to ascertain whether a criminal investigation should be opened against petitioner. His colleague got back to him at the end of the day with a negative answer. On February 13 the RO prepared an envelope in which the levy notice for 1986-1991 was to be sent by certified mail to petitioner's last known address. The RO did not generate a new levy notice dated February 13; he simply enclosed in the envelope the original levy notice dated February 11, together with the Form 12153 and the three IRS publications listed above. He attached to the envelope U.S. Postal Service (USPS) Form 3800, Certified Mail Receipt, and USPS Form 3811, Certified Mail Return Receipt. On the Form 3800 he made the notation "L1058," standing for Letter 1058, and indicated that it was being "sent to Charles Weiss." That same morning the RO prepared a similar levy notice concerning the 2001 joint tax liability addressed to petitioner's wife.
On February 13 the RO placed the envelopes containing the two levy notices, with USPS certified mail slips attached, in the outgoing mail bin at his office. He credibly testified that the office's standard operating procedure was to have outgoing mail picked up from that bin by support staff two or three times a day. The support staff would meter all outgoing mail and put it into a postal box outside the IRS office, to be picked up by USPS personnel. Because outgoing mail was stamped using a private postage meter, it did not receive a USPS postmark.
The date of the imprint of the private postage meter on the envelope in which each notice was mailed was February 13, 2009. After placing the two levy notices in the outgoing mail bin, the RO updated the Integrated Data Retrieval System (IDRS) through ICS to indicate that the levy notices had been mailed to petitioner and to his wife on Friday, February 13, 2009.3 The IRS office in which the RO worked was closed the next three days for the weekend and for Presidents' Day. The U.S. Post Office to which mail from that IRS office was taken was open on February 14, but was closed on February 15 and 16.
On February 17 petitioner's wife signed the USPS Form 3811 for each levy notice. Her signatures on these forms establish that the two levy notices were delivered to her, and that she received them, on that day. The certified mail numbers on the Forms 3811 that she signed match the certified mail numbers on the Forms 3800 that the RO completed. The RO subsequently made an updated IDRS entry confirming that he had "received return receipts back date stamped by Post Office on 2/17/2009 for Charles Weiss & Betty Hockenb[u]ry"; that "both return receipts are signed by B. Hockenb[u]ry"; and that the taxpayers had "accepted delivery" of the levy notices.
Petitioner's wife opened the envelopes, took out the enclosed documents, set them aside for her husband, and threw away the envelopes. When petitioner came home from work that day, he reviewed the levy notices and the IRS publications. By reading the publications, petitioner, who is an attorney, became aware of the collection actions available to the IRS and of the alternatives potentially available to him. He understood the difference between a CDP hearing, which would entitle him to judicial review if he were dissatisfied, and an "equivalent hearing," in which any collection relief would be solely at the IRS' discretion. Petitioner did not have the ability in February 2009 to pay his Federal tax liabilities, which then exceeded $550,000. He understood that enforced IRS collection action would cause serious financial hardship and make it impossible for him and his wife to maintain their standard of living.
In response to the two levy notices petitioner prepared two Forms 12153, Request for Collection Due Process or Equivalent Hearing. One Form 12153 requested a hearing with respect to petitioner's 1986, 1987, 1988, 1999, 2000, and 2001 tax years (1986 CDP Form). Petitioner was in a hurry to file the 1986 CDP Form and completed it at "the last minute"; he inadvertently listed tax years 1999-2001 instead of 1989-1991, the years actually covered by the levy notice.4 As his basis for requesting a CDP hearing he stated that he "can't pay the tax owed" and that "levy action will cause hardship." He did not check the box captioned "Equivalent Hearing." He dated this form March 13, 2009.
The other Form 12153 requested a hearing with respect to the 2001 joint tax liability of petitioner and his wife (2001 CDP Form). As the basis for requesting a CDP hearing he stated that he and his wife "can't pay the tax owed" and that "levy action will cause hardship." He did not check the box captioned "Equivalent Hearing." He dated this form March 13, 2009.
Petitioner mailed one Form 12153 in an envelope postmarked March 13, 2009, and he mailed the other Form 12153 in an envelope postmarked March 14, 2009. The IRS received both Forms 12153 on Monday, March 16, 2009. After the envelopes were opened, the forms became separated from their envelopes. In the absence of any identifying markings on the envelopes, the IRS was unable to determine which envelope had contained the 1986 CDP Form and which envelope had contained the 2001 CDP Form.
On April 13, 2009, the RO sent petitioner a letter noting that he had neglected to list tax years 1989-1991 on the 1986 CDP Form. Two weeks later, the SO received from petitioner a revised Form 12153, dated April 23, 2009, that listed the six years that were actually at issue. Petitioner on this revised form did not check the box captioned "Equivalent Hearing." He again stated as his basis for requesting a CDP hearing that he "can't pay the tax owed" and that "levy action will cause hardship."
A settlement officer (SO) was assigned to petitioner's case. The SO reviewed his tax transcripts for 1986-1991. She properly verified that: (1) the assessments for each year were properly made; (2) there was a balance due for each year; and (3) the tax bill for each year was mailed to petitioner's last known address within 60 days of each assessment.
The SO also verified that the statute of limitations did not bar collection of petitioner's 1986-1991 liabilities. The end of the 10-year period specified in section 6502(a)(1) had passed in July 2009. However, section 6330(e)(1) provides: "[I]f a hearing is requested under subsection (a)(3)(B), * * * the running of any period of limitations under section 6502 (relating to collection after assessment) * * * shall be suspended for the period during which such hearing, and appeals therein, are pending."
The SO determined that the collection period of limitations remained open because petitioner had timely requested a CDP hearing. In making this determination, the SO concluded that the critical date was not February 11, 2009, the date appearing on the levy notice, but the date on which that notice was actually mailed to petitioner. She examined the ICS history transcript maintained by the RO, which showed February 13, 2009, as the mailing date. She also examined the USPS forms in the administrative file. She concluded that the Form 3800 (completed by the RO on February 13) and the Form 3811 (signed by petitioner's wife on February 17) likewise pointed to February 13 as the mailing date, given that the IRS office was closed on the intervening three days. Although it was uncertain whether petitioner had mailed the 1986 CDP Form on March 13 or 14, the SO found it timely in either event because both dates were within 30 days of February 13.
On November 25, 2009, the SO sent petitioner a letter informing him that his CDP hearing request for 1986-1991 had been received and was timely. She indicated that she had scheduled a telephone CDP hearing for January 22, 2010, and enclosed the forms petitioner would need to complete in order to seek a collection alternative. Petitioner communicated with the SO, by letter or telephone, three times during December 2009. On none of these occasions did he disavow his desire for a CDP hearing or assert that he wanted only an "equivalent hearing."
Petitioner retained Daniel Pilla, his current counsel, on January 15, 2010. During the CDP hearing one week later Mr. Pilla contended that petitioner's CDP hearing request was untimely because the date appearing on the levy notice, February 11, 2009, controlled in determining whether petitioner had filed his request within the 30-day period specified in section 6330(a)(3)(B). The SO disagreed and stated that she considered both Forms 12153 to have been filed timely because the 30-day period was calculated from the mailing date. Petitioner during the CDP hearing did not challenge the dollar amount of his underlying tax liabilities or seek a collection alternative. Apart from claiming that the collection period of limitations for 1986-1991 had expired, he did not dispute the appropriateness of the proposed levy.5
The SO sought from IRS Chief Counsel a legal opinion concerning the timeliness issue. In December 2010 she received an opinion concluding that "the 30-day period for filing a CDP hearing request runs from the date the CDP notices were mailed." The SO telephoned Mr. Pilla to inform him of the IRS' position and asked whether petitioner sought a collection alternative. Mr. Pilla said he would give her an answer by April 29, 2011. On May 6, 2011, having received no further communication from petitioner or his counsel, the IRS sent petitioner a notice of determination sustaining the levy to collect his unpaid tax liabilities for 1986-1991. Petitioner timely petitioned this Court for review.
Section 6330(d)(1) does not prescribe the standard of review that this Court shall apply in reviewing an IRS administrative determination in a CDP case. The general parameters for such review are marked out by our precedents. We generally review the Appeals officer's determination as to the propriety of particular collection action for abuse of discretion. Wadleigh v. Commissioner, 134 T.C. 280, 288 (2010); Sego v. Commissioner, 114 T.C. 604, 610 (2000). However, where the validity of the underlying tax liability is properly at issue, we will review the matter de novo. We apply de novo review where the taxpayer did not receive a notice of deficiency or did not otherwise have an opportunity to challenge the tax assessed against him. See Wadleigh, 134 T.C. at 288; Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).
There is some uncertainty in our precedents as to whether a de novo standard of review applies where (as here) the controversy concerns a challenge to the 10-year collection period of limitations.6 Petitioner argues that his tax liability is uncollectible because the period of limitations on collection has expired. If that is so, respondent's proposed collection action would be impermissible under an abuse of discretion standard as well as under a de novo standard. Because we must decide whether the SO correctly determined that the limitations period had not expired, we would reach the same result regardless of which standard we applied. Cf. Kendricks v. Commissioner, 124 T.C. 69, 75 (2005) (explaining that, whether reviewing for abuse of discretion or de novo, we must reject an erroneous view of the law). We base our resolution of all factual issues upon a preponderance of the evidence, so that assignment of the burden of proof is unnecessary. See, e.g., McLaine v. Commissioner, 138 T.C. 228 (2005); cf. sec. 7491(a).
A. Governing Statutory Framework
Sections 6320 (pertaining to tax liens) and 6330 (pertaining to levies) establish procedures for administrative and judicial review of IRS collection action. The Commissioner must provide the taxpayer with written notice of lien filing or proposed levy action and inform the taxpayer of his right to an administrative hearing. See Davis v. Commissioner, 115 T.C. 35, 37 (2000). Such written notice must be furnished in one of three ways: it must be "given in person," be "left at the * * * [taxpayer's] dwelling or usual place of business," or be "sent by certified or registered mail * * * [to the taxpayer's] last known address." Secs. 6320(a)(2)(A)-(C), 6330(a)(2)(A)-(C).
A levy notice must be sent or delivered to the taxpayer "not less than 30 days before the day of the first levy." Sec. 6330(a)(2). This notice must inform the taxpayer in simple and nontechnical terms of his right "to request a hearing during the 30-day period" specified in section 6330(a)(2). See sec. 6330(a)(3)(B). "If the person requests a hearing in writing under subsection (a)(3)(B) and states the grounds for the requested hearing, such hearing shall be held" by the IRS Appeals Office. Sec. 6330(b)(1).
"[I]f a hearing is requested under subsection (a)(3)(B), the levy actions which are the subject of the requested hearing and the running of any period of limitations under section 6502 (relating to collection after assessment) * * * shall be suspended for the period during which such hearing, and appeals therein, are pending." Sec. 6330(e)(1). Following the hearing, the settlement officer issues a notice of determination sustaining or declining to sustain the proposed collection action. If the taxpayer disagrees with that determination, he may petition for judicial review "and the Tax Court shall have jurisdiction with respect to such matter." Sec. 6330(d).7
"A taxpayer who fails to make a timely request for a CDP hearing is not entitled to a CDP hearing," but he may be afforded an "equivalent hearing." Sec. 301.6330-1(i)(1), Proced. & Admin. Regs. Any relief afforded in an equivalent hearing is discretionary with the IRS; the "decision letter" issued after such a hearing is not subject to judicial review. Id. para. (i)(2), Q&A-16. The collection period of limitations is not suspended during an equivalent hearing, and the IRS may thus proceed to collect the taxpayer's liabilities. Id. Q&A-13; see McGowan v. Commissioner, T.C. Memo. 2008-125.
B. Commencement of the 30-Day Period
The focus of the parties' dispute is whether petitioner filed the 1986 CDP Form within the 30-day period specified in section 6330(a)(3)(B).8 Petitioner sent his hearing request to the IRS by certified mail on either March 13 or March 14, 2009. Under the "timely mailing, timely filing" rule of section 7502, petitioner is deemed to have filed his request on the date he mailed it. Moreover, because March 14 was a Saturday and March 15 was a Sunday, the 30-day window was extended until Monday, March 16, 2009, and the IRS received petitioner's 1986 CDP Form on that date. See sec. 7503. The central question, therefore, is whether March 14 was within 30 days of the levy notice. If it was, the running of the collection period of limitations was suspended and continues to be suspended until 90 days after the decision in this case has become final. See sec. 6330(e)(1); sec. 301.6330-1(g)(3), Example (1), Proced. & Admin. Regs.
We have stated on several occasions that "the 30-day period in which a taxpayer may timely request an Appeals Office hearing begins on the day after the date of mailing" of a levy notice under section 6330(a). Newsome v. Commissioner, T.C. Memo. 2007-111, 93 T.C.M. (CCH) 1193, 1194; Lopez v. Commissioner, T.C. Memo. 2001-228, 82 T.C.M. (CCH) 469, 470 ("[T]he taxpayer has 30 days from the mailing of * * * [the levy] notice to request a CDP hearing."); see also Andre v. Commissioner, 127 T.C. 68, 71 (2006). However, we have not previously addressed a situation where the date appearing on a levy notice does not match the mailing date. Respondent contends that the mailing date controls in this scenario. Petitioner contends — contrary to the position a taxpayer would normally take — that the 30-day window for requesting a hearing under section 6330(a)(3)(B) commenced on February 11, 2009, the date appearing on the IRS letter. He asserts that he mailed the 1986 CDP Form on March 14, 2009 — i.e., 31 days later — and that his request for a hearing was therefore untimely.
Although we have found no precedent that addresses the precise question involved here, a modest body of case law has developed on closely analogous questions. When considering the timeliness of notices of deficiency under section 6213, we have encountered situations where the date on the notice did not match the date on which the notice was successfully mailed to the taxpayer. Where the date on the notice was earlier than the date of mailing, we have held that "[t]he critical date is the date the deficiency notice was `mailed.'" August v. Commissioner, 54 T.C. 1535, 1536 (1970); see, e.g., Lundy v. Commissioner, T.C. Memo. 1997-14, 73 T.C.M. (CCH) 1693, 1695 (ruling that the date of mailing is generally "the date that the Commissioner actually places the notice of deficiency in the mail"); United Tel. Co. v. Commissioner, 1 B.T.A. 450 (1925). By contrast, when the date appearing on the notice of deficiency is later than the date of mailing, we have held that the former date controls. See Loyd v. Commissioner, T.C. Memo. 1984-172, 47 T.C.M. (CCH) 1450, 1453-1454; Jones v. Commissioner, T.C. Memo. 1984-171, 47 T.C.M. (CCH) 1444.
We recently applied the same line of reasoning in the CDP context. See Bongam v. Commissioner, 146 T.C. at 55-56. That case involved a different 30-day period in the CDP regime, namely, the requirement in section 6330(d)(1) that the taxpayer petition this Court within 30 days of the IRS notice of determination. We held that the mailing date of the IRS notice controlled when it was later than the date appearing on the letter.
In Bongam the IRS mailed a notice of determination to an address that was not the taxpayer's last known address. That notice was returned to the IRS as undeliverable. Several months later, on August 4, 2014, the IRS remailed the notice, without changing the original date, to the taxpayer's last known address by regular mail. The taxpayer received the notice at that address and petitioned this Court within 18 days of the mailing date.
Relying on the deficiency cases cited above, we held in Bongam that, "when the date appearing on a deficiency notice is earlier than the date of mailing, `[t]he critical date is the date the deficiency notice was "mailed."'" 146 T.C. at 58 (quoting August, 54 T.C. at 1536). As we explained:
We see no reason why the above-described rules governing our deficiency jurisdiction should not also govern our jurisdiction in CDP cases, thus allowing taxpayers the greatest opportunity, consistently with the statutory language, to obtain jurisdiction in our Court. We accordingly hold that the 30-day window prescribed by section 6330(d)(1) is calculated by reference to the Notice of Determination that was successfully sent to petitioner[ ] * * * on August 4, 2014. Because petitioner actually received that Notice and filed his petition within 30 days, we have jurisdiction to hear this case. [Id. at 59.]
This logic is equally applicable here. We will employ the same principle of construction to IRS notices issued under section 6330(a) that we have applied to IRS notices issued under section 6330(d). When the date appearing on a levy notice is earlier than the date of mailing, the 30-day window prescribed by section 6330(a)(2) and (3)(B) is calculated by reference to the date of mailing.
