...Memo. 2009-93 UNITED STATES TAX COURT THOMAS J. WOODY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 30077-07. Filed April 30, 2009. P alleges that during tax year 2004 he had a real estate investment and rental business. P deducted expenses associated with this activity as business expenses under I.R.C. sec. 162. R disallowed the business expense deductions. On the basis of this disallowance, R determined a deficiency in P’s Federal income tax for 2004. P petitioned this Court for redetermination of that deficiency. Held: P was not actively engaged in a real estate investment and rental business when he incurred and paid the expenses he deducted as Schedule C business expenses in 2004. Therefore, the costs P deducted are pre-operational start-up expenditures and may not be deducted as business expenses under I.R.C. sec. 162. - 2 Bruce E. Gardner, for petitioner. Scott L. Little, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GUSTAFSON, Judge: This case is before the Court on petitioner Thomas J. Woody’s petition for redetermination of his Federal income tax deficiency for 2004 which the Internal Revenue Service (IRS) determined to be $4,955. The issue for decision is whether Mr. Woody is entitled under section 1621 to deductions claimed on his 2004 Schedule C, Profit or Loss From Business. As a threshold matter, we must decide whether Mr. Woody was actively engaged in the trade or business of real estate investment and rental at the time...
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...July 2004 ITC's eChoupal Initiative Going Direct to the Farmer: ITC’s eChoupal initiative Ravi Anupindi Michigan Business School University of Michigan, Ann Arbor, MI 48105 (anupindi@umich.edu) SCTL Roundtable, July 2004 Background and Credits … Ø 1st year MBA project course at Michigan • 1st phase (Mar-Apr, `03): documentation of eChoupal concept [C.K. Prahalad and MBA students] • 2nd phase (Mar-Apr, `04): Rural retail [myself w/ MBA students] Ø Client site: • Mr. S. Sivakumar, CEO (International Business Division) • Several others … employees, farmers Ø Presentation material • S. Sivakumar (talk at Michigan at the Asia Business Conference, Feb. `04) • Report of the 1st phase MBA project • Dave Upton (HBS case / draft teaching note) 1 Anupindi / MBS SCTL, July 2004 ITC's eChoupal Initiative The New Indian Economy Ø Forex Reserves : $ 100 Bn Ø GDP Growth : 7% Ø Emergence of Indian MNCs Ø India as a Destination of Choice • For Outsourcing • Billion People Market Rural India: The Real India Ø 720 Million Consumers • Potentially a Huge Market è Greater than 70% of population; less than 30% GDP • Small Wallets Ø 156 Million Hectares of arable land in 36 rich & diverse agroecological zones • Potentially Food Factory to the World Ø Government(s) spend a lot of money in developmental activities • Results not consistent with the resources Indian Farmer as a producer & consumer … 2 Anupindi / MBS SCTL, July 2004 ITC's...
