Outback

Outback Steakhouse in Knoxville, TN, who recently assumed the new position of Joint-venture partner, and who will now be overseeing 12 restaurants located between Huntington, WV, and Pittsburgh, Is profiled as part of Nation's Restaurant News' NOR 50 General Managers Orchestrating Success feature. Throughout his years at the Knoxville property, Stanton Increased sales by a whopping 133% to $4. 3 million dollars. While Stanton rewards his employees financially, he also is keen on showering them with the respect they deserve.He notes that one of the most blissful aspects of his Job is to attach his staff evolve, slowly working their way through the ranks of the restaurant world. Joint-venture partner raises the stakes, ropes in customers, lassoes $4. 3 million in sales Since 1995 Tim Stanton has spent much of his time at the bustling Outback Steakhouse In Knoxville, Teen. He has watched sales grow, led a staff that Is alert and happy and enjoyed the unwavering support of his family. No w things are about to get even better.View Image – Stanton, who recently was made Joint-venture partner, soon will oversee 12 restaurant locations as well as four more that still are under construction. This month Stanton assumed the new position of Joint-venture partner. Instead of overseeing one Outback in Tennessee, the 43-year-old now will watch over 12 restaurants located between Huntington, W. Va. , and Pittsburgh, as well as four that are under construction. â€Å"This Is It,† Stanton says. â€Å"This Is my best tour of duty. All the rest were stepping stones. At Outback those with generalization responsibilities are not known as general managers. Instead, they are called managing partners and have partial ownership of their restaurants. As a result, managing partners have a personal stake in the success of their operations. For Stanton, who served as managing partner of the Knoxville restaurant for nine years, It was that vested Interest that motivated him to generate sales aggressively. â€Å"It's an ownership,† Stanton says. â€Å"l made a commitment to generate sales. Without sales, there are no profits.Without profits, there Is no business. It's the perfect triangle. Ten percent of the bottom line is profit. † Throughout his years at the property, he increased sales by a whopping 133 percent to $4. 3 million dollars. Colleagues are in awe of the accomplishment. He took a store that was in a good place and increased sales,† says Sheer Monnet, who worked alongside Stanton in Knoxville, helping to manage the front-of-the-house as well as tend bar. â€Å"His bosses weren't seeing those results in other stores, and so they said, ‘Maybe you can show us how to do it. † As a Joint-venture partner, Stanton will work hand in hand with managing partners, guiding them through operational challenges and keeping Outback's mission fresh and alive. His new home base will be Pittsburgh, and his hours, often 70 to 75 h ours weekly while he is in Knoxville, are likely to get longer. You goat do what you goat do,† he says of his managing-partner days. â€Å"If I needed to be in early, I came in early. If I needed to work late, I worked late. † In Knoxville, Stanton managed a staff of 70, with more men in the kitchen and more women in the front-of-the-house.As Joint-venture partner, Stanton will oversee 840 people, and that number is likely to grow because building the Outback brand within his new territory will be one of his mandates. But Joe Roberto doesn't foresee any problems. Station's supervisor for a year and a half, Roberto is a Nashville, Teen. -based Joint-venture partner who worked directly above Stanton and now shares similar responsibilities for a different regional market. â€Å"He's incredibly driven and extremely motivated,† Roberto says of Stanton. â€Å"He's detail-oriented and passionate about food quality. He's demanding but fair. † View Image – T he in Knoxville, Teen. Has been the site of many community fund- raisers and has contributed to such organizations as The Heart Association, The Lupus Foundation and Race for the Cure. As Monnet recalls, Stanton was an inspiring boss. â€Å"He's an extreme perfectionist,† she says. â€Å"He sets his expectations high and knows what needs to be done. † Stanton is no stranger to the restaurant industry. The Illinois native actually went to school for coal-mining technology, mistakenly thinking that's how he wanted to spend for mom-and-pop establishments and fast-food chains, and decided he needed to become a part of it.To escape the cold Midwestern winters, Stanton became area manager of the Long John Silver's franchise market in the Southeast. He also worked for eight and a half years as a Chili's general manager and credits that company with teaching him the importance of fresh food. When he learned about the opportunities at Outback, he made the leap. Based in Tampa, Flat. , Outback now has 825 namesake steakhouses as well as several other full-service concepts. View Image – Stanton says he rewards his financially and also is keen on showering them with the respect they deserve.Monnet says the fact that Stanton was such a dedicated managing partner made the Knoxville Outback feel more like a comfortable home than an impersonal and stuffy business. She says Station's own family was very involved with the dynamics of the restaurant. It was not uncommon to see his wife helping out with the books. His sons and daughters also worked there at different times. L would love to Just slow my kids down from growing up,† says Stanton, a self- described family man who has been married for 21 years and has four children.While Stanton rewards his employees financially, he also is keen on showering them with the respect they deserve. He notes that one of the most blissful aspects of his job is to watch his staff evolve, slowly working their way thr ough the ranks of the restaurant world. â€Å"There is someone who came on board with me who went from [being] server to bartender to key employee,† he notes. â€Å"Someone else also came on board as a server, hen started working in the back on salads, then went on to become key employee and then manager. Some people are not focused on life yet but have that fire in them. For his employees Stanton likes to keep it simple, believing that it is the little things that keep everyone happy. He's the kind of guy who might let someone take the day off or, for a more morale-boosting team event, rent a movie theater out for a fun afternoon flick. He says the most important thing he has learned along the way is that communication is vital. He always listens and also encourages his staff to get involved. And he does so not Just in the restaurant. An avid community leader, Station's generous spirit reaches out to his own backyard.Under his leadership the Knoxville Outback has been the s ite of many community fund-raisers for grade schools and churches and has contributed to such diverse causes as The Heart Association, The Lupus Foundation and Race for the Cure. Once, around Halloween, local children were encouraged to pick pumpkins, decorate them and bring them to the Knoxville Outback to display them so that customers could vote on their favorites. Despite his stellar accomplishments, Stanton maintains that he is doing nothing less Han acting upon his commitment to Outback. We have to be committed and set the bar high,† he says. â€Å"We have to be ready and take care of the guests as a group goal. You need great food and great people. It's a team. Some people are exceptional in themselves. Surround yourself with great people, instill pride in them and give them something they can take pride in. † Sidebar Tim Stanton Outback Steakhouse Outback Steakhouse Inc. Concept type: casual Steakhouse Company location: Tampa, Flat. Unit location: 330 N. Peters Road, Knoxville, Teen. No. Of years with company: 9 years, 6 months Age: 43 Hometown: Carbondale, Ill.Personal: married, four children, ages 9 to 21 Most rewarding part of your Job: seeing the people I work with grow with the company work with. Tip for otter general managers: Surround yourself with great people. What the boss says: â€Å"I've known Tim Stanton for eight years,† says Ben Novel, vice president of operations for Outback Steakhouse. â€Å"He Joined Outback in 1994, and since then he's been up there, winning Proprietor of the Year six times. â€Å"During his tenure Tim became a managing partner and grew sales from $3. 2 million to $4. 3 million. It's a spectacular thing. He's a developer of people.

Immortality

Possibly one of the greatest achievements in life is to attain immortality. Generally, immortality means being able to have eternal life or sustain life for an infinite amount of time. However, for a lot of people, the word can have different meanings if it is viewed from various perspectives. For soldiers or heroes of war, the only way to attain immortality is through fighting in the battlefield. However, contrary to the purpose of immortality which is to sustain life, for soldiers or heroes of war, death is another way to become immortal. Basically, more than receiving honor and glory after a battle or a war, it is also important for soldiers to be remembered. And for some, the best way to do this is to die honorably. Dying in the battlefield makes soldiers heroes almost instantaneously as they are given medals and other posthumous recognitions. Although they are no longer alive, the names and accomplishments of the soldiers who die valiantly and honorably are always glorified and in effect, this makes them immortal. In other words, soldiers who die in battle become immortal as their names are forever imprinted in history. On the other hand, other people believe that immortality can only be attained if they remain young. In this aspect, the concept is that if one stays young, he or she will not acquire age-related diseases or sicknesses which could cause his or her death. While there are a lot of methods and ideas being used to preserve one’s youth, most of them only have temporary effects. For example, one of the most conventional methods to stay young is exercising as studies show that this promotes good circulation of the blood in the body which subsequently results in good health. Although this method does not make a person immortal, it sustains his or youth for a short period of time. However, aside from conventional methods, some people believe that one way to attain immortality is through supernatural or magical means. One example is the legendary fountain of youth which is a spring that restores the youth of any person who drinks from it and is believed to be located in Florida. While modern day society has dismissed the existence of this fountain, certain people still believe in its youth-restoring effects and even drank the water themselves. Moreover, according to the basic concepts of most religions, people are immortal as they possess in them souls or spirits, which never cease to exist. For example, in Buddhism, one of the strongest beliefs is that people go through a cycle of birth, death, and rebirth. Although Buddhists believe that there is no such a thing as an eternal soul, they still believe that after biological death, a person will still continue to live and attain eternal happiness. On the other hand, in Christianity, the strongest belief regarding immortality is that everyone who dies will eventually be resurrected depending on the â€Å"Final Judgment† of God. Based on this belief, those who are born again after the â€Å"Final Judgment† will live forever or attain immortality. However, for other people, one sure way to attain immortality is to publish a book. Whether it’s a novel, an autobiography, a reference material, the authors of these books can attain immortality as their thoughts and ideas are printed and read by people from all over the world. Even if these authors die, they will still continue to live on through their ideas and stories that have been published in their respective books. Furthermore, for some people, attaining immortality is simply being the first in accomplishing extraordinary feats. For example, Edmund Hilary, who recently died due to a heart attack, became immortal because he was the first to successfully climb Mount Everest. In reality, Hilary was an ordinary person. However, since he was the first to conquer the world’s tallest mountain, he was able to imprint his name in history books and attain immortality. Another venue to attain immorality is sports. In the world of basketball, Michael Jordan was able to achieve immortal status by being named â€Å"the greatest basketball player of all time† by the National Basket Association (NBA). Aside from his legendary stint in the NBA, Jordan has also become a highly successful brand name. Up to his day, kids and even professional basketball players from all over the world continue to idolize Jordan, which further solidifies his immortality. Furthermore, in sports, height is also another way of attaining immortality. In basketball, aside from his superb talents and numerous accomplishments, Magic Johnson is also remembered as the tallest point guard to ever play the game. On the other hand, Shawn Bradley is the tallest player to every play the game. Although in terms of accomplishments, Johnson outweighs Bradley, both their names are already imprinted in history books simply because of their heights. In this regard, fame is also another way of attaining immortality. Like in the case of Jordan, famous people such as rock stars, professional athletes, and actors, among others, are able to attain immortality by simply showcasing their skills and talents in their respective fields or specialties. However, for some, immortality is attained by simple passing on objects, lessons, and other things to younger generations. For example, a father has already attained immortality if he is able to pass on good values to his children, who in turn, pass on the lessons they have learned to their children. Even if the father dies, he will continue to live on through the lessons that he has passed on to his children. In short, immortality is not simply through prolonging life. It can also be achieved if one passes on memories, legacies, and lessons to future generations.