In so ruling, we are guided by the proposition that, in determining whether we have jurisdiction over a given matter, this Court and the Courts of Appeals have given our jurisdictional provisions a broad, practical construction rather than a narrow, technical one. See Lewy v. Commissioner, 68 T.C. 779, 781 (1977). Acceptance of petitioner's submission would disserve the interests of most tax-payers by converting the CDP hearing, in the scenario presented here, into an "equivalent hearing" immune from judicial review. When a statutory provision is capable of two interpretations, "we are inclined to adopt a construction which will permit us to retain jurisdiction without doing violence to the statutory language." Traxler v. Commissioner, 61 T.C. 97, 100 (1973).9
Petitioner errs in contending that the regulations point to a different conclusion. They provide that a CDP hearing must be requested within the 30-day period commencing "the day after the date of the CDP Notice." Sec. 301.6330-1(b)(1), Proced. & Admin. Regs.; see id. para. (c)(1) (hearing must be requested within 30 days after "the date of the CDP Notice"). Notably, these provisions refer, not to the date on the CDP Notice, but to the date of the CDP Notice. The examples to the regulations indicate that "the date of the CDP Notice" is the date on which that notice is mailed. See id. subpara. (3), Example (1) (concluding that the 30-day period begins to run the day after "[t]he IRS mails a CDP Notice of intent to levy to * * * [the taxpayer's] last known address").10
C. Determination of the Mailing Date
In deciding whether the SO erred in sustaining the proposed levy, the relevant question is whether she properly concluded that the 10-year period of limitations remained open. The answer to this question depends on whether the 1986 CDP Form was mailed by petitioner and/or received by respondent within 30 days of the date on which the IRS mailed the levy notice.
Generally speaking, we have approved a settlement officer's reliance on tax transcripts to prove relevant facts. See, e.g., Tornichio v. Commissioner, T.C. Memo. 2002-291; Schroeder v. Commissioner, T.C. Memo. 2002-190. Here, the SO reviewed petitioner's tax transcripts and determined that the levy notice for 1986-1991 was mailed to petitioner's last known address on February 13, 2009. We have held that a settlement officer may not rely solely on computerized tax transcripts where the taxpayer demonstrates "an irregularity in the assessment procedure." See Jordan v. Commissioner, T.C. Memo. 2011-243, 102 T.C.M. (CCH) 386, 387. Petitioner argues that he has identified "an irregularity in the assessment procedure" because the date on the levy notice does not match its mailing date. Assuming arguendo that petitioner is correct, the SO was required to do more than check his tax transcripts.
The SO did more than check the tax transcripts. She verified the mailing date shown on the transcripts by consulting the ICS history transcript maintained by the RO, which showed that the Letter 1058 was mailed on February 13. She reviewed the Form 3800 that the RO completed on February 13; the certified mail number on that form matched the certified mail number on the Form 3811 that petitioner's wife signed on February 17. The SO reasonably concluded that the Form 3811 bolstered her determination that the levy notice had been mailed on February 13, because the IRS office was closed on the intervening three days.11
The evidence at trial supported the SO's determination. The testimonial and documentary evidence established that the RO left the levy notice in the outgoing mail bin on February 13; that an IRS staff person collected the notice from the mail bin and ran it through a private postage meter, which imprinted February 13 as the date; and that IRS staff placed the notice into a postal box outside the IRS office for collection by USPS personnel later that afternoon.
While it seems plausible that USPS personnel collected the notice from the IRS postal box on February 13, the evidence does not conclusively establish that they deposited it into the U.S. mail that same day. But it is immaterial to our conclusion whether the notice was actually mailed on February 13 or February 14. The SO correctly determined that February 13 was the earliest date on which the levy notice could have been mailed. That date was within 30 days of March 14, the date on which petitioner testified that he mailed the 1986 CDP Form. See sec. 7502. Moreover, because March 14 was a Saturday and March 15 was a Sunday, the 30-day window was extended until Monday, March 16, 2009, the date on which the IRS received petitioner's 1986 CDP Form. See sec. 7503. Thus, regardless of whether the levy notice was mailed on February 13 or February 14, petitioner's 1986 CDP Form was timely filed under section 6330(a)(3)(B) by reference both to the date of its mailing and to the date of its receipt.
Petitioner cites cases like Galluzzo v. Commissioner, 564 F. App'x 656 (3d Cir. 2014), and Pietanza v. Commissioner, 92 T.C. 729 (1989), for the proposition that the IRS must establish the exact date on which a notice of this sort was mailed. That is certainly true where (as in those cases) acceptance of one of the possible mailing dates as the actual mailing date would lead to the conclusion that the notice was untimely. In this case, by contrast, both possible mailing dates for the levy notice lead to the conclusion that petitioner's 1986 CDP Form was timely filed. Ascertaining the notice's exact mailing date is unnecessary here because it would not affect the outcome.12
D. Petitioner's Other Arguments
Petitioner contends that the levy notice was fatally defective because it violated what he calls "the `information' requirement" of section 6330(a)(3). That section provides that a levy notice shall furnish certain information to the taxpayer "in simple and nontechnical terms," including "the right of the person to request a hearing during the 30-day period under paragraph (2)." Petitioner acknowledges that the levy notice informed him of his right to request a hearing within 30 days. But he says that this information was not communicated "in simple and nontechnical terms" because the 30-day period did not run from February 11, the date on the levy notice, but from the subsequent mailing date.
This argument faces several hurdles at the threshold. First, petitioner cites no authority for the proposition that Congress envisioned a sanction for the failure of an IRS notice to be drafted "in simple and nontechnical terms." Second, petitioner cites no authority for the proposition that section 6330(c)(1), which obligates the settlement officer to "obtain verification from the Secretary that the requirements of any applicable law or administrative procedure have been met," includes the obligation to verify that IRS communications have been drafted "in simple and nontechnical terms." Third, if we were to assume that a settlement officer must verify this (or that it is part of a challenge to the existence of the underlying liability), petitioner cites no authority for the proposition that the failure to employ "simple and nontechnical terms" in a levy notice would require invalidating the collection action where the failure does not prejudice the taxpayer's ability to secure a CDP hearing.
In any event, we have frequently upheld the validity of IRS notices even though there was a mismatch between the letter date and the mailing date. In Bongam, 146 T.C. at 58, the date appearing on the notice of determination was earlier than the mailing date, as it was here. Our conclusion as to the notice's validity was "unaffected by the fact that the date appearing on the Notice of Determination does not match the date on which the Notice was successfully mailed to petitioner." Going back many years, we have reached the same conclusion regarding notices of deficiency, and we have done so regardless of whether the taxpayer was aware of the actual mailing date. See S. Cal. Loan Ass'n v. Commissioner, 4 B.T.A. 223 (1926); United Tel. Co., 1 B.T.A. 450; Hurst, Anthony & Watkins v. Commissioner, 1 B.T.A. 26 (1924). Although a notice of deficiency, like a notice of levy, "refers taxpayers to the date appearing at the top of the notice," it is "settled law that the date appearing on the notice of deficiency is not the date of mailing (although the dates may coincide)." Traxler, 61 T.C. at 99. The directive that levy and lien notices should be drafted "in simple and nontechnical terms" does not justify a different outcome here.13
In a related vein, petitioner argues that the SO failed the verification requirement by paying insufficient heed to a section of the Internal Revenue Manual (IRM) cautioning that a levy notice should bear the same date as that on which it is mailed to the taxpayer. See IRM pt. 5.11.1.2.2.2(4) (Mar. 21, 2008). The IRM lacks the force of law and does not create rights for taxpayers. Anonymous v. Commissioner, 145 T.C. 246, 257 (2015). Petitioner cites no case in which a settlement officer was found to have abused her discretion regarding verification by failing to follow an IRM provision. Cf. Wadleigh, 134 T.C. at 294 n.13 (declining to decide "whether the procedures described in the IRM are administrative procedures that come within the verification requirement of sec. 6330(c)(1)"). As explained above, we have often upheld the validity of IRS notices where the letter date did not match the mailing date.
Finally, petitioner contends that "equitable estoppel applies to bar respondent from * * * relying on a mail date of the notice other than February 11, 2009." Petitioner asserts that the IRS misled him "by misrepresentation or concealment" as to the existence of a fact — namely, the date on which the levy notice was mailed — and that he "suffered prejudice as a result." His claim of prejudice is based on the notion that, while he requested a CDP hearing, what he really wanted was an "equivalent hearing" that would not suspend the period of limitations on collection. Rather than check the "Equivalent Hearing" box on the 1986 CDP Form, petitioner asserts that he aimed to achieve this goal by intentionally filing his CDP request one day late, using the February 11 date appearing on the levy notice as his starting point. He was prejudiced, he says, when his scheme was frustrated by the SO's conclusion that he was entitled to the CDP hearing he had asked for because commencement of the 30-day period was calculated by reference to the notice's mailing date.
Petitioner's estoppel argument is unpersuasive. See Hofstetter v. Commissioner, 98 T.C. 695, 700 (1992) ("Estoppel is applied against the Commissioner `with utmost caution and restraint.'" (quoting Estate of Emerson v. Commissioner, 67 T.C. 612, 617 (1977))). The IRS did not "misrepresent or conceal" any fact. The date on the levy notice and the date imprinted on the envelope were visible for all to see. If petitioner had not thrown away the envelope, the mismatch would have been apparent to him.
Petitioner's testimony concerning prejudice, moreover, was wholly lacking in credibility. In February 2009 he could not pay his 1986-1991 Federal tax liabilities, which exceeded $550,000. He averred on the 1986 CDP Form that he "can't pay the tax owed" and that "levy action will cause hardship." Petitioner is an attorney; he studied the IRS publications he received; and he understood the difference between a CDP hearing and an "equivalent hearing." His testimony that he actually sought an "equivalent hearing" was implausible for at least four reasons: (1) he did not check the box for "Equivalent Hearing" despite two opportunities to do so; (2) the IRS during the pendency of an "equivalent hearing" could begin immediate collection action, which was the last thing petitioner wanted; (3) any relief afforded by the IRS in an "equivalent hearing" would be purely discretionary and not subject to judicial review; and (4) the CDP hearing that he requested would entitle him to judicial review and defer IRS collection action indefinitely, thus achieving the goals he expressed in his hearing request. For all these reasons, we find no credible evidence to support his claim of prejudice.
In consideration of the foregoing,
An appropriate decision will be entered.
1. All statutory references are to the Internal Revenue Code in effect at all relevant times. We round all dollar amounts to the nearest dollar.
2. The U.S. Bankruptcy Court for the Eastern District of Pennsylvania held that petitioner had attempted to evade or defeat his income tax liabilities for the 1988-1991 tax years. United States v. Weiss (In re Weiss), 237 B.R. 600, 606 (Bankr. E.D. Pa. 1999). That determination was affirmed on appeal with respect to all six years at issue. United States v. Weiss, 2000 U.S. Dist. LEXIS 16523, at *13-*14 (E.D. Pa. Nov. 15, 2000), aff'd, 276 F.3d 582 (3d Cir. 2001).
3. The RO's entry for February 13 reads as follows: "RO Sent L1058 certified with Pub 594, Pub 1660 & Pub 1 Copy to Charles Weiss and Betty Hockenbury * * * LTR 1058 Delivery Status: Mailed."
4. There is nothing in the record to indicate that the IRS sent petitioner any notice relating to 1999 or 2000. We find that he intended to list tax years 1989 and 1990 on the 1986 CDP form and that he wrote 1999 and 2000 by mistake as a holographic error. We find that he made a similar holographic error on the 1986 CDP Form in writing 2001 instead of 1991. He did receive notice of a joint liability with his wife for 2001, but he mailed in a separate Form 12153 for that year.
5. Petitioner paid the 2001 joint income tax liability, totaling about $3,000, in early 2010.
6. Compare, e.g., Jordan v. Commissioner, 134 T.C. 1, 8 (2010) ("We have held that a challenge to the 10-year period of limitations on collection is a challenge to the underlying liability."), with Crites v. Commissioner, T.C. Memo. 2012-267, at *11 ("The second (c)(1) issue here is whether the Appeals officer verified that the IRS assessed the penalty against Crites within the statute of limitations. This is a (c)(1) issue because it is a `legal requirement' that an Appeals officer must consider at a CDP hearing."). See also Proper Standard of Review For Collection Due Process Determinations, IRS Notice CC-2014-002 (May 5, 2014).
7. Petitioner's argument assumes that section 6330(e)(1) operates to suspend the collection period of limitations, regardless of whether the IRS in fact grants the taxpayer a CDP hearing, only if the taxpayer has requested that hearing within the 30-day period referenced in section 6330(a)(2) and (3)(B). Respondent does not challenge this assumption, which is consistent with the regulations. See sec. 301.6330-1(g)(2), Q&A-G2, Proced. & Admin. Regs.
8. Although petitioner on the 1986 CDP Form incorrectly listed tax years 1999-2001 rather than 1989-1991, he corrected this error by filing, on April 23, 2009, a revised Form 12153 listing 1986-1991, the six years covered by the levy notice to which he was responding. The parties do no dispute that the corrected Form 12153 relates back to the date on which the 1986 CDP Form was filed, so that petitioner is deemed to have requested a CDP hearing for tax years 1986-1991 ab initio. Petitioner was in a hurry to file the 1986 CDP Form and completed it at "the last minute." It is clear that he made a holographic error on the original Form 12153 and that he intended to request a CDP hearing for all six of the years covered by the levy notice, not for 1999-2000 (which were never at issue) or for 2001 (which he addressed in a separate Form 12153 submitted in response to the levy notice issued to his wife for that year). Cf. O'Neil v. Commissioner, 66 T.C. 105, 107 (1976) (finding that a petition is adequate where it contains "some objective indication that the petitioner contests the deficiency determined by the Commissioner against him").
9. Petitioner asserts that the date appearing on the levy notice must be deemed to be the mailing date "when there is a clear discrepancy and no other date was provided to the petitioner." To support that proposition he cites Jones v. Commissioner, T.C. Memo. 1984-171, 47 T.C.M. (CCH) 1444, but his reliance is misplaced. In Jones, the date on the notice of deficiency was later than the mailing date; consistently with the authorities discussed in the text, we held that the date appearing on the notice controlled. We stated: "We emphasize that we are not announcing a rigid rule under which the date stamped on the face of the notice will always be considered the date the notice was mailed for purposes of sec. 6213(a). We do not intend, for example, to shorten the period which existing law gives the taxpayer to file his petition when the date stamped on the notice is earlier than the date of delivery to the postal authorities." Id., 47 T.C.M. (CCH) at 1448 n.5.
10. For similar reasons petitioner errs in relying on Offiler v. Commissioner, 114 T.C. 492 (2000), where we relied on the regulations discussed in the text. We there stated that the taxpayer had to request a CDP hearing within "the 30-day period following the date of the notice" and concluded that he had not requested a hearing "within 30 days of the issuance of the * * * notice" on February 1, 1999. Id. at 494, 497. Because February 1, 1999, was the date on which the notice was mailed, our Opinion in Offiler is fully consistent with the conclusion reached in the text.
11. The SO testified that she had inquired whether a certified mail log existed, but the RO replied in the negative. At that time, the Internal Revenue Manual (IRM) did not require the creation of such a log when sending out levy notices. See IRM pt. 5.11.1.2.2.2(8) (Mar. 21, 2008).
12. For essentially the same reasons, petitioner errs in contending that the SO abused her discretion by declining to determine whether he had mailed the 1986 CDP Form on March 13 or (as he testified) on March 14. Both dates are within 30 days of February 13, the earliest date on which the levy notice could have been mailed. Moreover, regardless of when petitioner mailed the 1986 CDP Form, it was timely because the IRS received it on March 16, the due date as extended by section 7503. A settlement officer does not abuse her discretion when she refrains from making determinations that are immaterial to her decision.
13. Petitioner asserts that the IRS publications accompanying the levy notice failed to alert him to the importance of the mailing date. That assertion is incorrect. Publication 1660 reads: "The IRS can't levy or seize your property within 30 days from the date this notice is mailed, given to you, or left at your home or office." (Emphasis added.) Even if an IRS publication offers erroneous information, such publications are not authoritative sources of Federal tax law. See Adler v. Commissioner, 330 F.2d 91, 93 (9th Cir. 1964) ("Nor can any interpretation by taxpayers of the language used in government pamphlets act as an estoppel against the government, nor change the meaning of taxing statutes."), aff'g T.C. Memo. 1963-196.


