...Estate of Leavitt v. Comm Facts: As shareholders of VAFLA Corporation, an S corporation, the appellants claimed deductions to reflect the corporation’s operating losses. The commissioner disallowed deductions above the $10,000 bases from original investment. The appellants contend that the adjusted basis in their stock should be increased to reflect a $300,000 loan. The loan was obtained by VAFLA from bank and was guaranteed by the shareholder-guarantors. VAFLA made all of the loan payments, principals and interest to the bank and the appellants did not. Neither VAFLA nor the shareholder-guarantors treated the loan as constructive income taxable to the shareholder-guarantors. Because the bank lent the loan to the shareholder-guarantors and then they contributed the funds to the corporation, the appellants present that the loan is a capital contribution from appellants to VAFLA. If it is characterized as equity, they should be entitled to add a pro rata share of the loan to their adjusted basis. The Tax Court disallowed such increase in basis. Issues: The issue is whether the shareholder-guarantors should add a pro rata share of the loan to their adjusted basis and deduct operating losses to the extent of the basis. Court holdings: U.S Court of Appeals affirmed the Tax Court decision, concluding that shareholders’ basis in stock wasn’t increased by personal guarantees given as collateral and proportionate shares of NOL was limited to initial investment. Analysis and...
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...The most pleasant and delectable tale of the marriage of Cupid and Psyches. There was sometimes a certaine King, inhabiting in the West parts, who had to wife a noble Dame, by whom he had three daughters exceeding fair; of whom the two elder were of such comly shape and beauty, as they did excell and pass all other women living, whereby they were thought worthily to deserve the praise and commendation of every person, and deservedly to be preferred above the residue of the common sort. Yet the singular passing beauty and maidenly majesty of the youngest daughter did so farre surmount and excell then two, as no earthly creature could by any meanes sufficiently expresse or set out the same. By reason wherof, after the fame of this excellent maiden was spread about in every part of the City, the Citisens and strangers there beeing inwardly pricked by the zealous affection to behold her famous person, came daily by thousands, hundreths, and scores, to her fathers palace, who was astonied with admiration of her incomparable beauty, did no less worship and reverence her with crosses, signes, and tokens, and other divine adorations, according to the custome of the old used rites and ceremonies, than if she were the Lady Venus indeed, and shortly after the fame was spread into the next cities and bordering regions, that the goddess whom the deep seas had born and brought forth, and the froth of the waves had nourished, to the intent to show her high magnificencie and divine power...
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...Wise Judgment Scenario A teenage girl is “in love” with her 17-year-old boyfriend. He is encouraging her to have sex with him saying that he will make sure they only have “protected” sex. This scenario is a very common one among teenagers these days. I can especially relate to this scenario because I was once in the same situation. However, this scenario can be applied to the five components of wise judgment to help come up with an answer, or solution, to this situation. First, there are four components to emotional intelligence one is emotional perception and expression, emotional facilitation of thought, emotional understanding, and emotional management. Emotional perception and expression is the ability to recognize your own emotions as well as recognizing other people’s emotions. Also, this component involves the capacity to both express positive and negative emotions accurately. As a teenager, it is very hard to control your emotions I myself know how this feels I went thourgh this also when I was teenager. For one this teen girl thinks that she is in love with her boyfriend, but for , being so young she could be confusing love for lust or even a very strong liking feelings because these feelings are probably something she has never felt before and are new to her. Emotional facilitation of thought, if developed in this teen girl, could use her emotions to tha could help for more efficient decision-making in this delmia she is having . The only thing is , being a teen...
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...Using Facebook to Teach Rhetorical Analysis Jane Mathison Fife The attraction of Facebook is a puzzle to many people over the age of thirtyfive, and that includes most college faculty. Yet students confess to spending significant amounts of time on Facebook, sometimes hours a day. If you teach in a computer classroom, you have probably observed students using Facebook when you walk in the room. Literacy practices that fall outside the realm of traditional academic writing, like Facebook, can easily be seen as a threat to print literacy by teachers, especially when they sneak into the classroom uninvited as students check their Facebook profiles instead of participating in class discussions and activities. This common reaction reflects James King and David O’Brien’s (2002: 42) characterization of the dichotomy teachers often perceive between school and nonschool literacy activities (although they are not referring to Facebook specifically): “From teachers’ perspectives, all of these presumably pleasurable experiences with multimedia detract from students’ engagement with their real work. Within the classroom economy technology work is time off task; it is classified as a sort of leisure recreational activity.” This dichotomy can be broken down, though; students’ enthusiasm for and immersion in these nonacademic literacies can be used to complement their learning of critical inquiry and traditional academic concepts like rhetorical analysis. Although they read these texts daily...