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...डॉ. बाबासाहेब आंबेडकर यांचा जिवन पट 1) 14 एप्रिल 1891 - महू, मध्यप्रदेश येथे सैनिक छावणीत जन्म. 2) 1907 - रमाबाई वलंगर यांच्याशी लग्न झाले. 3) 1907 - बाबासाहेब मॅट्रिकची परीक्षा पास. 4) 1910 - इंटरची परिक्षा उतीर्ण 5) 1912 - बी. ए. परिक्षा उतीर्ण. 6) 1912 - पुत्र यशवंतराव यांचा जन्म. 7) 2 फेब्रुवारी 1913 - वडील सुभेदार रामजी यांचे निधन. 1 जुन 1913 - सयाजीराव गाडकवाड यांनी विदेशात अध्यनासाठी शिष्यवृत्ती जाहिर केली. 9) 1913 - उच्च शिक्षणासाठी अमेरिकेला प्रयान. 10) 1915 - ऍन्शंट इंडियन कॉमर्स या प्रबंधावर एम. ए. ची पदवी बहाल. 11) 1916 - नॅशनल डिविडंट ऑफ इंडिया ए हिस्टोरिक अँन्ड अनलिकटिकल स्टडी प्रबंध कोलंबिया विद्यापीठाद्वारे स्विकृत. 12) 1916 - कास्ट इन इंडिया, देअर मॅकेनिझम जेनिसिस अँन्ड डेव्हलपमेँट या निबंधाचे वाचन. 13) 1916 - पी. एच. डी. ची पदवी बहाल. 14) 1917 - मुंबई ला परत आले. 15) 11 नोव्हेँबर 1918 - सिडनहेम कॉलेजमध्ये अर्थशास्राची प्रोफेसर म्हणुण नियुक्ती. 16) 31 जानेवारी 1920 - राजर्षी शाहु महाराज यांच्या साहाय्याने मुकनायक पाक्षिकाचा पहिला अंक प्रकाशित. 17) 1921 - एम. एस. सी पदवी संपादन. 18) 1922 - बॅरिस्टरची परिक्षा पास. 19) 1923 - डॉ. ऑफ फिलॉसॉफी पदवी मिळाली. 20) 1923 - डॉ. ऑफ सायन्सची पदवी बहाल. 21) 1923 - दि प्रॉब्लेम ऑफ रुपी ग्रंथ प्रकाशित. 22) 1923 - बॅरिस्टरीस सुरुवात. 23) 1924 - अस्पृश्य समाजाची परिषद. 24) 20 जुलै 1924 - बहिष्कृत हित कारणी सभेची स्थापना, मुंबई. 25) 1925 - असृश्यांसाठी वसतीगृह स्थापन. 26) जुलै 1926 - राजरत्न या मुलाचे निधन. 27) 1927 - कुलाबा जिल्हा महाड बहिष्कृत परिषद. 28) 3 एप्रिल 1927 - बहिष्कृत भारत या पाक्षिकाचे...
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...SPAM - the central buying office 1932 - foundation of Monoprix 1932 - opening of the bar and restaurant at Haussman 1940 – first sales 1950 - salon de the on the roof terrace 1958 - the first 3J - 3 days when all the employees (even from the offices) help with the sales 1962 - first "corner" - LAURA (Soniya Rykiel) - first corner dedicated to one brand 1969 - opening of Lafayette 2 - the men store today 1973 - opening of Montparnasse 1989 - launch of private brands - avant premiere, jodphur, briefing 1991 - acquisition of new galleries in provence 1993 - creating of private label Kid's graffiti 1997 - opening of GL in Berlin with inverted dome 1993 - acquisition of BHV 2001 - acquisition of Marks&Spencer France 2004 - launching of Lafayette Maison 2009 - the biggest space of shoes in France 2009 - Dubai 2011 - Casablanca 2012 - new project in...
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...MCDONALD’S: POLISHING THE GOLDEN ARCHES VIEWPOINT Jim Cantalupo, Chief Executive Officer and Chairman TIME CONTEXT Year 2004 I. PROBLEM STATEMENT How can McDonald’s adapt to changing market conditions to sustain the growth it had experienced? II. STATEMENT OF OBJECTIVES To have an annual system wide sales growth of between 3 and 5 percent by 2005 and beyond III. AREAS OF CONSIDERATIONS STRENGTHS 1. McDonald’s has the strongest international presence and greatest amount of worldwide sales since the beginning of overseas expansion. 2. It has vast real estate holdings. WEAKNESSES 1. Lack of employee trainings, reflected on its poor service ranking. OPPORTUNITIES 1. With expected growth of the global food-service industry McDonald’s has more opportunity of expansion. 2. With the changing customer preference McDonald’s has the opportunity to come up with more unique and innovative ideas. THREATS 1. Increased domestic expansion led to cannibalization in existing franchises, but this was resolved by focusing more on international expansion. 2. New entrants and existing competitors. 3. Government regulations. IV. ASSUMPTIONS No assumptions. V. ALTERNATIVE COURSES OF ACTION (ACA) 1. Focus on its international expansion. This alternative will focus on its strength of expansion. There will be a continuous growth...