In addition to our ticketed concerts, MCS Chorus enjoys performing at community events throughout Mississauga. Here's where you'll find us this season, we look forward to seeing you there!
This year, Doors Open Mississauga turns the spotlight onto the Malton community and MCS Chorus is honoured to partner with Trinity United Church at 7113 Airport Road on Saturday, September 8th.
The original 1857 Malton Methodist Church was a wooden, framed building that was later bricked over. It served as a Methodist church until the formation of the United Church in 1925, when it became the Malton United Church. In 1953, the congregation moved to a new church building, where it stands today.
Members of the MCS Chorus will be performing at Mississauga Arts Council's annual Cranberry Christmas Market on Saturday, November 24th.
MCS Chorus/ Mississauga is proud to represent the City of Mississauga by accepting the invitation to perform in partnership with the Toronto Beach Chorale in the annual performance of Messiah for the City. The late Jack Layton conceived Messiah for the City in the late 1990s. He felt music and art should be accessible to everyone. Tickets to this special concert are not sold but rather distributed by United Way and its partner agencies to Torontonians who wouldn't normally have access to such an event.
The performance features players from the Toronto Symphony, professional soloists, and an 80 voice chorus combining The Toronto Beach Chorale, MSC Chorus Mississauga and the Georgetown Bach Chorale and is hosted by CBC's Tom Allen.
Contact us if you would like us to perform at your event.