Mary Wollstonecraft and Gender Inequality in Our Modern World Essay

Ridgeway states that â€Å"In the United States as in many other societies, gender relationships are changing and inequalities between men and women are questioned in virtually every sphere – at work, in the home, and in public affairs.† In Mary Wollstonecraft’s â€Å"A Vindication of the Rights of Women,† she argues different issues about women’s role in society, and she called for equality between men and women. However, even now women still demand equal rights with men because gender inequality still exists throughout different countries in the world. Since â€Å"A Vindication of the Rights of Women,† many issues have changed for women in society in various fields such as education, employment, and politics, but some specific problems exist now. In the modern world, there are many gaps between men and women in different positions. Wollstonecraft’s piece still applies to women in the modern world because of social, economic, and political inequality. Wollstonecraft argues that women’s societies are neglected when she wrote hundreds of years ago. This is still true in the present day because in most societies men and women are allocated diverse duties, rights, and privileges. Women and men have different roles in society. Gender inequality is characterized by the social process individuals deal with. According to Wollstonecraft, â€Å"There must be more equality established in society or morality will never gain ground, and this virtuous equality will not rest firmly even when founded on a rock† (198). This means that society plays an important role in determining the position role of the women, and that role depends on religion, traditions, and customs. They are attached to values joined to human well-being and prosperity. Research shows that â€Å"Sex categorization unconsciously primes gender stereotypes. This allows the stereotypes to become cognitively available to affect our behavior and judgments† (Fisk ). Regardless, how much they truly do shape our conduct can vary from inconsequential to huge depending on the particular situation and our own specific goals and interests. For example, in general, men are accepted by society to be particularly more skilled than women in male work -settings such as engineering, sports, and positions of expertise, while women are advantaged in female- work settings such as childcare and communication. In other words, Wollstonecraft acknowledges society expects a different thing from men and women. Also, Wollstonecraft writes about the role of women in the economy is not as clear and concrete as it is for men. Wollstonecraft mentions that â€Å"Business of various kinds they might likewise pursue if they were educated in a more orderly manner, which might save many from common and legal prostitution† (205). In other words, people don’t know what women can accomplish because they have never been allowed to fully participate in the economy because of gender-defined jobs. In most of the world, women spend more hours working than men. In addition, they spend a lot of energy doing housework which is unpaid and along these lines not considered when economists analysts measure the amount of work done by men and women. Indeed, even women who have full-time occupations do the majority of housework in the household. In most countries, women possess an exceptionally small percentage of the basic leadership positions in the upper economic range. Although women work more hours than men, the wage gap between the genders remains generally static between women and men working full time according to the study in the article, â€Å"Women still make only about 80% of what men earn for full-time work† (Ridgeway). Also, corporations should assist in treating both women and men similarly because when women choose to have kids and stay home for maternity leaves they don’t make it up the chain of leadership. However, companies should significantly assist in executing approaches that incorporate women again into the workforce in senior positions after having children including more flexible advancement processes and activities as strategic scheduling. Furthermore, Wollstonecraft discusses that women’s politics has been intangible for many years and still exists in the modern world. According to the article, â€Å"Women are less likely to hold managerial or supervisory positions, and when they do, their positions carry less authority† (Ridgeway). Men have had the monopoly on political power for a long time which indicates gender inequality and led to its continuation. Even in democratic societies, gender segregation happens in governmental issues both concerning assumptions about political devotions that fall along gender lines, and dissimilar gender representation inside delegate vote based systems. Truly, this is considered obvious when women couldn’t even vote. Wollstonecraft writes that â€Å"They might also study political, and settle their benevolence on broadest basis, for the reading of history will scarcely be more useful than the perusal of romances† (205). The participation of women in politic al life is one of the most important elements of the democratic process in a country. Therefore, the weakness of democratic mechanisms and forces in society contributes to the marginalization of women’s political participation. Public and private communities should strengthen their capacities to contribute to the development of their female population. It should be noted that traditional societies are more likely to recognize women’s political rights. This is important because women with access to political power might have an opportunity to change her situation thus disrupting the narrative that men are the traditionally powerful ones in society. Obviously, when Wollstonecraft wrote the â€Å"Vindication of the Rights of Women,† she opened the doors for women’s rights. Wollstonecraft piece is still applicable to women in the modern world because of social, economic, and political systems. Although women have equal rights in some fields, some issues of equality regarding society’s rights and duties are still with us today because it depends on society how people think about and respects women. Works Cited Fisk, Susan, â€Å"How Does Gender Inequality Persist?.† Gender.stanford.edu, Monday,2 May. 2011, http://gender.stanford.edu/news/2011/how-does-gender-inequality-persist. Ridgeway, Cecilia. L, â€Å"HOW GENDER INEQUALITY PERSISTS IN THE MODERN WORLD.† Scholarsstrategynetwork.org, June. 2013, http://www.scholarsstrategynetwork.org/brief/how-gender-inequality-persists-modern-world. Jacobus, Lee, editor. A World of Ideas. Bedford /St. Martin’s, 2017. Mary, Wollstonecraft. â€Å"Of the Pernicious Effects Which Arise from the Unnatural Distinctions Established in Society†. Bedford /St. Martin’s, 2017, pp. 198-205. NSCC Grading Rubric for Composition I and II Note: All essays are marked for errors and include comments. This rubric shows the breakdown of your score. Any essay that does not meet the requirements of the assignment may not be graded and may receive a zero. Any essay that contains an abundance of major grammatical errors or numerous repetitive errors that negatively affect the meaning and readability may lose extra points. A. Content Topic Fits assignment, narrowed appropriately, focused, original, shows independent thought, creative Thesis Statement Clear, strong, focused, logical, and insightful Rhetorical Technique Adheres to assigned rhetorical technique or blends rhetorical techniques effectively to enhance the strength of content Support Evidence, details, examples, and explanations are sufficient, thorough, accurate, logical, well-developed, and effectively support claims, ideas, and the topic Critical Thinking Appropriate level of analysis, evaluation, inference, or deduction of issues related to the topic Comments Possible Score Your Score 25 B. Organization Thesis Placement Thesis statement is logically placed for the specific essay Introduction Catches reader’s attention, accurately introduces scope of paper, interesting Conclusion Leaves reader with a sense of completion reemphasizes point and/or motivates reader, the appropriate ending for essay Paragraphs Each paragraph is well developed and relates to the thesis has a strong topic sentence and presents solid supporting information Sequencing Careful development of related ideas in coherent, sequential paragraphs with smooth and logical transitions that create a smooth flow of the essay Comments Possible Score Your Score 25 C. Editing Grammar Essay is free from major errors, such as fragments, comma splices, run-ons, and agreement errors, and minor errors, such as punctuation and capitalization Style Tone is mature, consistent, and suitable, a voice is appropriate for academic writing, and awareness of audience is evident Language Sentences are forceful, clear, and logical, a variety of sentence structures are present, and diction is precise and expressive using college-level vocabulary Presentation Correct MLA style formatting, including MLA style heading, double-spacing, correct margins, and font style and size, with a strong title and indented paragraphs Comments Possible Score Your Score 25 D. Documentation Sources Appropriate amount of research is used from credible and quality sources instead of sources such as encyclopedias, SparkNotes, eNotes, BookRags, Wikipedia, answers.com, or the like; sources support rather than overwhelm the writer’s ideas Borrowed Information Quotations use quotation marks or are put in block format if needed and are written exactly as the author intended, paraphrases and summaries are written well and do not change the meaning of the original, information is integrated smoothly into text and thoroughly discussed, and quantity and quality of information is appropriate In-text Citations Formatted correctly with a signal phrase and a citation that matches the first element of the works cited the entry Works Cited Page Starts a new page, entries are double-spaced and indented correctly, information is incorrect order and complete, and no extra sources are listed that are not cited in the essay Comments Possible Score Your Score 25 Total Score Possible Score Your Score 100

History and Political Science Essay Example | Topics and Well Written Essays - 2250 words

History and Political Science - Essay Example There were many factors at the end of the 19th century that saw a shift towards American Imperialism. Kennedy Cohen-Bailey in his book, The American Pageant outlines the period and covers the various aspects that led to the Great War of 1914 and America’s involvement. This article reviews the book under the following subheadings: The Spanish American war and the aftermath. The legacy of President Roosevelt and the effect of his presidency on America A comparison of the presidency of Theodore Roosevelt. Taft and Wilson and who was the best among the three? The end of World War I and the decisive factors that lead to the end The Spanish American war and the Aftermath The US had for the most part of the 19th century strictly adhered to its non-colonization policies and even at the onset only acquired contiguous territories. Most of it was brought about by the need to expand the trade borders of the American people. America was linked in many ways to Cuba than just at the time of the war. Cuba was one of the major producers of sugar and major suppliers to the USA. The Wilson-Gorman tariff imposed on Cuba by America to protect the sugar growers in America invariably raised the price of sugar and the Cuban economy suffered as a result. The misrule by the Spanish of its colony in Cuba created a lot of unrest. The Cubans fought the 10year battle of independence from 1868 to 1878 and tried to drive the Spanish away by destruction of property including cane fields and blowing up of passenger trains. The situation peaked when Spain sent tyrant General Wyeley in 1895 to Cuba. Wyeley took it upon himself to crush the rebellion and opened up re-concentration camps, imprisoned and isolated the Cuban revolutionaries from the Filipino revolutionaries in their war of independence. Many perished and â€Å"died like dogs† (Bailey, 629). from unsanitary conditions in the camps. The American people rose against this atrocities to the Cubans and wanted war but the then president Grover Cleveland was against it and even motioned to strike against congress if they were to declare war against Spain and send troops to Cuba. This resolve however did not last very long as there were many other factors at stake than America was unwilling to admit to at that time. US also had a stake in the war because it was not really comfortable with having a European colony that close to its own borders. The unrest in Cuba was straining US trade relations in the region and threatening US investments in Cuba. There was also fear that its access to Panama would affect future sea trade routes. The anti-colonisation policies of the US went a long way in selling the concept of a free Cuba to the Americans. What cinched the deal however was the journalistic trend of the time, which focused more on justifying the concept of war. There started a spate of graphic imagery and reports of atrocities adding fuel to the situation and feeding the insatiable hunger of yellow journali sm. Eventually Wyeley was removed from his position and sent back home. In February 1988, the USS Maine, which was on a friendly mission to take Americans in Cuba to safety, blew up in the Havana harbour with the loss of 260 American lives. The cause for the explosion still remains unknown. Reports have even said that the blow up was due to mechanical failure and not a case of sabotage. But sensationalised news articles blamed the Spaniards for it and the fate of history was sealed, War had begun. President Mc Kinley forced by circumstances and party loyalty consented and under Theodore Roosevelt’s command of the military, the American’s over threw the Spanish from Tampa, Florida and gave armistice to the Cubans in August 12, 1898. The war was a forgone conclusion although not evident. Spain’

A policy review of affordable housing in London Essay

A policy review of affordable housing in London - Essay Example Affordable housing policy has over time been the dream for the Londoners to find a sustainable solution to the housing challenges affecting this great city. In 2014 for instance, London housing strategy recognized that there is need to bring together adequate resources to enable London the development of 42,000 houses per year. This aims at virtually doubling the housing delivery for London. The strategy recognizes the need for collaboration between governments, private sector, mayor and boroughs. There is need for a policy framework that promotes support bringing up of surplus public land, as well as in promoting institutional investment to see London deliver the necessary housing.  a) Specific Policies for Boosting Housing SupplyThe London housing strategy under section 3.2 provides for policy reforms to create a flexible market and promote the growth of intermediate housing. The London policies have tremendously changed over time and in 2014, a policy to see increased housing de liveries involved the following (GLA, 2014,): Policy 1: the mayor of London city is expected to work with other partners to deliver the planned target for London which is 42,000 houses per annum. The policy provides for 25,000 market homes; 17,000 affordable homes that people can rent or buy; and 5,000 of the market homes shall be for purpose-built. This will include the long term private rent especially on the schemes which have more than one phase increasing the housing supply for the City.  Ã‚  

What is the marketing of Pampers diaper product and why is it marketed Assignment

What is the marketing of Pampers diaper product and why is it marketed in this way - Assignment Example The brand of Pampers always tried to maintain a strong relationship with its target customers and so desired to offer highly innovative products at a competitive price. In order to fulfil such strategy, it introduced pamper diapers for the babies of varying sizes. However, in order to enhance the position of the products in the market, it used varied techniques such as: Sampling program-in order to position the new product, pampers used to offer gif samples to the mothers. By doing so, the reliability and loyalty of the customers might get enhanced that might prove effective for the new product; diapers. Vigorous advertising- in order to market the new product, Pampers offered higher concentration over the process of advertising. However, it is done in order to enhance the level of awareness of the customers thereby amplifying the total sale and profitability of the brand. But it mainly focused on television advertisements, newspaper advertisements highlighting clean and comfortable nights, long sound-sleep day times. By doing so, the brand might enhance its position and brand image of its products in the market and within the minds of the customers. The product of diapers is marketed in the above mentioned fashion in order to analyse and evaluate the purchasing behaviour of the target customers. Apart from this, by doing so, the brand might analyse, which segment (newborn, extra protect, night, fresh comforts and wipes) is highly preferred by the customers. Along with this, the brand might also evaluate, which segments presents the highest sale and revenue among others. By doing so, the brand of Pampers might offer high concentration over that specific segment thereby amplifying its consistency and loyalty in the market among other segments. This might help the brand of Pampers to enhance its market demand and reliability in the market thereby fading the popularity of its competitor; Huggies (Pampers, 2014). Other than this,