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...Yoga as a Therapy for Menopausal Symptoms For some women, perimenopause is not an easy, smooth transition. Yoga is a regulator of the sympathetic system, respiratory system and the cardiovascular system. Combined with meditation, it is a form of exercise that has the potential to alleviate symptoms in women navigating the climacteric. In my review of literature, this essay will compare information from studies relating to the effectiveness of yoga and mind-body techniques in treating the symptoms associated with menopause. The midwife can offer yoga therapy to women who do not desire hormone therapy and would like to explore a non-allopathic alternative to treat her perimenopausal symptoms. Yoga is moving meditation, the union of mind and body. The word Yoga comes from the Sanskrit word "Yuj" meaning to unite. This means integrating all aspects of the woman- body, mind and spirit. The goals of yoga therapy are to improve the physical body, expand and relax the mind, and achieve a balanced life experience. The study of yoga and mind-body complementary and alternative medicine {CAM} is a fairly recent endeavor in the United States (Bond, 2007). The use of CAM, specifically by women, is on the rise in the United States (Schuiling, 2013). Complementary and alternative medicine {including yoga} in some midwifery communities is an essential part of midwifery practice, and in others, it is utilized only as a personal healthcare or lifestyle choice. It may be applied...
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...Criminals are born as such. Discuss: Five year old girl abducted, raped and murdered. It is headlines like this that often make newspaper headlines. When reading a headline such as this the question is often asked ‘How could a human being be capable of doing such a thing to another human being? Another headline may read ‘what led young people to riot?’ in reference to normal young people who took to the streets of London and broke into shops and set fire to pubs. There are many theories as to why people commit crimes. Are these crimes due to inherited predispositions? Are they a response to the strain of disjunction between goals and the means of achieving? Is this because they were written off as delinquents at school? Are these crimes a result of being labelled a murderer or a hooligan? Is the inequality in the capitalist world responsible for these people’s actions? This essay will look at biological, physiological and sociological perspectives to consider why people commit crimes. Deviance can be defined as behaviour that differs from the normal and is subjected to public disapproval. What is labelled as deviant is relative and will clearly differ between cultures. Similarly what is seen as deviant behaviour changes over time, it was once deviant to bear a child out of wed lock but over time it is now considered to be the norm. Lastly deviance is subjective depending on location for example it would be considered to be deviant to chant, shout and walk around topless at...
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...Twenty-one percent of adults in the United States can only read at a fifth grade level. 774 million adults in the world cannot read or write. Many adults do not know how to read and write because they did not complete high school for any number of reasons. These reasons could include being forced to stay home and work or go out and get a job to support a family; the schools may not educate past the fifth or eighth grade level; bad home life; sickness; or a family crisis. Technology and social media have aided in decreasing the rates of literacy and increasing the amount of anti-intellectualism in the United States. Social media and technology have also helped some people to learn to read and write in some cases. According to Cynthia L. Selfe in Technology and literacy in the twenty-first century: the importance of paying attention, “the access and use of technology in school-based settings is now a fundamental skill of literacy, and if such skills do help prepare graduates for the jobs they will be asked to do, these same students can expect fewer opportunities to assume high-tech and high-paying jobs, not more.”(136) However, social media and technology have increased the amount of anti-intellectualism in the places where it is used. Anti-intellectualism is the opposition to intellectuals. It opposes the artistic, academic, religious, and social ideas, and does not live for ideas. Anti-intellectuals live off of ideas. Intellectuals are the opposite in that they live for...
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...Having recorded some of his discourses with Powhatan, John Smith wrote in “What Can you Get By Warre”: Seeing you will not rightly conceive of our words, we strive to make you know our thoughts by our deeds; the vow I made you of my love, both my selfe and my men have kept. As for your promise I find it every day violated by some of your subjects: yet we finding your love and kindnesse, our custome is so far from being ungratefull, that for your sake onely, we have curbed our thirsting desire of revenge; els had they knowne as well the crueltie we use to our enemies, as our true love and courtesie to our...