They took the Big Bad Wolf' stage prop from Kara. I told the raid there was one missing.
Clever Scourge....no wonder the Scarlet Crusade was losing. They are no match for such craft and cunning.
Looks like the trees from super mario brothers that yoshi used to eat the fruit from lol.
If you're really bored, you can repeatedly summon the courier with this thing and kill him over and over again.
This is, by far, the most realistic decoy I have ever seen, in my entire life.
I wish I had one of these IRL, I'm very sure this could get me into the white house or the pentagon, NO one will see through this!
The purpose Tenris Mirkblood was dispatched to Kara must have been to steal one of these!
"What a strange tree. I really must investigate."
at least as far as the scarlet tavern, When he entered the tavern he got killed so I couldn't test how far he'll follow.
worth saying that using this will put you in stealth animation, even if you are a draenei or tauren.
is one of the very few ways to see the "hidden" draenei&tauren stealth mode, if you are that curious to see it.
That tree is a Spy!
It's simply insane that to this day there is no vanity item equivalent of this.


text:
Q: What does "Do you know how to party?" mean? I was actually wanting to know how to say this in Spanish when I realized that I didn't have a clear definition of it in my own language — English.  My knowledge of this phrase comes from colloquial, experiential usage and/or dialogue I've heard while watching American films.  A quick search of the web via Google led me to an Urban Dictionary entry for "Do you party?" but it had only one definition and that was "Do you do drugs?"  My experience with this phrase hasn't included drug usage.  When I've heard this phrase, it usually means something like:
"Do you know how to relax?"
"Do you know how to unwind?"
"Do you know how to have fun?"
"Do you know how to get loose?"
"Do you know how to get down?"
"Do you know how to have a good time?"
"Do you know how to get your groove on?"
"Do you know how to free your inhibitions?"
However, I can't find a source that actually defines this phrase.  I did find a definition of "get your groove on" at a site called "What Does That Mean?"  Its definition for this phrase is below:

It usually means dancing to music, finding your rhythm, etc. The idea comes from the grooves on vinyl records, and finding your rhythm with the "grooves" of the music.

The definition above was the most popular one and it certainly seems to at least somewhat support Jimmy Fallon's use of it in this video here:
Dwayne Johnson's "Shake It Off" vs Jimmy Fallon's "Jump In The Line" | Lip Sync Battle
You'll find other definitions on the "What Does That Mean?" site.  However, they are, unquestionably, for a "mature" audience (i.e., 17+).  If you're curious and such content doesn't bother you, click on the link below:
What does getting your groove on mean?
I tried to find examples of someone on video or in film asking the line, "Do you know how to party?" but didn't find one.  However, revising this to just "know how to party" returned a lot more results.
In fact, you'll find a lot of songs with the word "party" in them and even some that include the phrase "know how to party" (more than 1,000 in AllMusic's database).  One called "I Know How to Party" by Bryson Tiller certainly is using it with sexual connotations.  The video for another one by the same name, but from a different artist — Indian Askin — definitely might make you wonder if "know how to party" is a reference to drugs.
Having said all of that, I am under the impression that the meaning of "Do you know how to party?" goes beyond just "Do you know how to get your groove on?"  It appears to have many meanings and I would like to find the most authoritative source possible that lists all of these various meanings.
Overall, my search of the web was, for the most part, fruitless, but I must admit that it was also cursory, so I would imagine someone, somewhere has attempted to define this phrase.  Rather than waste gobs of time searching for it myself, I thought I'd post a question about it here.
Also, would you consider this phrase colloquial, slang, and/or euphemistic?