Compare and contrast the experiences of the former colonies and Essay

Compare and contrast the experiences of the former colonies and developing countries in the twentieth century to the earlier new nations in the Americas in the eighteenth and nineteenth centuries - Essay Example While earlier colonisers were fully in charge of the governance of their colonies before 18th and 19th centuries, twists of events were experienced in the neo-colonialism period (Strayer, 2012). This was in the 18th century through 19th century. In the 18th and 19th centuries, â€Å"new nations† in the Americas were generated. The colonial powers in these centuries ceased their harsh rules to the developing countries. The developing countries or the former colonies, therefore, became sovereign and fully in control of their social, political and economic resources. This research paper compares and contrasts the experiences of the former colonies and developing countries in the 20th century to the â€Å"new nations† in the Americas in the 18th and 19th centuries. Formers colonies and developing countries in the 20th century were ruled by realism policies while the new nations in Americas were under idealism policies (Strayer, 2012). The former colonies were governed by iron fist. This is a case where colonial governments did not recognise the sovereignty of colonies and their citizens. The new states, on the other hand, emerged due to the struggle for liberation from the colonial governance. The Pan Africanism movement, for example, was the epitome of â€Å"new nations’† origin (Strayer, 2012). New nations in the 18th and 19th Centuries are sovereign states with recognitions in the international relations while the former colonies never had such recognitions. The idealism policies’ governing the post-colonialism new nations believes in the enlightenment process in the international system. The realism, on the other hand, was composed of the self-interest realist colonial powers, which never believed in the enlightenment process or even humanity. Realism majored on their excessive and unrestricted power imposition on their colonies (Strayer, 2012). Indeed this absolute power

Judaism and the Jews in New York Term Paper Example | Topics and Well Written Essays - 1500 words

Judaism and the Jews in New York - Term Paper Example American Jews are American citizens having Jewish faith and Jewish ethnicity and whose origin also is from other countries. A wide range of Jewish cultural traditions and a full spectrum of Jewish religious observance are apparent in the Jewish community of America. The Jews of America live overwhelmingly in the suburbs of the largest American cities. The American Jews by every measure constitute to be one of the highest socio economic groups of the United states and they share almost all the characteristics of the upper middle class urban Americans. Depending on demographic studies and religious definitions, the United States is home to the world’s second largest Jewish community. This paper in particular intends to describe Jews in New York and their religion ‘Judaism’. Who is a Jew? The Jews represent a group of people having some unique characteristics rather than a distinct race or ethnic group. Although the Jews originally came from the Middle East, many a n umber of races and people have joined together in Jewish communities over the centuries, especially after Jews were forced out of Palestine in the second century A.D. In America, they engaged in marriages with Christians and formed a mixed community. It is evidently, a common Jewish heritage that passed down from generation to generation that binds the group together. And for the Jews in New York also, the binding element is their religion. Although most often, Judaism is used as a term referring to the Jewish religion, sometimes it is used to refer to all Jews. In other words, one does not have to be religious to be Jewish. In general, one is Jewish if one is born of a Jewish mother or converted to Judaism. Unlike Christians, they are still waiting for the arrival of a Savior who would integrate all the Jews who have been scattered and gone astray. Advent of Jews to America There is no unanimous opinion among the historians as to when the first Jews came to America. Although many b elieve that Jews reached America in the ancient period either when they were attacked by aliens or when they faced persecution from the Christians, no solid evidences are available to prove this argument. As Adler and Huhner point out, still it is believed that the first Jews came to North America in 1654 and settled in the Dutch colony of New Amsterdam which was later renamed as New York. Most of those who came were refugees from Recife, a Dutch colony in Brazil. It was when the Portuguese attacked the colony the Jews left Recife and headed to Holland. But as they ran out of money they were forced to settle at the Dutch colony of North America (Adler and Huhner). The newly came people were granted permission to inhabit in the American soil and to practice their religion and customs and this marked the beginning of a new community and religion in the land of America. The migrant Jews assimilated into the culture of Native Americans in all aspects of life. In other words, they had to imbibe the basic characteristics of the American community as forming distinctiveness was not possible challenging the customs of the natives. All together, the modern Jewish culture in America embodies an international culture of secular communities of Jewish people and the indigenous practices of the natives. Jews continued migrating to America on realizing it was a secure place for them. During the middle decades of the 19th century, there were considerable

Whos afraid of sigmund Freud Essay Example | Topics and Well Written Essays - 500 words

Whos afraid of sigmund Freud - Essay Example He is no longer thought of as scientific or serious. He is mostly a cartoon character who speaks in a thick German accent while chomping on a cigar. People tend to believe stereotypes about him, such as that he believed childhood trauma was the reason for all problems in adulthood. The author of this article seeks to defend Freud from some of these claims, and to a certain extent succeeds. To be fair to Freud, it is important to recall the time period he was living and writing in. Very little was known about psychology. He was the founder of this discipline. Many of his ideas were educated guesses based on conversations with patients and scientific study he undertook. There were bound to be errors. Few psychologists today would have been anywhere near as successful as Freud was if they had to operate under the same conditions. Even today, his basic concepts are accepted, as Hustvedt writes, â€Å"No neuroscientist today would say that the unconscious does not exist, nor would he or she say that we do not have implicit memories (memories outside of consciousness.) No one working in the field would argue against primal emotional drives in human beings either.† It is clear that he has a continuing influence, even if it is not as large as it once was. That is not to say Freud was not wrong on many fronts. Much of his thinking about sex is outdated. But all things considered, he was a genius who deserves our respect. An important subject he studied that is very relevant today is the relationship between patient and therapist. He immediately saw the danger of too close an attachment and warned that therapists must watch their feelings closely in these encounters.

Are GM crops the state of the art of intensive agriculture or a step Essay

Are GM crops the state of the art of intensive agriculture or a step too far Discuss with reference to the conservation of nature - Essay Example ild species of plants such as corn or blueberries, then you will notice that their fruit is much smaller than that of varieties sold in the local grocery store (p.9). The reason for this difference in size he explains is that for centuries, farmers have sought to improve the size –and other characteristics- of the crops they grow. This allows them to produce a greater volume of food per acre of land, and it produced more food to feed people. GM foods have been around for much longer than most people know, in fact in the U.S, and 30% of Americans have been eating food made from GM crops since the year 1998 when the first Flar-Savr Tomato was introduced into the U.S supermarkets. Still, even with hundreds of millions of people around the world eating GM foods for more than a decade, controversy over the use of this technology remains very high all over the world (Diehl Paul 2014:1). This controversy is mostly fired up by the fact that GM foods were released into the market without the public knowledge. The Real Truth Magazine (2014), states that several reasons as to why the GM food issue has remained a huge topic for discussion and controversy around the world (p. 1-2). Biotech corporations market their products by selling the idea that they are ideal solutions to nutrition, world hunger and the environment yet all these foods have managed to do to attract speculations and fear about their possible side effects to the hu man race. To further explain this, The Real Truth Magazine lists these areas of controversy; Producers of GM crops claim that their genetically altered crops are more nutritious than natural crops. The promoters of ‘Golden Rice’ said that this rice was more superior to natural rich in vitamin A among other nutrients. After several tests, this rice was discovered to be inferior to natural rice. This lie was uncovered by Ticciati and Ticciati (1998), the authors of â€Å"Genetically Engineered Foods: Are They Safe? You Decide." They present

Elemental Cost Plan for Commercial Office Development Research Paper

Elemental Cost Plan for Commercial Office Development - Research Paper Example Total steel/ metal required is approximated to be around 300 kgs .This done taking into consideration that CPA is 951.6 sq.mtr .Labor cost is assumed to be 16 pounds/ sq.mtr for entire work. Equipment charges are assumed to be around 3000 pounds Material cost = 400 x 30=12000 pounds Labor charges = 16 x 951.6=15225.6 pounds Total cost = 12000 + 15225.6 +3000=30225.6 pounds Total masonry and concrete required per sq.mtr is assumed to be 0.6 kgs per sq.mtr. Labour charges for entire work are assumed to be around twice the material required. Material cost = 0.6 x 951.6 x (64 +5) =39,396 pounds Labor charges = 2 x 39396 = 78792 pounds Total cost = 39396 + 78792 =118188 pounds Total area to be insulated is approximately around 1000 sq m. This includes all external walls .The area is calculated from the available drawings. The rate of insulating material is taken 8 pounds /sq.mtr from the above table. Labor charges are taken to be around 4000 pounds for above project. Total cost = 8 x 1000 +4000=12000 pounds Total number of doors of ground floor = 32 No of doors on first floor =25 ... Insulation :- Total area to be insulated is approximately around 1000 sq m. This includes all external walls .The area is calculated from the available drawings. The rate of insulating material is taken 8 pounds /sq.mtr from the above table. Labor charges are taken to be around 4000 pounds for above project. Total cost = 8 x 1000 +4000=12000 pounds Doors and windows:- Total number of doors of ground floor = 32 No of doors on first floor =25 Number of windows = 53 Wood work rate is 114 pounds / sq mtr. Assuming 100 pounds are required to make one door and 100 pounds to make one window. These include material and labor charges. Total cost = 55 x 100 + 53 x 100 = 10,800 pounds. Exterior trim and finish:- Total exterior area is approximately 480 sq. mtr. Material rate is assumed to be 50 pounds/sq.mtr Labor rate is taken as 27 pounds / sq.mtr. Material cost = 480 x 50=24000 pounds Labor charges = 480x 27=12960 pounds Total cost = 24000 + 12960 =36960 pounds Gable roof rafters, Gable roof trusses, Gable roofing:-Total roof area is calculated and comes out to be 415 sq.mtr approximately. The rate is from the table is 37 pounds /per sq.mtr. pounds for gable roof rafters, roof trusses and roofing.

The relationship between censorship and student publications Essay Example for Free