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...The debate between the applications of thermotherapy (hot) versus cryotherapy (cold) in the treatment of patients in the acute inflammatory phase following injury continues to wage on in the realm of professional healthcare and rehabilitation. For many athletic trainers, whether to use heat or cold therapy is often a personal choice, although cold therapy seems to be more effective for acute pain (Itoh & Lee, 2007). However, for many patients/clients concerned with the effectiveness of a specific treatment coupled with the rate of recovery, hard evidence derived from reliable and consistent research in support of one modality as the most effective, is in high demand. While both hot and cold treatments may be used to alleviate pain and inflammation, the various physical and chemical aspects of these two treatments have vitally different effects on the human body in regards to treatment of inflammation (Itoh & Lee, 2007). In general, temperature alterations have four main effects on surface body tissues, including pain relief (analgesia), muscle relaxation, blood vessel alterations, and connective tissue effects (Wnorowski, 2011). When treating a patient, it is important to know both the effects of the medium or modality being used on the body, as well as the consequences that it will bring to bear in relation to the physiological effects the body is already experiencing due to the mechanism of injury. The inflammatory response is divided into acute inflammation, which...
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...Turkish Online Journal of Qualitative Inquiry, October 2010, 1(2) Informal Online Learning Practices: Implications for Distance Education Fawn Winterwood The Ohio State University, USA fwinterwood@ehe.osu.edu Abstract This qualitative ethnographic study examines five American teenagers‟ historical and current digitally-mediated multiliteracy practices within digital popular culture. The participants included three male and two female students of a private high school in the Midwestern United States. The study is framed by the notion that literacy is a socially, culturally, and historically situated discursive construct rather than a purely individualized cognitive endeavor. This social constructivist theory of literacy emphasizes the social conditions necessary to navigate the economic, social, and political worlds of the 21st century. The purpose of the study was to explore the students‟ multiliteracy practices that they enact through their activities within digital popular culture. Data collection methods included synchronous interviews facilitated by video conferencing tools as well as observation of the participants‟ online activities and member checks conducted via email and instant messaging. The analytic strategy employed during this study was informed by Clarke‟s (2005) situational analysis method. The study‟s findings indicate that literacy practices in which the study participants have engaged through informal learning activities within digital youth culture...
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...xxviii). o Punishments must be both sufficient enough to deter crime and not excessive as to constitute an act of cruelty • “If the harm inflicted be lesse than the benefit, or contentment that naturally followeth the crime committed, that harm is not within the definition; and is rather the Price, or Redemption, than the punishment of Crime: Because it is of the nature of Punishment, to have for end, the disposing of men to obey the Law; which end (if it be lesse than the benefit of the transgression) it attaineth not, but worketh a contrary effect” (Hobbes, Leviathan, II.xxviii). {See Also Ch. 27 “Punishments declared before the Fact, excuse from greater punishments after it”). • “If a punishment be determined and prescribed in the Law it selfe, and after the crime committed, there be a greater Punishment inflicted, the excesse is not Punishment, but an act of hostility. For seeing the aym of Punishment is not a revenge, but terror;” (Hobbes, Leviathan, II.xxviii). o There should be no punishment of the innocent because it does not support the stability of the commonwealth or the security/self-preservation of the individual. • “All Punishments of Innocent subjects, be they great or little, are against the Law of Nature; For Punishment is only of Transgression of the Law, and therefore there can be no Punishment of the Innocent. It is therefore a violation, First, of that Law of Nature, which forbiddeth all men, in their Revenges, to look at any thing but some future good: For...
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...Vocabulary Instruction: Best Practices Raul A. Garcia Grand Canyon University SED: 535- Adolescent Literacy Prof. Dennis Fare May, 16, 2012 Meditation XVII: "No man is an Island, intire of it selfe; every man is a piece of the Continent, a part of the maine; if a Clod bee washed away by the Sea, Europe is the lesse, as well as if a Promontorie were, as well as if a Mannor of thy friends or of thine owne were; any man’s death diminishes me, because I am involved in Mankinde; And therefore never send to know for whom the bell tolls; It tolls for thee." (Donne, J., 1924/1987) I find it ironic that this poem is written in 1924 by a poet who has recently recovered an illness that nearly takes his life, and is again used in the book by Ernest Hemmingway For whom the bell tolls, in which the main Character is a professor at a University who is also an explosions expert on a mission to blow up a bridge. Yet knowing he will not survive his mission uses this poem as a reference to what he is sure will be his own death. However, as I think of this person being a professor would it be an irony that instead of being death it may talk about life as a teacher? For whom the bell tolls, it tolls for thee, not to remind us of death but to remind us of our service to Mankinde. Does that bell toll for our students to get to class or does that bell toll to remind us of the commitment we made when we decided to be teachers of those students. Now that I have your...