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...Case List for BUS203 Week 2 – Australian Legal System Donoghue v Stevenson (1932) Grant v Australian Knitting Mills (1936) Daniels v White (1938) Wallis v Downard-Pickford (North Queensland) Pty Ltd (1994) Week 3 – Torts Donoghue v Stevenson (1932) Grant v Australian Knitting Mills (1936) Perre v Apand (1999) Rogers v Whitaker (1992) Bolton v Stone (1951) p.92 Paris v Stepney Borough Council (1951) The Flying Fox Case (2005) p.94 Agar v Hyde (2000) p.94 Alexander v Cambridge Credit Corporation (1987) March v Stramare (1991) The Wagon Mound No. 1 Case (1961) – remoteness test Jon Blake Case – contributory negligence Insurance Commissioner v Joyce (1948) – voluntary assumption of risk McCracken v Melbourne Storm (2005) – voluntary assumption of risk Avram v Gusaroski (2006) – voluntary assumption of risk Drunken Possum Hating Cleaner Case (2003) – vicarious liability Week 4 – Business Entities Birtchnell v Equity Trustees (1929) Salomon’s Case [1897] Lee v Lee’s Air Farming Ltd [1961] Gilford Motor Co v Horne [1933] Artedomus v Del Casale [2006] Contracts (week 5) Clarke v Dunraven (1897) Balfour v Balfour (1919) Balfour v.Balfour:⑤丈夫(被告)为英国政府在锡兰(今斯里兰卡)的一个灌溉项目负责人,夫妻婚后在斯里兰卡生活了15年。1915年夫妻回国休假,因妻子患风湿性关节炎,不适合热带气候,遵医嘱留在英国。丈夫出国前给了妻子一张24英镑的支票,作为当月的生活费,并许诺夫妻团聚前,每月给妻子30英镑。1918年3月,双方离婚,妻子得到法定抚养费后起诉丈夫违约,要求支付剩余款项。初审法院支持了其诉讼请求。上诉法院判决,本案的夫妻协议虽有对价,因妻子身患疾病且只身在国内,其支出完全可能超过30英镑,但当事人没有成立合同的意图,故驳回了原告的请求 Wakeling v Ripley (1951) couple, move to aus , taking...
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...wer Résumé Mentorship Program 2004 Power Verbs for Résumé’s Management Skill Verbs: Allocated, Determined, Directed, Elected, Enlisted, Formed, Founded, Governed, Hired, Initiated, Inspired, Instituted, Led, Managed, Moderated, Motivated, Operated, Oversaw, Pioneered, Presided, Produced, Recruited, Represented, Selected, Spearheaded, Sponsored, Staged, Started, Supervised, Trained Organizational Skill Verbs: Arranged, Assembled, Collected, Centralized, Coordinated, Catalogued, Distributed, Disseminated, Enforced, Executed, Formalized, Implemented, Installed, Maintained, Organized, Planned, Prepared, Processed, Routed, Recorded, Reorganized, Scheduled, Updated Communication Skill Verbs: Acquainted, Apprised, Answered, Briefed, Conducted, Contacted, Demonstrated, Drafted, Educated, Explained, Listened, Familiarized, Presented, Handled, Reported, Informed, Instructed, Spoke, Introduced, Lectured, Responded, Summarized, Taught, Trained, Translated, Wrote Analytical Skill Verbs: Analyzed, Assessed, Edited, A udited, Evaluated, Compiled, Examined, Consulted, Gathered, Detected, Identified, Discovered, Interpreted, Documented, Interviewed, Researched, Searched, Surveyed, Tested Helping Skill Verbs: Aided, Attended, Assisted, Collaborated, Helped, Contributed, Counseled, Comforted, Settled, Facilitated, Fostered, Guided, Instilled, Mentored, Provided, Supported, Tutored, Treated Selling Skill Verbs: Arbitrated, Convinced, Dissuaded, Encouraged...