A: Party is a colloquial or slang verb. From the OED*:

party, v.
[1. and 2. are obsolete for to side with]
3. colloquial (originally North American).
a. intransitive. To give a party; to attend a party; to have a good time. In extended use: to take drugs or drink alcohol (usually
with others in a social context).
b. transitive. To entertain at a party; to accompany to a party.
c. intransitive. colloquial (originally and chiefly U.S.). to party hearty (also hardy): = *to party down *at sense 3d. Frequently in imperative. Cf. PARTY-HEARTY adj. [The form
in hardy seems likely to derive from the expression to party hard
< HARD adv., with suffixation (compare -Y suffix6) for
reduplicative effect, probably influenced by HARDY adj. and
n.1 The interchangeability of hardy with hearty is likely to have arisen because their U.S. pronunciation is frequently
identical.]
d. intransitive. colloquial (originally and chiefly U.S.). to party down: to go to parties, celebrate, drink, etc., esp. unrestrainedly. Frequently in imperative. Cf. PARTY-DOWN adj.
e. intransitive. colloquial (originally and chiefly U.S.). to party on: = to party down at sense 3d. Frequently in imperative.
f. intransitive. U.S. slang (originally and chiefly in gay usage) to party and play: to engage in sexual activity
sustained, enhanced, or facilitated by the use of disinhibiting and
stimulant drugs. Often in the context of group sex between
men at parties arranged for this purpose; cf. CHEMSEX n.
4. intransitive. U.S. slang (frequently euphemistic). To engage in sexual activity, esp. as or with a prostitute.

So, do you know how to do those things?
*Source: Oxford English Dictionary (login required)

A: My gut feeling is that when someone asks you if you party, they are asking you if you are comfortable using drugs. It is pure euphemism. It would be similar to someone asking if you partake which also is euphemistic for drugs.
See:

*

*https://forum.wordreference.com/threads/do-you-party.106272/#:~:text=%22Do%20you%20party%3F%22%20means,%3F%22%20or%20anything%20like%20that.

*https://movingtolatoday.com/someone-asks-if-you-like-to-party/


text:
Something Very Big
The search for the story of Lancaster B for Baker (and other things)
467 Postblog: List of all sources used
Book Review: The Boy with Only One Shoe
November 30, 2020 December 3, 2020 ~ Adam Purcell
It's a familiar sort of story:
World War II begins. At first, the boy is too young, but he enlists in aircrew the instant he turns 18. Basic training follows and he's awarded an aircrew brevet. Then comes operational training, crewing up, converting onto big four-engined bombers. The new crew joins a squadron, flies on operations and has one or two close calls. Then the war ends.
Call it a fairly standard career for a surviving member of Bomber Command. With greater or lesser degrees of variation, stories like this have been told in countless books over the years. Yes – the story of John Henry Meller, in the new book The Boy with Only One Shoe, follows much the same arc.
But what's notable about this book is that it's been published in 2020, seven and a half decades since the end of the war. It's the rarest of rare things: a recently-written first-hand account by a Bomber Command airman. There just aren't many veterans left alive these days, let alone ones who still have the drive and skill to vividly write a story about events of so long ago – and then publish it.
To be clear, Meller's daughter, Caroline Brownbill, a former airline pilot, is credited as a co-author. It's not clear how much of the work is hers, but that doesn't matter. The narrative is cohesive and in a consistent voice. Brownbill is also, it seems, doing a lot of the publicity work around the release of the book, which was self-published via Amazon in May 2020. The authors are planning to donate proceeds from sales of the book to the RAF Benevolent Fund, and Meller signs and writes a personal message on virtually every copy they sell, which is a nice touch.
John Henry Meller served as a wireless operator with 149 Squadron, flying operations on Lancasters from February 1945. That experience, and all the bits and pieces that go with it, necessarily forms the core of The Boy with Only One Shoe. But this book has so much more to offer too. The early sections about growing up in the English town of Warrington in the 1920s and 30s are detailed, and the descriptions of life as a teenage civilian in the early years of the war are full of life. Post-war, Meller remained in the Royal Air Force for a few years, and there are some very interesting sections about postings to exotic places like Egypt and Libya.
His personal recollections are great, and include some unusual details. I knew that RAF recruits, undergoing basic training in London, ate their meals in a restaurant at London Zoo, for example, but I didn't know that while there they were also told that they would be responsible for "protecting or detaining" any of the zoo animals that might escape as a result of air raid damage. There's also one of the better descriptions of the training and operational role of the wireless operator that I've seen in an aircrew memoir.
These are the sorts of details that you can't easily get from official files and archives – you really need the recollections of someone who was there. There's a fascinating discussion of a lecture attended during Meller's wireless operator course, during which it was clearly communicated to the trainees exactly what risk they were taking by becoming aircrew. The fatality rate in Bomber Command at the time, they were explicitly told, was 46%. Common knowledge now, of course, and certainly by the time a crew had been on a squadron for a few months they would have been well aware of the 'chop rate', but this is the first time that I've heard of aircrew being directly told about it while still in training. It makes their decisions to continue that training all the more courageous.
The Boy with Only One Shoe – the significance of the title is explained in a short introductory section in the book – came about after Meller's son in law persuaded him to write about his wartime experiences, primarily for his grand-daughter. The book is therefore pitched at an audience that may not have much understanding of Bomber Command and the context into which it fitted. Meller provides a lot of that context with explanations of what was going on in the wider conflict at the time, and while some of these bits aren't done as well as the parts of the story based on his own experiences, he nevertheless manages to successfully weave his own story into the wider one.
My only criticisms about the book are, I think, a direct result of its self-published roots. The story is great and the writing is engaging, but in some ways the execution doesn't do the story all the justice it deserves. Editing can be hit and miss, with the occasional superfluous punctuation and, on one occasion, "where" used in place of "were". There are one or two minor errors in terminology that probably should have been picked up, too: cumulonimbus clouds are called "Cumulus Nimbus" on p.175, for example. Formatting inside is a little inconsistent, particularly when dealing with block quotes. There is a contents page, but it's not very useful: it only lists "Chapter 1", "Chapter 2" and so on, despite all the chapters being individually titled. The cover – though attention-grabbing with an illustration of a Lancaster with an engine on fire – is printed on cheap stock and is not very hardy. My copy marked too easily, copping several dings from one or two trips in my bag.
Don't get me wrong: I really liked this book, and Amazon's global reach makes it very accessible to the widest possible audience. But it's a great shame that this story was not picked up by a traditional publisher, who might have had the expertise to overcome the few niggles I had with it.
Putting that to one side, though, The Boy with Only One Shoe is a good read. It's honest, engaging and true to life – and it's a never-before-heard Bomber Command story, written by someone who was there. Well recommended.
ISBN 9781838046705 – jhmeller.com
Available from Amazon.
The authors sent me a review copy for this article, which was originally written for Aircrew Book Review.
© 2020 Adam Purcell
‹ PreviousIn which Adam 'flies' a Link Trainer
When I was young my father showed me a small blue felt-covered notebook. It was the flying logbook of my great uncle Jack, a Lancaster navigator in WWII. Jack's crew was made up of seven young men, all from vastly different backgrounds. They were normal, everyday lads caught up in extraordinary circumstances. This blog charts my search for their story and where it is leading me.
The Australians at War Film Archive
Stirling Aircraft Society Forums
Bomber Command History Forum
Gaining an RAF Pilot's Brevet in WWII
Institutions and Associations
Bomber Command Association in Australia
International Bomber Command Centre
Bomber Command Commemorative Day Foundation
An Ordinary Crew
Lancaster Bombers of 49 Squadron
75 (NZ) Squadron
Aircrew Book Review
Aircraft Q Failed to Return
National Archives of Australia
World War Two Nominal Roll
467 Postblog (100)
Airfields (10)
Bardney (1)
Dale Johnston (8)
Eric Hill (7)
Gilbert Pate (12)
IBCC (17)
Jack Purcell (20)
Jerry Parker (6)
Joining Up (1)
Ken Tabor (8)
Llandwrog (1)
Myths & Legends (9)
Other Aircrew (64)
Pathfinders (2)
Phil Smith (28)
The Search (42)
Tiger Moth (1)
Transportation Plan (2)
Waddington (3)