The relationship between censorship and student publications Essay Pushing the limits of free speech and then killing it is not an uncommon theme for todays student press. Civil disobedience and censorship of student publications has been a hot-button issue since the 1960s and remains a crucial, yet under-examined area of free speech. In an assumed tolerant democracy which flaunts philosophical ideals like a free market of ideas, censorship laws have undermined the essential function of student newspapers as an outlet for challenging, insightful and investigative journalism. The following essay seeks to examine the relationship between censorship and student publications by specifically drawing on the Rabelais case. Accordingly, this essay further attempts to explore the legal and philosophical reasoning behind censoring student newspapers. In 1998, the Full Court of the Federal Court handed down its first decision which directly involved the right to political communication of a student publication1. The court held that an article advocating theft published in the La Trobe University student publication, Rabelais, instructed in matters of crime and was not protected by the implied constitutional freedom of speech.2 The appellants four editors of the publication argued that the article addressed issues of wealth distribution in a capitalist society and constituted political communication.3 Prior to Rabelais, Australian courts have never squarely confronted political communication in relation to the National Classification Code.4 Whilst the Federal Courts decision to uphold the findings of the Classification Review Board generated another proponent of control on the boundaries of political communication, it simultaneously limited the journalistic scope of student publications in challenging the moral and political patterns of society. The implications of Rabelais have since posed an explicit threat to the autonomy of student publications by which student journalists are left confined within the legally permissible censorship system.5 A common principle validating restrictions on free speech is balancing. In the case of Rabelais and similar articles in nature published in other student publications, striking a reasonable balance between political material and Australias censorship laws fosters the argument that the protection of political communication is not absolute. Judicially-considered concepts underpinning political communication6 is often subject to the maintenance and protection of the system of representative government.7 By strict adherence to this generalization, virtually all political dissent and civil disobedience is then liable to interfere with the maintenance and protection of the government system. Heerey J8 provided further insight, claiming this relationship to accommodate an imbalance in which the protection of representative democracy overrides the protection of dissent9 by student publications: It should be noted that Anarchist theory extended from non-violent writers and political leaders like Tolstoy, Thoreau and Ghandi to Proudhon (property is theft) the Anarcho-Syndicalists whose creed was that unions should become militant organizations dedicated to the destruction of capitalism and the state. All this may be in one sense politics, but the Constitutional freedom of political communication assumes indeed exists to support, foster and protect representative democracy and the rule of law. The advocacy of law breaking falls outside this protection and is antithetical to it. 10 However, the argument brought forward by his Honour is severely flawed. The knowledge needed to draw political comparisons from the works of Tolstoy, Thoreau and Ghandi lies in the mere fact that the writings of these revolutionaries were not refused classification, but available to the public for debate and reflection. In this instance, measuring competing interests on the basis of political ideologies in power would easily translate into banning all commonly dissenting student publications.11 The classic role of student publications in discussing socio-political affairs beyond the bounds of moral and legal civility is one which indeed supports, fosters and protects the system of representative democracy. This lends itself to another critical failure in determining classification of student publications. In refusing classification of Rabelais, the Review Board directly addressed the legal aspect of inciting crime, compromising the publications implied rights to political communication.12 It did so by appraising the article in isolation from other writings of political nature, published in the same edition.13 Setting aside possible constitutional questions, the approach in reviewing student publications does not distinguish between student and mainstream media. If a student press is to function as the dutiful outlet of alternative and challenging thought in society, then such definition should allow for exceptional free speech privileges. To give further reference to the limited interpretation of the role of student publications in Australia, there is a high probability that the article in question would have been permissible to publish in other countries, particularly the United States. Not only does the existence of a U.S. Bill of Rights expressly protect the rights of individuals to free speech, but an implicit rule applied by U.S. courts entitles student journalists to the highest level of First Amendment protection to sustain the traditional libertarian function of student publications. 14 The rule that student publications enjoy freestanding exemptions of restrictions underlying the First Amendment emanates from legislation based in the state of California, which expressly duplicates First Amendment rights to college and university students. 15 One can hardly ignore the advantageous effects of a similar law being implemented in Australia. Like the United States, it is widely maintained that student publications in Australia should remain wide-open free speech zones, where every form of speech is permitted and censorship controls are turned off.16 However, the recent introduction of the Voluntary Student Unionism bill17 before parliament has additionally threatened the agenda of student publications. Although the bill, which traces back to 197418, sets out to render universal student unionism voluntary, it could potentially be the first law that directly undermines students right to free speech by defunding Australias student press19. The Western Australian (WA) VSU model, which came into force in 1997, has cut funds directed to all student publications in the state, while other student advocacy bodies were lost completely.20 In conclusion, although Australia has a robust commitment to freedom of speech, on a practical level, this commitment is too often regulated by prevailing moral and legal protocols. As evidenced by the legal implications brought forward by the Rabelais case, there remains little conscious acknowledgement of the significant function of student media in challenging dominant viewpoints. Given the undoubted importance of the court in interpreting political communication, the process in determining such can only be rendered valid and objective if the historical and philosophical principles underpinning student media are taken into consideration. The burden here is not only on the narrowed definition of political communication, but the lack of an accountable and tolerant classification system. Similarly, the Rabelais case reawakens the time-worn argument of implementing an express free speech right in Australia. Given that student publications are dedicated to political dissent and civil disobedience, and thus vulnerable to legal ramifications, it would arguably seem fair to grant student media the privilege of special free speech rights, over and above all the general speech rights Australians enjoy. A law similar to that of the United States would allow society to recognize the doctrine of academic freedom and protect and maintain the free market of ideas in a representative democracy. As Parsons once said: The creative writer should enjoy a latitude greater than would be of proper to the journalist and newspaper published who deal with fact.21 1 Brown v Members of the Classification Review Board of the Office of Film and Literature Classification (1998) 154 ALR 67 (hereinafter Rabelais) 2 The article provided a step-by-step guide on how to shoplift. Pursuant to the Classification (Publication, Films and Computer Games) Act 1995, publications that describe, depict, express or otherwise deal with matters of crime will be refused classification 3 Note 1. The Federal Court upheld the decision of the Chief Censor to refuse classification (i.e. ban) of Rabelais. The charges were later dropped. 4 Clayton, M. (2005). Interview. [Interview with Christopher van Opstal, 24/05/2005]. See also Classification (Publication, Films and Computer Games Act) Act 1995 5 Boey, H. (2005). Interview. [Interview with Christopher van Opstal, 19/05/2005]. Duncan, J. (2005). Interview. [Interview with Christopher van Opstal, 19/05/2005]. Fomiatti, L. (2005). Interview. [Interview with Christopher van Opstal, 19/05/2005]. Belford, A. (2005). Interview. [Interview with Christopher van Opstal, 19/05/2005]. 6 For example, in Australian Capital Television v The Commonwealth (1992) 177 CLR 106, six members of the High Court acknowledged the implied freedom of communication in government and political matters. Other judicially-considered cases in Rabelais, include Theophanous v Herald Weekly Times (1994) 182 CLR 104; Lange v Australian Broadcasting Commission (1997) 189 CLR 520; Levy v The State of Victoria (1997) 189 CLR 579 7 Pearson, M. (2005). Interview. [Interview with Christopher van Opstal, 23/05/2005] 8 French J and Sunberg J were the two other judges in Rabelais 9 Heerey J refers here to dissent as writings which advocate breaking the law or anarchy 10 Note 1 (Heerey J). By contrast, the appellants council argued that advocating theft was an appropriate means of reallocation of resources of political dissent or as a central tenet of Anarchist theory. The same argument is brought forward by Des Clark, Chief Censor of Australia. Clark, D. (2005). Interview. [Interview with Christopher van Opstal, 26/05/2005] 11 Clark, D. (2005). Interview. [Interview with Christopher van Opstal 26/05/2005]. Clayton also points out that a publication which incites crime must be banned under regulations by the OFLC, even though the publication may be of political nature. Note 4. 12 Note 4. See also Clayton, M. 1998 Censorship, Free Speech and the Rabelais Case, Legal Date, Vol. 10, No 1.; Clayton, M. and Borgeest, T. 1998, Free Speech and Censorship after the Rabelais Case, Media and Arts Law Review, Vol. 3 at 194 13 Note 1. The Rabelais edition also discussed political issues of death penalty in the United States and pending execution of a former black activist, Mumia Abu Jamal 14 Goodman, M. (2005). Interview. [Interview with Christopher van Opstal, 23/05/2005] 15 Pursuant to s 76120 of the California Education Code, the governing board of a community college shall adopt rules and regulations relating to the exercise of free expression by students. See California Education Code Section 66301. 16 Boey, H. (2005) Interview. [Interview with Christopher van Opstal, 19/05/2005] 17 Higher Education Support Amendment (Abolition of Compulsory Up-front Student Union Fees) Bill 2005 18 Aldrich, F. (2005). Interview. [Interview with Christopher van Opstal, 27/05/2005] 19 Note 13. If impending VSU is passed by the Senate in July, it will be necessary to cut funds to the printing of student publications. This will result to the disappearance of most student publications. 20 Hastings, G. (2004) VSU Legislation Experiences in WA, Victoria, and Federally, NUS Research at 5 21 Pollak, M. 1990, Sense and Censorship, Reed Publishers, Sydney, at p. 284

Movie Review Of Fargo Film Studies Essay

Movie Review Of Fargo Film Studies Essay Fargo, the first time that I heard that name, I could not see how the name had anything to do with the movie. At first I thought maybe it was the name of a character in the movie but after watching the movie I came to learn that it was the mane of where most of the movie was based around; Fargo North Dakota. Fargo is a 1996 movie done by the Coen Brothers. This movie is also based on a true story which, after you watch it, you feel terrible for the victims. I would say that this movie is a dark comedy. I say this because the plot and the form of the movie have this dark but comedic aspect. The Brainerd accents have a very unthreatening way to the way it is used and due to the innocence of the accents; it throws off the seriousness of the situation. A main character in the film who gives off more of a comedic aspect is the seven month pregnant chief of police from Brainerd Minnesota Marge Olmsted. I doubt the director(s) were going for a comedic aspect to the film, but with the accent s, and constant use of the word Yaa, you couldnt help but laugh occasionally. The movie Fargo is about a nerdy, mild mannered, shady Executive car salesman named Jerry Lundergard who falls heavily into unexplained debt and comes up with a seemingly genius idea to hire some criminals to kidnap his wife. The reason for the pre conceived kidnap is to retrieve a ransom for her safe return, and get the money from her father who is a wealthy businessman. In the process of Lundergard and his accomplices going forth with their plan, things start to get out of control and eventually Marge Olmsted, the Brainerd Minnesota chief of police gets involved and starts investigating three coincidental murders that occur in her city. Marges character is a likeable polite character who seems after a while to be one of the only competent people in the whole town. The main characters in this film to pay attention to were Jerry Lundergard; a seemingly unstable character, he is shown to be desperate and insecure and there was even a scene after his wife was kidnapped where he practic es his distress call to make it seem believable. Predictably, as the murder investigation broadens and starts to lead back to him, he starts to break down emotionally. Throughout the movie they never explained what exactly his debt was for. Marge Olmsted; Brainerd Chief of police; Carl plays the small time crook who is described literally as the smaller, funny looking kind of guy by all those who came in contact with him and lived. Carl is a very talkative and vulgar kind of guy but seems to have some emotion for murder. His partner on the other hand, Gaer is of European decent. Seemingly quiet but composed character although he commits most of the murders showed in the film. He is a heavy smoker and is shown until towards the end to be more like Carls back up with muscle. This movie housed a couple of big named actors of their time. Some of which I know to still be in the acting business. Carls character and Jerrys character were played by Steve Buscemi, and William H. Macy, which to me, were the only two recognizable stars in the movie. Carl is known for such movies as Reservoir Dogs, and William is known for movies like Cellular, Wild Hogs, and Thank You for Smoking. This movie does a good job in showing the gender role differences in Marges growing family. In her introduction scene where she and her husband first come into the picture, they show how the gender roles are reversed. Usually, it would be the man who is the chief of police and his wife is the stay at home parent who takes care of the backup stuff. In the Olmsted household, Marges husband Norm is the reversed gender role character. He is never shown to be at work or ever even doing any kind of work for that matter, and she is the one with the seven month pregnancy. He makes her breakfast in the morning, brings her lunch to work, and always talks about his painting but somehow their relationship seems to work. Marge is also shown to have a pretty big appetite which is totally understandable due t o the fact that she is eating for two and always makes the joke can I have a seat?, I;m carrying quite a load here. The movie as based on true events starts to get a lot darker and grittier than the expectations of a dark comedy. The ransom exchange scene where the father gets killed semi brutally is a turning point of how serious and out of control things got; He was shot numerous times unnecessarily, and even the ending scene where the European criminal is shown grinding up his partner in a wood chipper and blood is being sprayed everywhere. This movie did not rely on scenery or music to help tell the story. In fact, the scenery was mostly white and snowy because it seemed to be shot in the winter time. There was music, but the music was not done in such a way that it would give away parts of the story. The directors claim that out of respect for the dead, the film was depicted as is. Names were changed though to protect the identities of those who survived. Overall, this movie wa s beyond my expectations but still was able to hold my interests enough for me to really enjoy the movie while giving my regards to those who unfortunately lost their lives.

How Charles Dickens’ Life Influenced Oliver Twist Essay -- essays pape

How Charles Dickens’ Life Influenced Oliver Twist â€Å"The range of his creative activity is, in the first place, limited to the world of his youth† (Cecil 169). This quote explains many people. What has previously happened to a person has a tremendous impact on them. It can affect their decisions, emotions, and life. The life of a person can sometimes be seen quite easily through what they do. Artists often reveal what their life has been like through the works that they create. The same can be said about writers. Events in authors past often show up in his works. The above quote is, in fact, made in regard to Charles Dickens. Dickens had several real life experiences of poverty and abandonment in his life that influenced his work, Oliver Twist. The times of poverty and abandonment in Charles Dickens’ life instilled a political belief in Dickens’ mind against the new poor laws of Great Britain. Dickens’ felt the new poor laws victimized the poor, failed to give the poor a voice, and were in need of change. These points are shown in Oliver Twist through the characters, scenes, and narration Dickens’ uses throughout the book. Dickens lived a life full of events that would later influence his novels. Dickens grew up during a time of change for Great Britain. By the time he was born in 1812, the Industrial Revolution was in full force. Dickens grew up as a normal middle-class child in Portsmouth, Great Britain. It was around the age of twelve that his life took a drastic turn. Dickens was still a child when his father was imprisoned for debt. Families, at this time, lived with the father in prison. Charles did not live in prison, though. Instead, he was sent to live alone and become a laborer at Warren’s Blacking Facto... ...r Twist† The Immortal Dickens. London, 1925. 63-87. Rpt in Oliver Twist. Ed. Fred Kaplan. New York: Norton & Company, 1993. Skim Greene, Graham. â€Å"The Young Dickens.† Collected Essays. 1969. Rpt. in Nineteenth Century Literary Criticism, Vol. 3. Ed. Laurie L. Harris. Detroit: Gale Research Company, 1983. Pg. 176. MacKenzie, Jeanne. Dickens, A Life. USA: British Library Cataloguing in Publication, 1979. Skim. Murray, Brian. Charles Dickens. New York: Continuum, 1994. Skim Paroissien, David. Letter to Noah Laible, 15 Feb 2000. Taine, Hippolyte A. History of English Literature, Vol 4. New York: Frederick Ungar Publishing Co., 1965. Pg. 117-163. Wall, Stephan. â€Å"The Letters of Charles Dickens, 1856-1858.† Essays in Criticism 47.1 (1997): 78-87. Wills, Garry. â€Å"Love in the lower depths.† The New York Review of Books 26 Oct 1989: 60-68.