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...BUSINESS FINANCE FINS1613 Tutorial Week 8 Risk & Return Basics 1 CONTACT DETAILS Your Tutor + Tutor‐in‐Charge: Peter Andersen peter.andersen@unsw.edu.au 2 FINS1613 — Peter Kjeld Andersen (2013‐S2) CHAPTER 10: PROBLEM 1 Q. Suppose a share had an initial price of $78, paid a dividend of $1.25 per share during the year and had an ending share price of $87. Compute the percentage total return. Return(%) A. Capital Gain/Loss Dividend Initial Price $1.25 $87 $78 13.14% $78 3 FINS1613 — Peter Kjeld Andersen (2013‐S2) CHAPTER 10: PROBLEM 2 Q. What was the dividend yield in the previous problem? What was the capital gains yield? Dividend Yield(%) A. $1.25 Dividend $78 Initial Price 1.60% Capital Gains Yield(%) Capital Gain/Loss Initial Price $87 $78 11.54% $78 Return(%) Capital Gains Yield(%) Dividend Yield(%) 11.54% 1.60% =13.14% 4 FINS1613 — Peter Kjeld Andersen (2013‐S2) CHAPTER 10: PROBLEM 3 Q. Rework Problems 1 & 2 assuming that the ending share price is $71. A. Dividend Yield(%) $1.25 Dividend $78 Initial Price 1.60% Capital Gains Yield(%) Capital Gain/Loss Initial Price $71 $78 8.97% $78 Return(%) Capital Gains Yield(%) Dividend Yield(%) 8.97% 1.60% = 7.37% Capital Gain/Loss Dividend $71 $78 $1.25 or.... 7.37% Initial Price $78 5 FINS1613 — Peter Kjeld Andersen (2013‐S2) CHAPTER 10: PROBLEM 4 ...
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...NIIT Qualification BSc. Information Technology. Project Management Professional Professional Diploma in Network Centered Computing 2005 NIIT Diploma E-Technology KNOWN APPLICATIONS Windows server 2003 Database using SQL server AutoCAD / REVIT ITIL CCNA WORK EXPERIENCE August 2005 – to Date Duties and Responsibilities Int’l Digitizing Center Accra Ltd.(IDCA LTD) Supports the LANs and application systems Assists in the installation, configuration and deployment of computers, printers and other peripherals Assist in the drafting of Civil Engineering Designs August 2004 – March 2005 Duties and Responsibilities Maintains of networks and system Ghana Shippers’ Council Supports the LANs and application systems Assists in the installation, configuration and deployment of computers, printers and other peripherals PRACTICAL ATTACHMENT March 2004 – June 2004 Duties and Responsibilities Maintains of networks and system Supports the LANs and application systems Assists in the installation, configuration and deployment of computers, printers and other peripherals Assist in the Coding cargo manifest for provision of maritime trade statistics Ghana Shippers’ Council HOBBIES Reading, making friends, and listening to music REFEREE Julius K. Kudzie Ecoband Networks Ltd. RF Engineer Osu, Accra Contact Numbers 024-3119802 054-4337406 Fidel K....
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...departure of the flight, with higher fares charged on flights with higher levels of demand for bookings made nearer to the date of departure. Ryanair’s Dublin to London (Stansted) route is its largest route in terms of passenger volume, with fares ranging from 0.99 to 199.99 (excluding government taxes and passenger service charges). Ryanair’s competitors generally do not operate a one-way pricing policy, so direct comparison is not possible, but current round-trip fares on Aer Lingus, Ryanair’s largest competitor on the LondonDublin route, for travel in September 2004 were 82.27 for economy restricted return tickets, 218.27 for economy flexible return and 353.75 for business class tickets. In July 2004, Ryanair launched a fare promotion offering a total of one million seats on certain routes for “ 0.99” (excluding government taxes and passenger service charges) for travel during the period between September 7, 2004 and January 31, 2005, and launched a similar fare promotion in...