text:
European stocks edge lower; Credit Suisse gains ahead of U.S. PPI data
Stock Markets Dec 09, 2022 10:20
© Reuters.
FCHI
DE40
CSGN
By Peter Nurse
Investing.com - European stock markets edged lower in nervous trading Friday as investors look to the latest U.S. inflation data amid growing recession worries.
At 04:00 ET (09:00 GMT), the DAX index in Germany traded flat, while CAC 40 in France traded down 0.1% and the FTSE 100 in the U.K. dropped 0.3%.
Equity markets have had a difficult week - with the broad-based S&P 500 index heading for a loss of 2.6% on Wall Street and the DAX index in Frankfurt set to lose 1.8% - as investors worried that tightening monetary conditions will likely result in a global recession in 2023.
Next week sees policy-setting meetings by the U.S. Federal Reserve and the European Central Bank, and both central banks are expected to hike interest rates once more to tackle inflation still at elevated levels.
The spotlight Friday will firmly be on U.S. producer price inflation figures later in the session for more clues about the health of the U.S. economy.
PPI is expected to have climbed 0.2% on the month in November, an annual rise of 7.2%, which would be a drop from 8.0% the prior month.
Back in Europe, Spanish industrial production rose 2.5% on the year in October, a drop from the 3.6% growth the prior month.
In corporate news, Credit Suisse (SIX:CSGN) stock rose 1.9% after the embattled Swiss lender announced late Thursday that it has raised CHF 2.24 billion ($1=CHF0.9333) as a result of a capital raise, in addition to the CHF 1.8B raised from an earlier placing of stock with a group of institutional investors led by Saudi National Bank.
AB Foods (LON:ABF) stock fell 0.7% despite the retailer confirming its 2023 financial guidance, noting lingering inflationary pressures.
Crude oil prices stabilized around one-year lows Friday, and are still set to close the week with heavy losses on worries that the global economy is heading for a recession in 2023.
News that the Keystone pipeline between U.S. and Canada was closed after a spill in Kansas helped sentiment, but the disruption in supply isn't expected to last long.
By 04:00 ET, U.S. crude futures traded 0.2% higher at $71.60 a barrel, while the Brent contract traded 0.1% higher at $76.22.
The two contracts were also set to lose about 10% this week, having previously fallen to their weakest levels since December 2021.
Additionally, gold futures rose 0.1% to $1,803.50/oz, while EUR/USD traded 0.1% higher at 1.0562.
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text:
Wednesday, February 8, 2017 by Bethany Jett
Meet our leaders, the Co-Directors of FCWC. Some of us attend just to hear their banter. (Smile.) But all who attend glean more than a few chuckles from this team. We receive wisdom, grace, and a wealth of knowledge.
Mark Hancock began his career founding a national advertising agency and running it for fifteen years. His conversion to Christ led him into ministry as a Youth and College Pastor, Associate Pastor, Homeless Ministry Director and Global Event Director for an international ministry, organizing events on five continents. He holds two Masters Degrees in the Mental Health Counseling field, having spent a number of years in private practice, and has taught at secular and Christian colleges. An award-winning writer and conference speaker, he serves as Chief Executive Officer of Trail Life USA and lives near Greenville, SC with his wife of 28 years, and two sons.
Eva Marie Everson is one of the original five members of Word Weavers, and a multiple award-winning, best-selling author and speaker. Known as a Southern fiction writer and Bible scholar, Eva Marie teaches at writers conferences, has spoken in churches and special events for women across the country and Canada. Some of Eva Marie's most notable works are: Reflections of God's Holy Land; Sex, Lies, and the Media, The Potluck Club (series); Things Left Unspoken; The Cedar Key series; Waiting for Sunrise; Unconditional (novelization of the movie by the same title), The Road to Testament; and Five Brides. In the autumn of 2016, she had two books release: The Bipolar Experience (written for LeeAnn Jefferies) and God Bless Us Every One. She worked with Eric Eichinger on the biography of Olympic champion and missionary to China, Eric Liddell (Chariots of Fire) for Tyndale Publishing, which releases in 2017. Also releasing in 2017 is Eva Marie's second novel for Tyndale, The One True Love of Alice-Ann. Eva Marie is the president of Word Weavers International, the acquisitions editor for Firefly Southern Fiction, and a freelance workshop leader for AAA. Eva Marie lives with her husband in Central Florida where they are owned by one short dog. She is a mother and a grandmother.
In this exclusive interview with Eva Marie Everson and Mark Hancock, hear Eva Marie call Mark a genius (for reals!), hear insights into the Christian writing and publishing industry, and glean advice straight from the Directors of the Florida Christian Writers Conference.


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text:
Supernatural, the VR workout app, adds boxing for more variety
Supernatural, the Beat Saber-like VR app for the Oculus Quest and Quest 2 that gets you to work up a sweat by beating targets with virtual bats, has added another way to wreck a target: your fists. Boxing is the latest workout introduced on Supernatural and like the original bat-oriented "Flow" workout, it works up a sweat while being fun.
Supernatural Flow is sort of like Beat Saber crossed with high-intensity interval training (HIIT). Each workout can last from seven minutes to an hour, and there's an enthusiastic coach shouting encouragements in your ear and guiding you through the session as you dance, lunge, squat, and murder targets with your VR bats.
The problem with Supernatural, at least for me, is that you can plateau. The workout, like HIIT, is hard on the knees and it's easy to get stuck doing workouts that get the heart rate up but don't actually build your cardio health or muscle. I started cycling and lifting weights to push myself more and give my knees a rest.
Crucially, neither of those things were happening in the Supernatural app. Since Supernatural launched in April 2020, it's added two additional workouts — Guided Meditation and Recover (stretching) — but they felt less like a reason to strap on the headset and dive in than the original Flow workout. Boxing, which launches today, is the third new workout and the first intended to get the heart pumping like the original.
VR boxing to get buff isn't new. Thrill of the Fight and Knockout League on Oculus Quest both have enthusiastic fans who use them for cardio. But like Beat Saber, those are games being used for working out. Boxing in Supernatural is very much a workout first. Black and white targets fly at your face and you're meant to hit black targets with your left hand and white ones with your right. The targets look different depending on if you're supposed to jab, uppercut, or toss a hook at them. Glowing bars twirl toward your face to force you to tilt left or right or do a full bob and weave to avoid them. The coach has you stretch for about thirty seconds to a minute both before and after the core workout. They also tell you when to change up your feet position to ensure you're working out your left and right sides equally, and they tell you when to get ready to block a blow with both hands.
The workouts available before launch were limited to just 13 minutes max. After that first one, I told my co-workers it had given me a good sweat but hadn't done much else due to how short the workout was. Then I woke up the next morning and my arms and shoulders called me an idiot. Heart rate-wise, the average beats per minute in the boxing workout were about 10bpm higher than in the regular Supernatural workout — and my knees didn't get as angry with me. I could definitely see using this regularly as a warm-up before weight training.
But I don't know if this would be a good supplement for people who regularly box to keep fit. When I did a slower-paced low-intensity workout, I had no problem keeping great boxing form, but faster-paced workouts absolutely wrecked it. I went from feeling like I knew how to throw a punch to flailing like I was in a fight with my brother when I was 10. I didn't miss a lot of targets, but I'm also positive my punches would have landed on a heavy bag like the gentle flutter of a butterfly wing.
Thankfully, I have no interest in going to a boxing gym — heck, I don't really want to go to a regular gym either. And Supernatural, despite its inability to stop bad boxing habits, gives me the feeling of a gym without all the smells and potential for COVID-19 exposure.
Boxing is available on Supernatural starting today. Supernatural is available for a free, month-long trial. After that, you'll either need to pay $18.99 a month or $179 a year to get access to new workouts, which are available daily.
Doug the ugly New Zealand potato could be world's biggest
Basketball star Kevin Durant launches $200 million SPAC