Gothic Cathedrals :: Europe European Architecture Essays

Gothic Cathedrals For nearly four hundred years Gothic style dominated the architecture of Western Europe. It originated in northern France in the twelfth century, and spread rapidly across England and the Continent, invading the old Viking empire of Scandinavia. It confronted the Byzantine provinces of Central Europe and even made appearances in the near East and the Americas. Gothic architects designed town halls, royal palaces, courthouses, and hospitals. They fortified cities and castles to defend lands against invasion. But it was in the service of the church, the most prolific builder of the Middle Ages, that the Gothic style got its most meaningful expression, providing the widest scope for the development of architectural ideas. Although by 1400 Gothic had become the universal style of building in the Western world, its creative heartland was in northern France in an area stretching from the royal domain around Paris, including Saint-Denis and Chartres, to the region of the Champagne in the east and southward to Bourges. Within this restricted area, in the series of cathedrals built in the course of the 12th and 13th centuries, the major innovations of Gothic architecture took place. The supernatural character of medieval religious architecture was given a special form in the Gothic church. "Medieval man considered himself but an imperfect refraction of Divine Light of God, Whose Temple stood on earth, according to the text of the dedication ritual, stood for the Heavenly City of Jerusalem."3 The Gothic interpretation of this point of view was a cathedral so grand that seems to belittle the man who enters it, for space, light, structure and the plastic effects of the stonework are made to produce a visionary scale. The result of the Gothic style is distortion as there is no fixed set of proportions in the parts. Such architecture did not only express the physical and spiritual needs of the Church, but also the general attitude of the people of that time. Gothic was not dark, massive, and contained like the older Romanesque style, but light, open, and aerial, and its appearance in all parts of Europe had an enduring effect on the outlook of succeeding generations. Gothic architecture evolved at a time of profound social and economic change in Western Europe. In the late eleventh and twelfth centuries trade and industry were revived, particularly in northern Italy and Flanders, and a lively commerce brought about better communications, not only between neighboring towns but also between far-distant regions. Politically, the twelfth century was also the time of the expansion and consolidation of the State.

Sophocles’ Oedipus Cycle †Antigone, as a Feminist Essay -- Antigone E

Sophocles’ Oedipus Cycle – Antigone, as a Feminist Throughout history, women have always stood in the shadows of men. In many cultures, the role of women has always been to be seen and not heard. As one of the first feminists in world literature, the character Antigone, of Sophocles’ Oedipus Cycle, displays fine characteristics of a great female leader in order to stand up against male dominance for her religious, political, and personal beliefs. When the king denies her brother, Polynices, proper burial, Antigone goes against state law by burying him herself in order to protect heavenly decree and maintain justice. In doing this, she steps out of her place as a woman in a male dominated society. In order to characterize Antigone as a feminist, it is important to study Antigone’s early childhood, which displays the origins of the characteristics found in her that make her a feminist. In Oedipus of Colonus, Sophocles illustrates these qualities that Antigone possesses. During the first twenty years of her life, Antigone spends her time secluded from society with her blind, exiled father, Oedipus. Sophocles sums up her childhood in the following soliloquy by Oedipus: "Since her childhood ended and her body gained its power, has wandered ever with me, an old man’s governess; often in the wild forest without shoes, and hungry, beaten by many rains tired by the sun; yet she rejected the sweet life of home so that her father should have sustenance" (Fitts 104). Because she is secluded, Antigone never has to take her place in society as a woman. Without a female role model to show her how a woman is supposed to act, there is no one to raise her as a woman. She spends her days taking care of her blind father and leading him. Sh... ...Creon, when she kills herself causing Creon to lose. Creon at this point has caved in by deciding to bury Polynices and free Antigone, but it is too late. She dies an honorable death for future feminists. Since Sophocles wrote Antigone, there have been thousands of literary works about feminists and their movement to let their voices be heard over men. Through her strong will and bravery, Antigone made her political, religious, and personal beliefs seen. She died in order to win against men even when no one else would stand up to male dominance. For these reasons, Antigone is a prime example of a great feminist in world literature. Works Cited Fitts, Dudley and Robert Fitzgerald. The Oedipus Cycle. Trans. Sophocles. Florida: Harcourt Brace & Company, 1977. Sophocles. â€Å"Antigone.† Literature and the Writing Process 5th ed. New Jersey: Prentice Hall. 1999.