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...Table of contents Executive summary 2 Companies profile and History. 3 The company’s proposition. 3 Chronology in introducing products, and other landmarks 3 Plants for manufacturing: 4 Land marks 4 Choosing Brand 5 Main Competitors 6 SWOT analyze Hero Motor Corp 6 Macro Environment 9 Consumer Behaviour. 9 The buying decision behavior for buying 10 Marketing plan, strategy (BCG’s and SBUs 10 Pricing 11 Channels of distribution 11 Promotion Mix 12 Executive summary Company background Companies profile and History. Hero MotoCorp Limited is the World's single largest two-wheeler motorcycle company. The com-pany has three manufacturing facilities in Dharuhera, Gurgaon at Haryana and Haridwar at Uttarak-hand. The company head quarter is based in New Delhi, India .It started manufacturing bicycles, in 1984 the company was incorporated in a joint venture with Honda and given the name Hero Honda Ltd. Honda was making the R&D work and Hero was manufacturing. The company’s proposition. In the 1980s, Hero Honda grabbed everyone's attention with its campaign 'Fill it - Shut it - Forget it' Chronology in introducing products, and other landmarks 1985 : CD100 1989: Sleek 1991: CD 100 SS 1995 : Splendor 1999: Hero Honda CBZ first 150 cc in Indian market 2001: Passion and joy 2002: Dawn and Ambition 2003: CD Dawn, Splendor+ and Passion Plus, and Hero Honda Karizma, the industry's first 223cc motorcycle. 2004: Ambition 135 and CBZ 2005: Super...
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...Functionalist (MACRO) view on Religion Functionalists believe that society is like an organism (Organic/Biological Analogy), and different key things each play its crucial part to keep society running successfully. This can include Religion, the Economy and the people in it. For functionalists what makes order possible is a social consensus (Equilibrium or Social Harmony/agreement) – shared norms and beliefs by which society as a whole follows. Religious institutions play their part in the social consensus and also help create social solidarity. Functionalist like to keep to the status qou and any change must be very slow (evolutionary like). Durkheim says religion is an important function for society as it binds people together like a ‘Social Cement’. Durkheim: The Sacred and the Profane * Durkheim believed in an idea called THE SACRED AND THE PROFANE. Durkheim argued that the key features of religion was not the idea of believing in a certain god/goddesses or spiritual beings. But it was the fundamental distinctions between the sacred (things that are set apart, forbidden and inspire feelings of awe, fear, compassion surrounded by taboos and prohibitions.) and the profane (these are things that have no social value) found in all religions. A religion is not a set of beliefs, it involves definite rituals or practises in relation to the sacred. These rituals are often collective – performed by social groups. * Powerful feelings in believers indicates to Durkheim that...
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...Marlowe's "Doctor Faustus" and "Sin against the Holy Ghost" Author(s): Gerard H. Cox, III Source: Huntington Library Quarterly, Vol. 36, No. 2 (Feb., 1973), pp. 119-137 Published by: University of California Press Stable URL: http://www.jstor.org/stable/3816592 Accessed: 07/11/2010 15:38 Your use of the JSTOR archive indicates your acceptance of JSTOR's Terms and Conditions of Use, available at http://www.jstor.org/page/info/about/policies/terms.jsp. JSTOR's Terms and Conditions of Use provides, in part, that unless you have obtained prior permission, you may not download an entire issue of a journal or multiple copies of articles, and you may use content in the JSTOR archive only for your personal, non-commercial use. Please contact the publisher regarding any further use of this work. Publisher contact information may be obtained at http://www.jstor.org/action/showPublisher?publisherCode=ucal. Each copy of any part of a JSTOR transmission must contain the same copyright notice that appears on the screen or printed page of such transmission. JSTOR is a not-for-profit service that helps scholars, researchers, and students discover, use, and build upon a wide range of content in a trusted digital archive. We use information technology and tools to increase productivity and facilitate new forms of scholarship. For more information about JSTOR, please contact support@jstor.org. University of California Press is collaborating with JSTOR to digitize, preserve and extend access...
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