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...September 2004. Business in the Community (2003) Responsibility: Driving Innovation, Inspiring Employees, Fastforward Research, from http://www.bitc,org. uk/resources/publications/ffwd03. html – accessed September 2004. Business in the Community (2004) Accrediting Employee Volunteering: Using volunteering plus to add value to your employee volunteering programmes, Available online at http://www.bitc.org.uk/programmes/ programme_directory/partnership_ academy/volunteering_plus/ – accessed December 2004 CAF (2004) Getting engaged: achieving closer working relationships between companies and local communities, Research and Policy Briefing 2004, Paper 3, West Malling: Charities Aid Foundation. Corporate Citizenship Company (2003) Good companies better employees: how community involvement and good corporate citizenship can enhance employee morale, motivation, commitment and performance, London: The Corporate Citizenship Company. Davis Smith, J. (1998) The 1997 National Survey of Volunteering, London: National Centre for Volunteering. Hardy, R. (2004) Employer supported volunteering and giving: findings from the 2001 Home Office Citizenship Survey, Home Office Research Study 280, London: Home Office Research, Development and Statistics Directorate. HM Treasury (2003) ‘Corporate Challenge: Strengthening community involvement’, http://www.hm- treasury.gov.uk/spending_review/ spend_ccr/spend_ccr_voluntary/ spend_ccr_corpchall.cfm – accessed October 2004. Kramer, M. (2004) ‘Integrating...
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...Welcome, To all the people who are viewing this “Thank You”, because of you it is possible that we spread the love all over the whole world. With that said we would like everyone to know that “God is Love “ and if you’ve been looking for God or either not sure where to find them. We’ll be glad to assist you with that. Mission Statement/ Company Message At Spread the Love our sole purpose is to give to every single living person we touch paths with. We will assist individuals who look to improve there current situation by providing a stable means of communication. For those who enjoy treating others just how they would want to be, treated, this websites just for you! That’s How we Spread Love Baby About Use Centrally located in Newport News, Virginia Spread -The-Love is focused on maintaining a thriving balance of Love and Communication between those of us who seek a better standard of living, a occupation that is promised longevity and wealth, that we may indeed enjoy peace on earth for all generations to witness. Some of you might not understand but How long will you sleep, O sluggard? When will you arise out of your sleep. Like they say, Yet a little sleep, a little slumber, a little folding of the hands to sleep. So shall your poverty Come… So unfold your arms awake from your sleep and put those hands to work because that is how we intend to reach our goals and live out our dreams. By doing what is right we are giving knowledge and love to those who support this...
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...The Plant Location Puzzle 1. Should EDC proceed with the Asian market opportunity? I believe that EDC should proceed with the Asian market opportunity because the saturation point has been almost been reached in the U.S. which means that there is not much room for EDC to expand and grow as a company if they only stay within the U.S. If they move to Asia, there is a growing middle class able to purchase the bikes because they have a more disposable income. 2. If they are going to proceed with the Asian opportunity, where should they locate and why? I think that they should relocate to Taiwan if they proceed with the Asian opportunity, because of Taiwan’s many different resources and better infrastructure. This would ensure that power outages would not be as common as in China. The roads and waterways would be less contaminated if at all, which would allow a potential facility to run more efficiently and at a more eco-friendly level. Taiwan also has a decent-sized population, resulting in a large available workforce. 3. Which part of their business (marketing, production, design/engineering) should be located at their new location? I believe that the new location should focus on production. With all of the resources available at a moment’s notice because of a larger market, production is not slowed when waiting for materials. Also, if the production is done there, money can be saved by not having to ship the materials back and forth between facilities. Each bike can be...
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...Intruding Ima and the Falsified Report An 8-year employee of your police agency, Officer Ima Goodenough, is a patrol officer who often serves as a field training officer. Goodenough is generally capable and experienced in both the patrol and detective divisions. She takes pride in being of the “old school” and has developed a clique of approximately 10 people with whom she gets along while mostly shunning other officers. As an officer of the old school, she typically handles calls for service without requesting cover units or backup. She has had six complaints of brutality lodged against her during the last 3 years. For Ima and her peers, officers who call for backup are “wimps.” She has recently been involved in two high-speed pursuits during which her vehicle was damaged when she attempted to run the offender off the road. Ima will notify a supervisor only when dealing with a major situation. She is borderline insubordinate when dealing with new supervisors. She believes that, generally speaking, the administration exists only to “screw around with us.” You, her shift commander, have been angry about her deteriorating attitude and reckless performance for some time and have been wondering whether you will soon have occasion to take some form of disciplinary action against her. You have also learned that Ima has a reputation among her supervisors as being a “hot dog.” Some of her past and present supervisors have even commented that she is a “walking time bomb”...
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