South-Western Federal Taxation: Comprehensive Volume

CHAPTER 21 PARTNERSHIPS SOLUTIONS TO PROBLEM MATERIALS | | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | | LO 1Partnership definitionNew 2LO 2General partnership versus LLCNew 3LO 1Check-the-box regulationsNew 4LO 2Partnership tax reportingModified1 5LO 2Analysis of Income scheduleModified1 6LO 2Partnership Schedule M-3New 7LO 3Special allocationsNew 8LO 3Capital accountsNew 9LO 3Inside versus outside basisNew 10LO 4Comparison of corporate and partnershipUnchanged2 treatment 11LO 4Application of  § 721New 12LO 4Exceptions to  § 721New 13LO 4Disguised sale issue recognitionUnchanged4 14LO 5Initial costs of a partnershipNew 15LO 6Cash accounting method for partnershipsNew 16LO 7Economic effect testUnchanged8 7LO 8Adjustments to partner’s basisUnchanged9 18LO 8Liability allocations to basisUnchanged10 19LO 10Guaranteed paymentsNew 20LO 8, 9, 14Partnership advantages and disadvantagesUn changed12 21LO 4, 6, 7,Partnership formation and operationsUnchanged13 8, 9, 10issues 22LO 11Basis in distributed propertyUnchanged14 23LO 11Distribution ordering rules; liquidatingNew versus nonliquidating distributions 24LO 11Conceptual: tax results of distributionsNew 25LO 12Ramifications of sale of a partnership interestNew Instructor: For difficulty, timing, and assessment information about each item, see p. 1-4. | | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | | 6LO 4Formation of partnership; inside and basisUnchanged15 27LO 4, 14Formation of partnership; inside and outsideUnchanged16 outside basis 28LO 4Contribution of various properties onUnchanged17 formation of a partnership; basis and depreciation 29LO 4Formation of a partnershipNew 30LO 4Formation of a partnershipNew 31LO 4, 8, 14Basis of property received as gift; receipt Modified19 of interest for services 32LO 8, 14Planning fo r service interestsNw 33LO 4, 10, 14Disguised sale versus distributionUnchanged20 *34LO 4, 7Treatment of contributed propertyNew 5LO 5Tax issues related to formation ofUnchanged5 partnership 36LO 4, 5, 6,Preparation of initial LLC tax returnUnchanged6 37LO 6Accounting methodsUnchanged7 *38LO 5Definition of organization costs;Unchanged21 amortization of organization costs *39LO 6Computation of partnership’s required taxUnchanged24 year under the least aggregate deferral method 40LO 4, 7Date basis of partner’s interest; gain on saleUnchanged25 of contributed land with precontribution built-in gain 41LO 7Date basis of partner’s interest; loss on saleUnchanged26 of contributed land *42LO 7, 8Computation of partner’s outside basis atModified27 beginning and end of year when several transactions took place *43LO 7, 8Partnership income; partner’s basis;Modified28 separately stated items; guaranteed payments 44LO 7, 8, Partnership income; partner’s basis; lossModified29 10,limitations; guaranteed payments 45LO 4, 7, 8Partnership’s income and separately statedUnchanged30 items; partner’s basis and amount at risk 6LO 4, 7, 8Same as Problem 45 for an LLCModified31 47LO 7, 8, 9,Basis and loss limitationsUnchanged32 *48LO 4, 7, 8,Allocations under  § 704(b)Modified33 9 49LO 7, 8, 9Allocation of gain under  § 704(b)Modified33 50LO 7, 8, 9Allocations to partner; basis in interest; Unchanged34 loss limitations 51LO 8Allocation of recourse debtUnchanged35 52LO 4, 8Sharing recourse debt for basis purposesUnchanged36 Instructor: For difficulty, timing, and assessment information about each item, see p. 21-4. | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | | 3LO 8, 9, 14Basis calculations and loss limitationsUnchanged11 54LO 8, 9Loss disallowance under  § 704(d),  § 465,Unchanged37 and  § 469 55LO 7, 10Timing of recognition of guaranteedModified38 payments 56LO 10Timing of recognition of guaranteed New payments, continued *57LO 7, 10Comparison of C corporation salary versus Unchanged39 partnership guaranteed payment 58LO 10Disallowed  § 267 loss from sale of propertyUnchanged40 to partnership by partner; conversion f capital gain to ordinary income from sale of investment property to partnership by partner 59LO 11Nonliquidating distribution; basis of New assets distributed (limited); partner’s outside basis 60LO 11Nonliquidating distribution; basis of New assets distributed (limited); partner’s outside basis *61LO 11Nonliquidating distributions; amount andModified43 nature of gain or loss; basis of assets distributed; partner’s outside basis *62LO 11Allocation of basis to multiple assetsUnchanged44 distributed 3LO 11Effect of change in partner’s share of New liabilities; nonliquidating versus liquidating distributions 64LO 11Results of various liquidating distributionsUnch anged45 65LO 12Sale of partnership interest; amount andModified46 nature of gain or loss; basis of new partner’s interest; election to adjust basis of partnership property *The solution to this problem is available on a transparency master. Instructor: For difficulty, timing, and assessment information about each item, see p. 21-4. | | | |Status: | |Q/P | | Research | | | |Present | |In Prior | |Problem | |Topic | |Edition | |Edition | | | | | | | | | 1Economic effect allocationsUnchanged1 2Allocation of liabilitiesNew Internet activityUnchanged3 | | |Est'd | |Assessment Information | | |Question/ | |completion |AICPA* | AACSB* | |Problem |Difficulty |time |Core Comp | Core Comp | | | | | | | | | | 2 |Easy | |10 |FN-Reporting |Analytic | | 3 | |Easy | |10 |FN-Reporting |Analytic | | 4 | |Easy | |10 |FN-Reporting |Analytic | | 5 | |Medium | |10 |FN-Reporting |Analytic | | 6 | |Medium | |10 |FN-Reporting |Analytic | | 7 | |Easy | |10 |FN-Reporting |Analytic | | 8 | |Medium | | 10 |FN-Reporting |Analytic | | 9 | |Easy | |10 |FN-Reporting |Analytic | | 10 | |Medium | |10 |FN-Reporting |Analytic | | 11 | |Easy | |10 |FN-Reporting |Analytic | | 12 | |Medium | |10 |FN-Reporting |Analytic | | 13 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 14 | |Medium | |10 |FN-Reporting |Analytic | Reflective Thinking | | 15 | |Medium | |10 |FN-Reporting |Analytic | | 16 | |Easy | |10 |FN-Reporting |Analytic | | 17 | |Easy | |10 |FN-Measurement |Analytic | | 18 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 19 | |Easy | |10 |FN-Reporting Analytic | | 20 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 21 | |Medium | |15 |FN-Reporting |Analytic | | 22 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 23 | |Easy | | 5 |FN-Measurement | FN-Reporting |Analytic | | 24 | |Easy | | 5 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 25 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 26 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 27 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 28 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 29 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 30 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 31 | |Hard | |15 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | | |*Instructor: See the Introduction to this supplement for a discussion of using AICPA and AACSB core competencies in assessment. | | 32 | |Medium | |10 |FN-Reporting |Analytic | Reflective Thinking | | 33 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 34 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 35 | |Medium | |10 |FN-Measurement | FN-Reporting Analytic | Reflective Thinking | | 36 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 37 | |Medium | |10 |FN-Repo rting |Analytic | | 38 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 39 | |Medium | |10 |FN-Reporting |Analytic | | 40 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 41 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 42 | |Medium | |20 |FN-Measurement | FN-Reporting |Analytic | | 43 | |Hard | |15 |FN-Measurement | FN-Reporting |Analytic | | 44 | |Hard | |15 |FN-Measurement | FN-Reporting |Analytic | | 45 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 46 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 47 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 48 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 49 | |Hard | |10 |FN-Measurement FN-Reporting |Analytic | | 50 | |Hard | |15 |FN-Measurement | FN-Reporting |Communication | Analytic | | 51 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 52 | |Hard | |15 |FN-Measurement | FN-Reporting |Communication | Analy tic | | 53 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 54 | |Hard | |15 |FN-Measurement | FN-Reporting |Communication | Analytic | | 55 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | | |*Instructor: See the Introduction to this supplement for a discussion of using AICPA and AACSB core competencies in assessment. | 56 | |Medium | |10 |FN-Reporting |Analytic | | 57 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 58 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 59 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 60 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 61 | |Medi m | |10 |FN-Measurement | FN-Reporting |Analytic | | 62 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 63 | |Medium | | 5 |FN-Measurement | FN-Reporting |Analytic | | 64 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 65 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | | |*I nstructor: See the Introduction to this supplement for a discussion of using AICPA and AACSB core competencies in assessment. | CHECK FIGURES 26. a. $0; $0. 26. b. $200,000. 26. c. $100,000. 26. d. $100,000 basis in property. 27. a. ($15,000) realized; $0 recognized. 27. b. $60,000. 27. c. $75,000. 27. d. $75,000. 27. e. Sell and contribute cash. 28. a. $20,000 on land; $60,000 on equipment. 28. b. No gain under  § 721. 28. c. Carol $70,000; Connie $30,000. 28. d. $40,000 basis in land; $30,000 basis in equipment. 28. e. Inside = Outside = $100,000. 28. f. Partnership continues Connie’s depreciation schedule. 29.No gain or loss to Justin, Tiffany, or partnership; Justin’s basis $85,000; Tiffany’s basis $125,000; partnership’s basis in land $65,000; partnership steps into Tiffany’s shoes for depreciation. 30. Tiffany recognizes $25,000 loss on sale; basis is $100,000. Partnership must spend additional $10,000 to acquire assets. 31. a. $0. 31. b. $ 50,000. 31. c. $25,000 ordinary income. 31. d. $75,000. 32. b. Contribute ‘‘property’’ of ‘‘permits’’ and ‘‘development plan’’ completed before contribution. 33. a. Distribution. 33. b. $0 gain or loss. 33. c. $50,000. 33. d. Disguised sale. 33. e. $16,667. 33. f. $66,667. 34. a. Rachel $360,000; Barry $600,000. 34. b. 170,000 ordinary income. 34. c. $100,000 capital loss and $20,000 ordinary loss. 35. Organization costs $10,000 (deducted); start-up costs $60,000 (amortized over 180 months); property acquisition costs $24,000 (added to property basis; depreciated as newly acquired asset); syndication costs $1 million (nondeductible). 36. Issues include partnership year end; partnership accounting method; treatment of initial costs; partners’ bases in LLC interests; LLC’s basis in property received on formation; interests issued in exchange for services; built-in gain on later sale of land. 37 . BR can use cash, accrual, or hybrid method in 2008, 2009, and 2010.In 2011 and later years, BR may no longer use cash method. 38. a. Organizational costs: $8,000; syndication costs $10,000. 38. b. $5,000 deduction plus $50 amortization of organization costs. 38. c. 180-month amortization. 39. January 31. 40. a. $75,000. 40. b. Five years. 40. c. $15,000 gain. 41. a. $36,000 loss; $30,000 to Reece and remaining $6,000 allocated equally among partners. 42. a. $160,000. 42. b. $230,000. 43. a. $42,000; qualified dividends $4,000. 43. b. $29,000 basis. 43. c. $22,000 basis. 44. a. ($18,000); qualified dividends $4,000. 44. b. $0 basis; $8,000 loss deductible currently, $1,000 suspended. 44. c. $0 basis; $1,000 loss allowed; $8,000 suspended. 45. a. 175,000 (Celeste); $125,000 (Ernestine). 45. b. Ordinary income $80,000; qualifying dividend $3,000; tax-exempt interest $1,000; charitable contribution $500; distribution to Celeste $20,000. 45. c. $283,500 basis and at-risk amount. 46. a. Accounts payable are nonrecourse for LLC. 46. b. $283,500 basis; $233,500 amount at risk. 47. a. $24,000. 47. b. $4,000. 47. c. $0. 47. d. $4,000. 47. e. Don can contribute capital or partnership can incur debt. 48. a. Year 1—Fred $49,600; Manuel $78,400. Year 2—Fred $960; Manuel $75,840. 48. b. Yes. 49. a. Gain $43,200 allocated equally. Basis—Fred $22,560, Manuel $97,440. 49. b. Fred’s cash $22,560; Manuel’s cash $97,440. 49. c.Tax savings now or cash later; not both. 50. Deduct $54,000 of loss unless basis increased before year-end. 51. Melinda $6,000; Gabe $6,000; Pat $18,000. 52. Paul $160,000; Anna $80,000. 53. a. Basis adjustment rules per Figure 21. 3; then loss limitation rules [ § 704(d),  §Ã‚  465, then  § 469]. 53. b. $5,000 gain, $0 basis. 53. c. No loss deduction. 53. d. Make distribution next year so Brad can deduct loss this year. Partnership can incur additional debt. 54. $48,000 deducted. $14,000 suspended— § 704(d ); $8,000 suspended— § 469. 55. a. $70,000 in 2010, incl. guaranteed payment. 55. b. $25,000 in 2010. 56. $70,000. 57. a. $55,000 salary in 2010. 57. b. 0 in 2010; $40,000 partnership income and $60,000 guaranteed payment in 2011. 58. a. $0. 58. b. $10,000. 58. c. $80,000 gain; may be ordinary. 59. a. $0. 59. b. $0. 59. c. Inventory $60,000; land $75,000; partnership interest $185,000. 60. a. $0. 60. b. $0. 60. c. Account receivable $0; land $20,000; partnership interest $0. 61. a. $15,000 gain and basis in partnership interest $0; partnership $0 gain. 61. b. Land $30,000 basis and basis in partnership $10,000; partnership $0 gain. 61. c. No gain or loss; land basis $12,000; basis in partnership interest $0. 61. d. $10,000 gain; $0 basis in inventory; $0 basis in partnership interest. 62. a. No gain or loss. 62. b. 6,000 in item 1 and $3,000 in item 2. 63. a. Inventory basis $10,000; basis in partnership interest $20,000. 63. b. Recognized loss $20,000; Inventory basis $10, 000. 64. a. $15,000 capital gain. 64. b. No gain or loss; $40,000 basis. 64. c. No gain or loss; inventory $10,000; capital asset $22,000. 64. d. $0 basis in accounts receivable; $60,000 capital loss. 65. a. $100,000 realized. 65. b. $30,000 ordinary income. 65. c. $20,000 capital gain. 65. d. $100,000 basis. DISCUSSION QUESTIONS 1. A partnership is an association of two or more persons (including individuals, trusts, estates, corporations, other partnerships, etc. ) formed to carry on a trade or business.Each partner contributes money, property, labor or skill, and each expects to share in profits and losses. The entity must not otherwise be classified as a corporation, trust, or estate. p. 21-3 2. In a general partnership, all partners are â€Å"general partners† who are jointly and severally liable for partnership debts, including liabilities arising from tort or malpractice judgments against the general partnership. A general partner bears liability for these debts even i f the partner was not personally involved in the malpractice. A limited liability company has the corporate attribute of limited liability for the owners (called â€Å"members† in an LLC), but an LLC is treated as a partnership for tax purposes.In a properly-structured LLC, none of the members are personally liable for entity debts. State law governs the types of entities that may be established as LLCs. Most states permit capital-intensive entities to use this form of business, but they do not permit personal-service entities to be treated as LLCs. pp. 21-3 and 21-4 3. By default, a newly-formed noncorporate entity with two more owners is treated as a partnership under the check-the-box Regulations. The entity may â€Å"check-the-box† on Form 8832 to elect, instead, to be taxed as a corporation. p. 21-4 4. A partnership is not a tax-paying entity; however, it must still file a tax return.The partnership reports its income and expenses on Form 1065. Partnership income is comprised of income from operations and separately stated income and expenses. The income and expenses from operating activities are reported on Page 1 of the Form 1065. A separately stated item is any item (income or expense) that could differently affect the tax liabilities of different partners. Separately stated items are reported in the partnership return on Schedule  K. The partners must pay the tax on the partnership income. The partnership’s income and separately stated items are reported to each partner on a Schedule K-1 prepared for that partner. pp. 21-4 to 21-7 5.Because it is not a tax-paying entity, a partnership does not report â€Å"taxable income. † However, it must still reconcile between the tax return and the books. The partnership prepares the Analysis of Net Income (Loss) (page 5 of Form 1065) to determine what might be called the partnership’s â€Å"taxable income equivalent. † Certain amounts shown on Schedule K are netted and entered on the Net Income (loss) line of this Analysis. This â€Å"taxable income equivalent† is reconciled to book income on Schedule M-1 or Schedule M-3 of the partnership’s return. This is similar to the corporate reconciliation (also on Schedule M-1 or M-3) in Form 1120; however, for a partnership, the â€Å"taxable† amount must be derived as described above. pp. 1-5 to 21-7 6. Schedule M-3 is filed (in lieu of Schedule M-1) by â€Å"larger† partnerships to report a detailed reconciliation between the partnership’s book and tax income. In addition, these partnerships must file Schedule C to answer various questions regarding the partnership’s changes of ownership, reporting, or other activities during the year. This reconciliation is designed to highlight differences between GAAP basis reporting (per an SEC filing or an audited financial statement) and tax basis income. A partnership is generally required to file Schedule M-3 if it has $10 million or more in assets or $35 million or more in total receipts.In addition, it must file Schedule M-3 if any partner owns a 50%-or-greater interest in partnership profits, losses, or capital, and if that partner meets either the $10 million (assets) or $35 million (receipts) threshold. pp. 21-6 and 21-7 7. A special allocation is an amount that is allocated differently from the general profit or loss sharing ratios specified in the partnership agreement. For pre-contribution gain or loss property, special allocations are required to be made to eventually bring the partners’ tax bases in line with their book-value capital accounts. Orange, LLC, can offer a preferential special allocation of profits and cash flows to Green to compensate the company for use of its capital.The LLC can offer a guaranteed payment (rather than a special allocation) to Rose for her managerial time and expertise. Upon sale of the appreciated property contributed by Rose,  §Ã‚  704(c) require s the precontribution gain to be allocated to her. pp. 21-8, 21-24, and 21-36 8. A partner’s capital account is a mechanical determination of the partner’s financial interest in the partnership, as determined using one of several possible accounting methods, including tax basis, GAAP,  §Ã‚  704(b) book basis, or some other method defined by the partnership. The capital account reflects contributions and distributions of cash or other property to or from the partner.In addition, it accumulates the partner’s share of increases and decreases from operations, including amounts that are otherwise tax-exempt or nondeductible. Even if capital accounts are determined on a tax basis, a partner’s capital account usually will differ from the partner’s basis in the partnership interest because (among other reasons) the capital account does not include the partner’s share of partnership liabilities. p. 21-8 9. The â€Å"inside basis† is the part nership’s tax basis for the assets it owns. The â€Å"outside basis† is a given partner’s tax basis in the partnership interest. On formation of a partnership, the total of all partners’ outside bases will equal the partnership’s inside bases of all of its assets. p. 21-8 10.As a general rule, both  §Ã‚ §Ã‚  721 and 351 provide that no gain or loss is recognized when property is transferred on the formation of a partnership or corporation. However,  §Ã‚  351 applies only if those persons transferring property to a corporation are in control of the corporation immediately after the exchange, whereas  §Ã‚  721 does not include a control requirement. Section 721 not only applies to initial transfers in forming the partnership but to all subsequent contributions from any partner. Similarities exist between  §Ã‚ §Ã‚  721 and 351 in that these nonrecognition provisions do not apply to all transfers made by the owners. Under  §Ã‚  721, the contr ibutor must receive an interest in the partnership, while under  §Ã‚  351, the transferor must receive stock in the corporation.Under both  §Ã‚ §Ã‚  721 and 351, if the transfer of property involves the receipt of money or other consideration, the transaction may be deemed a sale or exchange rather than a tax-free transfer. pp. 21-9 to 21-11, and Concept Summary 21. 1 11. In general, on formation of a partnership, no gain or loss will be recognized by either the partnership or the contributing partners [ §Ã‚  721]. Bobbi will not recognize the realized gain related to the land she is contributing. Similarly, BC will not recognize a gain or loss. Bobbi’s basis in the land will carry over to BC. Bobbi’s basis in BC will be a substituted basis equal to her basis in the contributed land. If the land Bobbi contributes is ever sold by BC, the precontribution gain must be allocated to Bobbi [ §Ã‚  704(c)]. pp. 21-9, 21-10, and Example 24 12.Under the general rule of à ‚ §Ã‚  721(a), no gain or loss is recognized on formation of a partnership. This rule does not apply in at least four situations. Realized gain or loss is recognized if: †¢ The entity is an investment partnership, †¢ The partner received the interest in the partnership in exchange for services, †¢ The transaction can be viewed as an exchange of properties (e. g. , properties are contributed to the partnership and soon thereafter are distributed to other partners with the intent of taking advantage of the basis rules of  §Ã‚  731 for distributed property), and †¢ The transaction can be viewed as a disguised sale of the property from the partner to the partnership or one of the other partners. pp. 21-10 to 21-11 13. a.If a contribution of property to a partnership is followed shortly thereafter by a distribution of cash to that partner, the IRS may recharacterize the transactions as a disguised sale of the property. In this case, Gerald would be treated as contri buting 75% of the property and selling the remaining 25% for cash [$60,000 sales price (distribution amount) ? $240,000 property value]. He would recognize $30,000 of gain on the deemed disguised sale [$60,000 deemed selling price less $30,000 basis ($120,000 ? 25%)]. b. The parties could use any of several techniques to minimize the possibility that the IRS will recharacterize the transaction as a sale. First, the distribution could be proportionate to all the partners. Second, the contribution should not be contingent on the later distribution of cash.Third, even if cash is required to ensure the contribution, the distribution should not be contingent on the partnership achieving a certain level of profits. Fourth, the distribution could be made in stages over a longer (say, three-year) time period. Here, it may be viewed as being a reasonable return of Gerald’s capital (e. g. , each $20,000 payment represents a 10% return on his capital). Finally, the distribution could be deferred until two years following the capital contribution. pp. 21-11, 21-12, and Example 12 14. In its initial year, a partnership will typically incur organizational and startup expenses. If property is contributed to the partnership, the entity may incur costs related to transferring the title of the property.If the partnership interests are sold to investors, the partnership might incur syndication costs. Once the partnership has started business, it will incur ordinary and necessary business expenses; these expenses are deductible under  §Ã‚  162. Organizational and startup costs are generally deductible to the extent of the first $5,000 of such costs. This deductible amount is reduced to the extent the total of such costs (in the respective category) exceeds $50,000. Any portion that is not deductible is amortized over 180 months, beginning with the month in which the partnership begins business. The cost of selling the partnership interests to investors is treated as a sy ndication cost under  §Ã‚  709. Such expenses are not deductible.The cost of transferring title to an asset is treated as an acquisition cost related to the asset; this amount will be treated as a new asset placed in service when incurred, and it will be depreciated using the same method and life as the underlying property. (If this underlying property was contributed by a partner, that property will be depreciated by continuing the depreciation schedule used by the contributing partner. The partnership â€Å"steps into the shoes† of the contributing partner in calculating depreciation deductions. ) pp. 21-15 and 21-16 15. A partnership may generally use the cash method of accounting unless it is a tax shelter or has one or more partners that are subchapter C corporations.The C corporation partner will not preclude use of the cash method of accounting if that corporation is a qualified personal service corporation or if it is engaged in the farming business. In addition, a subchapter C corporate partner will not preclude use of the cash method if the partnership has never had â€Å"average annual gross receipts† in excess of $5 million, for any year beginning in 1986 or later years. Average annual gross receipts is calculated by averaging the taxpayer’s gross receipts for the three years prior to the tax year in question or for the period of the taxpayer’s existence, if shorter. p. 21-17 16. The three rules of the economic effect test are designed to ensure that a partner bears the economic burden of a loss or deduction allocation and receives the economic benefit of an income or gain allocation.By increasing the partner’s capital account by the gain or income allocated to the partner, the rule ensures that a positive capital account partner will receive an allocation of assets equal to the balance in the partner’s capital account when the partner’s interest is eventually liquidated. If the partner has a negat ive capital account, an allocation of gain or income to the partner reduces the amount of the negative capital account and, therefore, the amount of the deficit capital contribution that is required from the partner upon liquidation. In short, a dollar of income or gain increases the partner’s capital account by a dollar and, everything being equal, the partner should receive a dollar more upon liquidation (or contribute a dollar less to restore a deficit in the capital account). Allocations of losses and deductions affect the partner in the opposite manner as income or gain.Therefore, the allocation of a dollar of loss or deduction reduces the partner’s capital account by a dollar and, everything being equal, reduces the amount the partner will receive upon liquidation (or increases by a dollar the partner’s deficit capital restoration requirement). p. 21-23 and Example 22 17. Under  § 722, a partner’s initial basis is determined by reference to the am ount of money and the basis of other property contributed to the partnership. This basis is increased by any gain recognized under  § 721(b) and the partner’s share of any partnership liabilities. Basis is decreased by any partner liabilities assumed by the partnership.Basis is also adjusted to reflect the effect of partnership operations: it is increased by the partner’s share of taxable and nontaxable income and is decreased by the partner’s share of loss and nondeductible/noncapitalizable expenses. Certain adjustments for depletion are also made. Finally, a partner’s basis is increased by additional contributions to the partnership and by increases in the partner’s share of partnership debt. Basis is decreased by distributions from the partnership and decreases in the partner’s share of partnership debt. A partner’s basis is adjusted any time it may be necessary to determine the basis for the partnership interest, for example, wh en a distribution was made during the taxable year, or at the end of a year in which a loss arises. A partner’s basis may never be reduced below zero (i. e. , no negative basis). Figure 21. 3 18.The partnership’s debts are allocated to the partners in determining the partners’ bases in their partnership interests. Any increase in partnership liabilities is treated as a cash contribution to the partnership, thereby increasing the partners’ bases. Any decrease in partnership liabilities is treated as a distribution from the partnership to the partners and decreases their bases. Partnership debt is allocated differently depending on whether it is recourse to the partners or nonrecourse. Recourse debt is allocated in accordance with the constructive liquidation scenario. Under this test, all partnership assets are deemed to be worthless.The losses that would arise are allocated to the partners according to the partnership agreement. The losses would create ne gative capital accounts for at least some of the partners; those partners are deemed to contribute that amount of cash (equal to the negative capital balance) to the partnership in settlement of the obligation to repay partnership’s recourse liabilities. The amount of that deemed capital contribution is the amount of the partner’s share of the recourse liabilities. Nonrecourse debt is allocated in a three-tier system. First, allocate any gain related to assets where the debt exceeds the partnership’s â€Å"book† basis in the assets. This is called minimum gain and is allocated according to the partnership agreement.Next, any debt related to any remaining precontribution gain is allocated to the partner who contributed the encumbered property to the partnership. Finally, any remaining debt is allocated in accordance with the method specified in the partnership agreement. pp. 21-28 and 21-29 19. A guaranteed payment is an amount paid to a partner for the pe rformance of services or for the use of the partner’s capital. These payments are in the nature of salary or interest payments that are made by other entities, but the tax treatment of guaranteed payments is somewhat different. Like payments made by other entities, guaranteed payments are generally deductible by the partnership, and can result in a loss to the entity. Guaranteed payments are taxed as ordinary income to the recipient partner.Unlike salary and interest payments made by other entities, guaranteed payments are treated as if they were received by the partner on the last day of the partnership’s tax year. If the partner and partnership have different tax years, there will be a deferral between the time the partnership claims the deduction and the time the partner reports the income. Guaranteed payments are treated as self-employment income by the recipient partner. pp. 21-36 and 21-37 20. A partnership is advantageous under any of the following conditions: à ¢â‚¬ ¢ Special allocations of income, expenses, cash flows, etc. can be made by the entity owners. †¢ The entity has taxable losses which the owners can utilize on their individual tax returns. †¢ The partnership generates net passive income which offsets passive losses of the owners. The entity operated as a Subchapter C corporation and would be required to report taxable income since other means of reducing such income (e. g. , interest, rents, salaries to owners) have been maximized and are not available. †¢ The entity cannot qualify under the requirements for a Subchapter S election (e. g. , too many shareholders, nonqualifying shareholders, more than one outstanding class of stock, etc. ) †¢ The entity will exist for only a short period of time and, if a corporation, its liquidation will result in a large tax due to the appreciation in its assets. †¢ Several other advantages may exist. The disadvantages of the partnership entity form arise when: The ent ity income is significant and will be taxed at higher individual rates than if accumulated in the corporation. †¢ The entity is in a high risk business and the owners require protection from personal liability. An LLC or LLP may be useful in such situations. pp. 21-51, 21-52, and Concept Summary 21. 5 21. a. False. The entity is required to file an information return, generally by the fifteenth day of the fourth month after the end of the partnership’s tax year. The return includes data concerning the partners’ allocable shares of the financial activities of the partnership. In addition, property, sales, and employment tax returns are likely to be required of the entity. p. 21-6 b. False.Generally no gain or loss is recognized, but there are exceptions to  § 721, including those pertaining to the receipt of boot, the contribution of property with liabilities in excess of basis, and the receipt of a partnership interest in exchange for services provided to the pa rtnership. pp. 21-10 and 21-11 c. False. The partner recognizes ordinary income, to the extent of the fair market value of the partnership interest that is received in this manner. p. 21-11 d. False. If property which was inventory in the hands of the transferor partner is sold by the partnership within five years of the date it was contributed, any gain will be treated as ordinary income, regardless of the manner in which the property was held by the partnership. p. 21-13 e. False. The partnership chooses tax accounting periods and methods that are applied to all of the partners. p. 21-15 f. False.An alternative tax year will never be required by the IRS; instead, the partnership must request permission from the IRS and may have to illustrate to the IRS that it has a business purpose for using an alternative tax year. p. 21-19 g. True. Built-in losses, as well as gains, must be allocated to the contributing partner when recognized by the partnership. pp. 21-24 and 21-25 h. True. pp . 