THE GIST of Editorial for UPSC Exams : 11 FEBRUARY 2019 (The solution is universal (The Hindu) | IAS EXAM PORTAL - India's Largest Community for UPSC Exam Aspirants.
To allay some misgivings of the distress, one of the announcements in the Budget speech was that "vulnerable landholding farmer families, having cultivable land up to 2 hectares, will be provided direct income support at the rate of ₹ 6,000 per year".
The Ministry of Agriculture has written to State governments to prepare a database of all eligible beneficiaries along with their Aadhaar numbers, and update land records "expeditiously". The letter further states that changes in land records after February 1, 2019 shall not be considered for this scheme.
The farmers' distress needs urgent attention but let's see if the PM-KISAN is a reasonable solution.
In targeted programmes, it is very common to have errors of exclusion, i.e., genuine beneficiaries get left out. Such errors go unrecorded and people continue to be left out.
Several MGNREGA payments have been rejected, diverted, or frozen as a consequence. In the last four years alone, more than ₹1,300 crore of the MGNREGS wage payments have been rejected due to technical errors such as incorrect account numbers or faulty Aadhaar mapping.
There are numerous cases of MGNREGS payments getting diverted to Airtel wallets and ICICI bank accounts. In Jharkhand for Aadhaar-based payments, it was found that 42% of the biometric authentications failed in the first attempt, compelling them to come later.
The MGNREGA allocation for 2019-20 is ₹60,000 crore, lower than the revised budget of ₹61,084 crore in 2018-19. In the last four years, on an average, around 20% of the Budget allocation has been unpaid pending payments from previous years.
While the country stares at an impending drought, workers languish in unemployment. The MGNREGA is neither an income support programme nor just an asset creation programme.
Yet, work demand has been 33% more than the employment provided this year underscoring the desperation to work.
At a time of such acute distress, does it not behave the Central government to improve the existing universal infrastructure of the MGNREGA before plunging into a programme pretending to augment farmers' income?
Q.1) The New Development Bank is associated with which of the following international organisation/ grouping?
Q.1) Strengthening the MGNREGA would be more prudent than a targeted cash transfer plan like PM-KISAN. Give your arguments in this regard of this statement.


text:
Бульонные кубики — это спрессованный концентрированный и обезвоженный гидролизат животного или растительного белков. Он формируется в кубики со стороной примерно 15 мм. Бульон, приготовленный растворением кубиков в кипятке, хуже по качеству, чем натуральный сваренный, однако он дешёвый, удобный и широко используется на кухне для приготовления блюд. Чаще всего применяется для дополнительной ароматизации приготавливаемых блюд (супов, гарниров и т. д.).

Изготовление и состав
Впервые их начал продавать в 1882 году швейцарский предприниматель Юлиус Магги. Он разработал и начал производить их для бедных городских жителей (которые не могли позволить себе мясо) как недорогой способ приготовления питательного супа.

Первоначально, до Юлиуса Магги, бульонные кубики (изначально порошки) изготовлялись путём сублимационной сушки из натурального мясного бульона, но не имели широкой популярности из-за низких вкусовых качеств. Современные бульонные кубики представляют собой гидролизат белков (кислотный при помощи HCl или ферментативный гидролиз) и жиров (обычно гидрогенизированные жиры) с загустителями (обычно крахмал), пищевыми ароматизаторами, усилителями вкуса, вкусовыми добавками и иногда пищевыми красителями. По сути, изготовление бульонных кубиков относится к безотходной технологии, так как сырьём для гидролиза могут служить кости (содержат коллаген), низкосортные рыба и мясо, субпродукты, рогокопытная мука (содержит кератин), а также соевый белок. Заявления, что они изготовлены из бульона (в широком смысле под бульоном можно подразумевать любую смесь, в том числе раствор гидролизата белков различного происхождения), курицы, говядины, грибов и т. д., — в большей степени маркетинговый приём. При изготовлении некоторых бульонных кубиков в гидролизат может добавляться определённая часть упаренного мясного бульона, сушёные травы, овощи и грибы.

Повышенная солёность бульонных кубиков обусловлена также технологией приготовления: при нейтрализации гидрокарбонатом натрия избытков соляной кислоты применяемой при гидролизе образуется хлорид натрия (HCl +  → NaCl +  + ). При получении белковых гидролизатов, несмотря на некоторые преимущества ферментативного гидролиза, чаще используется кислотный гидролиз, так как гидролизат, получаемый при этом, обладает лучшими вкусовыми качествами, а технологический процесс получения занимает меньшее время. Для придания насыщенного вкуса в состав бульонных кубиков практически всегда включаются усилители вкуса, такие как глутамат натрия, инозинат натрия, .

Виды по вкусу-аромату
 Говяжий
 Куриный
 Рыбный
 Грибной
 Утиный (французская и швейцарская)
 Бараний (валлийская, ирландская)

Производители

 Maggi
 Knorr
 Gallina Blanca

См. также
 Бульон из сена

Примечания

Литература
 .
 ГОСТ 5.106-68 «Кубики бульонные мясные. Требования к качеству аттестованной продукции».
 ГОСТ 18157-88 «Продукты убоя скота. Термины и определения».
 Баер Н. А., Неклюдов А. Д., Дубина В. И. и др. Патент на изобретение RU2132142C1 от 12.11.1998 г. «Способ получения белкового гидролизата из мясного и мясокостного сырья убойных животных».
 Д. Маккарти, Д. Маккартидхарам, В. Вадехра, Д. В. Вадехра. Патент на изобретение RU2185075C2 от 25.05.1995 г. «Способ получения съедобного гидролизата (варианты)».
 Кильмаев А. А., Разумовская Р. Г. Исследование ферментативного гидролиза малоценного рыбного сырья в технологии получения белковых продуктов / Научная статья, УДК [664.951.014:577.152.3]:664.959.2 // Астрахань: Вестник АГТУ, 2007 г. ISSN 1812-9498.

Приправы


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