21-27 to 21-29 i. True. p. 21-33 j. False. Such losses can be deducted by partners who hold a 50% or less ownership interest in the entity. p. 21-38 22. Generally, a taxable gain arises on a proportionate distribution only when cash is received in excess of the distributee partner’s basis in the partnership interest. As a relief of liabilities is treated as a distribution of cash, a decrease in a partner’s share of liabilities may also trigger a taxable gain.Similarly, certain distributions of marketable securities are treated as distributions of cash and can result in gain recognition. Other transactions, such as disguised sales and distributions related to precontribution gain property, might also result in gain recognition by the distributee partner. pp. 21-41 and Examples 51, 52 and 57 23. In either a current or liquidating distribution, assets are distributed in the following order: 1)  cash, 2) ordinary-income producing (hot) assets, and 3) other assets. Cash . In either a current or liquidating distribution, a cash distribution in excess of the partner’s basis triggers a gain (typically a capital gain). Cash (and certain items treated as cash) is the only asset for which a distribution might trigger a gain. Hot assets.In either a current or liquidating distribution, the partner’s basis in distributed hot assets equals the lesser of the partner’s basis in the partnership interest (after any cash distributions) or the partnership’s basis in the hot asset. In a liquidating distribution, the partner can claim a loss equal to any basis remaining after these hot assets are distributed, if no â€Å"other assets† will be distributed. In a current distribution, no loss can be deducted. Other assets. In a current distribution, â€Å"other assets† are treated similarly to hot assets: the basis equals the lesser of the partner’s basis in the partnership interest (after any cash and hot asset distribu tions) or the partnership’s basis in the asset. In a liquidating distribution, â€Å"other assets† absorb any remaining basis in the partnership interest after cash and hot assets are accounted for.For either a current or liquidating distribution, if â€Å"other assets† are distributed, the partner cannot recognize a loss. Examples 54, 57, 59, and 60 24. The partnership distribution rules reflect the aggregate theory of taxation. With respect to property ownership, the partner can be seen as an extension of the partnership. Ownership of property by the partner generally produces the same result as ownership by the partnership (and vice versa). The result is a carryover basis in distributed property with a preservation of the character of distributed property. The distribution rules operate with the goal of deferring tax on the distribution, while preserving the ordinary income potential.No gain or loss is recognized if an adjustment can be made to the basis of t he distributed property, without reducing the amount of ordinary income the partner will eventually recognize. So, gain is recognized if cash distributions exceed basis, because there is no asset for which the basis can be reduced. The basis of hot assets can be decreased, but not increased, in a distribution because the inherent ordinary income cannot be decreased. Similarly, loss can be recognized if only cash and â€Å"hot† assets are received in a liquidating distribution, because the basis in these types of assets cannot be increased to absorb the partner’s remaining basis. pp. 21-40 and 21-41 25.Jody must determine her gain or loss on the sale of the partnership interest. If the partnership owns â€Å"hot assets,† she must recognize ordinary income or loss to the extent of her proportionate share of the built-in appreciation or depreciation on these assets. Her remaining gain or loss is adjusted by the ordinary income or loss recognized. If the partnership ’s assets are substantially appreciated, Bill may wish to ask the partnership to make a  § 754 election so he can be allocated a step-up in basis. If the partnership has a substantial built-in loss (assets are depreciated by more than $250,000), the partnership may be required to make a step-down adjustment with respect to Bill’s acquired interest.If Jody sells more than a 50% interest in the partnership, or Bill is the sole remaining member of a two-owner partnership, the entity will terminate on the date the purchase is finalized. This may result in a loss of a favorable tax year or accounting method by the partnership. pp. 21-47 to 21-49 PROBLEMS 26. a. Under  § 721, neither the partnership nor the partners recognizes any gain on formation of the entity. b. Chip will take a cash basis of $200,000 in his partnership interest. c. Marty will take a substituted basis of $100,000 in his partnership interest ($100,000 basis in the property contributed to the entity). d. The partnership will take a carryover basis in the assets it receives ($200,000 basis in cash, and $100,000 basis in property). Example 14 27. a. Liz has a realized loss of $15,000.However,  § 721 contains the general rule that no gain or loss is recognized to a partnership or any of its partners upon the contribution of money or other property in exchange for a capital interest. Since Liz is subject to this rule, she does not recognize the loss. p. 21-10 b. $60,000. Section 722 provides that the basis of a partner’s interest acquired by a contribution of property, including money, is the amount of such money and the adjusted basis of such property to the contributing partner at the time of the contribution. p. 21-12 c. $75,000, the adjusted basis of the contributed property ( § 722). p. 21-12 d. $75,000. Under  § 723, the basis of property to the entity is the adjusted basis of such property to the contributing partner at the time of the contribution, increased by a ny  §Ã‚  721(b) gain recognized by such partner.Since no such gain (and no loss) was recognized by Liz on the contribution, the partnership takes a carryover basis in the property. Example 14 e. A more efficient tax result may arise if Liz sells the property to an unrelated party for $60,000, recognizes the $15,000 loss on the property, and contributes $60,000 cash to the partnership. The partnership could then use the $60,000 to acquire similar property, in which it would take a $60,000 basis. Example 9 28. a. Carol realizes a gain of $20,000 on contribution of the land. Connie realizes a gain of $60,000 on contribution of the equipment. The partnership realizes a gain equal to the value of the property it receives (it has a $0 basis in the partnership interests it issues). b.Under  § 721, neither the partnership nor either of the partners recognizes any gain on formation of the entity. Example 8 c. Carol will take a substituted basis of $70,000 in her partnership interest ($30 ,000 cash plus $40,000 basis in land). Connie will take a substituted basis of $30,000 in her partnership interest ($30,000 basis in the equipment). Example 14 d. The partnership will take a carryover basis in all the assets it receives ($30,000 basis in cash, $40,000 basis in land, and $30,000 basis in equipment). p. 21-12 e. The partners’ outside bases in their partnership interests total $100,000: Carol’s basis of $70,000 plus Connie’s basis of $30,000.This is the same as the partnership’s basis in assets of $100,000 ($30,000 cash plus $40,000 land plus $30,000 equipment). p. 21-12 f. The partnership will ‘‘step into Connie’s shoes† in determining its depreciation expense. It will use the remaining depreciable life and the same depreciation rates Connie would have used. p. 21-12 29. Both partners are contributing assets valued at $100,000. One property has a built-in gain; the other has a built-in loss. Justin and Tiffany recog nize no gain or loss on contribution of their respective properties to the partnership. Justin takes a substituted basis of $85,000 in his partnership interest ($20,000 cash plus $65,000 basis in land). The partnership takes a $65,000 carryover basis in the contributed land.The â€Å"built-in gain† on the land must be tracked and allocated to Justin if the property is ever sold at a gain [ §Ã‚  704(c)]. Section 721 applies to losses as well as gains and prevents Tiffany from recognizing the $25,000 loss on her contribution to the partnership. She will have a $125,000 basis in a partnership interest worth $100,000. Similarly, the partnership will have a $125,000 basis in assets valued at $100,000. The partnership will â€Å"step into Tiffany’s shoes† in determining depreciation deductions. As this is â€Å"built-in loss† property,  §Ã‚  704(c) applies, and amounts related to the built-in loss must be allocated to Tiffany. Depreciation must be allocated in accordance with Reg.  §Ã‚  1. 704-3 (not discussed in detail in this chapter). Basically, a large portion of the depreciation deductions would be allocated to Tiffany to reduce the difference between her basis and the fair market value of her partnership interest as quickly as possible. (If the property basis was less than its fair market value, depreciation would first be allocated to the other partner. )] pp. 21-10, 21-12, 21-13, 21-24, and Example 9 30. Tiffany has a taxable transaction when she sells the assets to a third party. She receives cash of $100,000 in exchange for assets with a basis of $125,000 and recognizes a $25,000 loss. (Based on the facts presented, the loss will likely be a  §Ã‚  1231 loss. ) When Tiffany contributes the $100,000 cash to the partnership, she recognizes no gain or loss and has a basis of $100,000 in her partnership interest.The partnership, of course, has a basis of $100,000 in the cash it receives. The partnership will need to use Tiffa ny’s $100,000 cash contribution, plus $10,000 of the cash Justin contributed to acquire new equivalent assets for $110,000. In this situation, the tax result to Tiffany is improved (she can recognize her $25,000 realized loss), but there is a $10,000 economic cost to the partnership when it acquires equivalent assets for $110,000 instead of $100,000. pp. 21-10, 21-12, 21-13, 21-24, and Example 8 31. a. None. Under  § 721, neither the partnership nor any of the partners recognize gain on contribution of property to a partnership in exchange for a partnership interest. b. $50,000.Ben’s basis in his partnership interest will equal the basis he held in the property he inherited from his father. The basis a beneficiary takes in property received from an estate generally equals the fair market value of the asset at the date of death or at the alternate valuation date (6 months later) if available and elected. p. 21-26 c. Beth will recognize $25,000 of ordinary income. The fair market value of Beth’s 50% partnership interest is $75,000. Since Beth will contribute only $50,000 of property, the difference between the amount contributed and the value of the interest will be treated as being for services rendered to the partnership. Services do not constitute ‘‘property’’ for purposes of  § 721 nonrecognition treatment. p. 21-11 d.Beth’s basis in her partnership interest will be $75,000 [$50,000 (cash contributed) + $25,000 (the amount of ordinary income recognized for services rendered to the partnership)]. Example 13 32. a. Assets Basis    FMV Cash $ 50,000 $ 50,000 Land50,00075,000 Land improvements 25,000 25,000 Total assets$125,000$150,000 Ben’s capital $ 50,000 $ 75,000 Beth’s capital 75,000 75,000 Total capital$125,000$150,000 Note that the partnership will capitalize the $25,000 deemed payment for Beth’s services, since the services relate to a capitalizable expenditure. The partners hip will reflect this $25,000 in ‘‘cost of lots sold† as the development lots are sold. b.Beth could prepare a development plan and secure zoning permits before the partnership is formed. She could then contribute these plans and permits to the partnership in addition to the $50,000 cash. Since a completed plan would be considered â€Å"property,† no portion of her partnership interest would be received in exchange for services if this were done. The entire transaction would be considered under  § 721. p. 21-12 33. a. Under general guidelines, the $50,000 would be treated as a distribution, which, since it does not exceed Ben’s basis in his interest, would not be taxable. The distribution would reduce Ben’s basis in his partnership interest by $50,000. b. None. c.The partnership would take a basis of $50,000 in the land, Ben’s basis in the property at the time of the contribution. d. The IRS might assert that the contribution and distr ibution transactions were in effect a disguised sale of two-thirds ($50,000 distribution ? $75,000 fair market value) of the property contributed by Ben to the partnership. e. $16,667. Under disguised sale treatment, Ben will recognize gain on a sale of two-thirds of his interest in the land. He will be deemed to have received $50,000 in exchange for two-thirds of the land, with a basis of $33,333 ($50,000 basis ? 2/3). Total gain recognized, then, is $16,667. f. $66,667. The partnership will be deemed to have paid $50,000 for two-thirds of the land.The remaining one-third is deemed to be contributed to the partnership, and the partnership will take a carryover basis of $16,667 in this parcel. The partnership’s total basis is $66,667 ($50,000 + $16,667). Figure 21. 3 and Example 12 34. a. The partners’ initial bases in their partnership interests are the same amounts as their bases in the contributed property ( § 722). Rachel’s basis $360,000 Barry’s ba sis 600,000 b. The 2011 sale results in ordinary income of $170,000 to the partnership. 2011 sale: Selling price$530,000 Basis (360,000) Gain$170,000 The gain is ordinary income, since the land is held as inventory by the partnership. The land was a capital asset to Rachel, but no code provision allows treatment of the gain based on Rachel’s use rather than the partnership’s use. c.The 2012 sale results in a $100,000 capital loss and a $20,000 ordinary ( § 1231) loss. 2012 sale: Selling price$480,000 Basis (600,000) Loss ($120,000) As a sale of inventory (determined at the partnership level), the sale in 2012 of the land contributed by Barry would normally result in an ordinary ( §Ã‚  1231) loss. However,  §Ã‚  724 overrides the usual treatment. The character of the precontribution loss, instead, is determined based on the character of the property in Barry’s hands. This sale was within five years of the capital contribution date, so the loss is capital in nature to the extent of the built-in loss at the contribution date, which is: FMV at contribution$500,000 Basis (600,000) Capital loss ($100,000)The remaining $20,000 loss in 2012 is an ordinary ( § 1231) loss because the character of the post-contribution loss is based on the partnership’s ownership and use of the property as inventory. d. If the property Barry contributed was sold by the partnership in 2017, the entire $120,000 loss would be treated as an ordinary ( §Ã‚  1231) loss. A sale in 2017 would not be within five years of the contribution date, so the character of the loss would be determined solely by reference to the character of the asset to the partnership. Since the land is inventory to the partnership, the loss in 2017 would be ordinary. pp. 21-12, 21-13, and Examples 16 and 17 35. P5 Partnership, Ltd. has incurred costs for organizing ($10,000), starting the business ($60,000), transferring of property ($24,000), and securing investors ($1  million) f or the partnership. The organizational costs are treated under  § 709. Under this section, the first $5,000 of such expenses are deducted (provided the total is less than $50,000); the remainder is amortized over 180 months. The startup costs are treated under  § 195. Under this section, also, the first $5,000 of such expenses are deducted, provided the total is less than $50,000. If costs exceed $50,000, the $5,000 deduction is phased out, dollar for dollar, by the amount of costs in excess of $50,000. When total costs equal or exceed $55,000 (as in this situation), no portion of the expense is currently deductible.Instead, the full amount is amortized over 180 months. The $24,000 transfer tax is treated as a cost of acquiring the land and is added to the partnership’s basis in the land. The $1 million of brokerage commissions is treated as a syndication cost of the partnership. Under  §709, these costs cannot be deducted. pp. 21-15 to 21-17 36. The SB Limited Liabilit y Company must address the following issues in preparing its initial tax return: †¢ What year-end must the LLC use? Unless an election is made under  § 444, the LLC must use the year-end determined under the least aggregate deferral method. There is no majority member, and the principal members do not have the same year-end.Under the least aggregate deferral method, the LLC would use a July year-end since this would result in only a 5-month deferral of income to Block. Example 19 †¢ What method of accounting will the LLC use? Even though both members are Subchapter C corporations, the LLC may elect the cash method of accounting if average annual gross receipts are less than $5 million for the year. The LLC, then, could select either the cash, accrual, or a hybrid method of accounting. p. 21-17 †¢ How are the initial legal fees treated? Can the first $5,000 of organizational expenditures be immediately expensed and the balance amortized over a period of 180 months or more? Would any amounts be treated as startup expenditures under  § 195? p. 21-15 The members’ initial bases in their LLC interests must be determined. The bases will be the substituted basis of the assets contributed to the LLC ($650,000 for Block, and $550,000 for Strauss). Example 14 †¢ The LLC’s basis in the property received from the members must be determined, and any cost recovery related to contributed property calculated. The LLC takes a basis of $650,000 in the equipment and steps into Block’s shoes in determining cost recovery allowances. Since the licenses and drawings are contributed rather than sold, the LLC takes a $0 basis in these assets, with no cost recovery possible. The LLC takes a $50,000 carryover basis in the land and a $500,000 basis in the cash. p. 21-12 The LLC must determine whether any portion of either of the LLC interests is issued in exchange for services. The equipment, cash, and land are considered â€Å"property† for purposes of  § 721. The building permits and architectural designs also are considered property under  § 721, even though they are intangible assets. Therefore, none of the LLC interests is issued in exchange for services. Example 13 †¢ Treatment of expenses incurred during the initial period of operations must be considered. The legal fees are organization costs and their tax treatment was previously noted. The construction costs must be capitalized until such time as the building is placed in service. The office expense may have to be capitalized under either (1)  § 195, if it is etermined that the business is still in the startup stage, or (2)  § 263A if it is determined the costs relate to â€Å"production† of the rental property. If neither of these provisions applies, the office expense is currently deductible. pp. 21-15 and 21-16 †¢ If the land is later sold, a portion of the gain must be allocated to Strauss, since the gain was â€Å"built-inâ €  at the time the property was contributed. Note that if the equipment had been appreciated, depreciation allocations would have to take the precontribution gain into account. Allocation of precontribution deductions related to depreciable property are not covered in this text. p. 21-24 37. In 2008, 2009, and 2010, BR can use either the cash, accrual, or a hybrid method of accounting.BR has at least one Subchapter C corporation as a partner, but BR’s average annual gross receipts did not exceed $5,000,000 in either 2008 or 2009. (BR’s average annual gross receipts were $4,600,000 for 2008 and $4,800,000 for 2009. ) In 2011, BR must change to the accrual method of accounting. BR has at least one Subchapter C corporation as a partner during that year, and BR’s average annual gross receipts for the preceding y