...Individual Case Individual Case 1 Facts: Mame Green is the owner and operator of the sole proprietorship Green Haven hotel in St. Simons, Georgia. At the beginning of the 2015 tax year, the hotel had a fair market value of $3,000,000 and an adjusted basis of $1,500,000, the hotel furniture and other furnishings had a fair market value of $1,000,000 and an adjusted basis of $100,000, and the hotel had a fair market value of $5,000,000 and an adjusted basis of $3,000,000. Three months ago, Green Haven was completely destroyed by a fair. Green Haven was covered under a fire insurance policy, and as a result, Mame received $4,000,000 after settling the claim. $3,000,000 was allocated to the building and $1,000,000 for the loss of furniture and equipment. Using the $4,000,000, Mame plans to use $3,150,000 to build a smaller hotel on the same land Green Haven was located and $350,000 to purchase hotel furniture and furnishings. Mame plans to use the remaining $500,000 from the proceeds to invest in undeveloped beach property on the other side of the island. The hotel is expected to be completed in 2 ½ years. Issue: 1. Does Mame have to recognize any gain on his $500,000 purchase on undeveloped beach property, and if so, what will the character be? 2. Will Mame have to recognize any gain on the construction of the hotel building or purchase of the replacement furniture and furnshings? Authorities Issue 1 IRC Sec. 1033(a)(2)(A) IRC Sec. 1231(a)(3)(A)(ii) Rev. Rul...
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...My understanding of this is that the film has used a certain scenes that would definitively add towards the development of Australian identity and society. By further analysis of the film rabbit proof fence, it encourages me to believe that this particular scene has used a variety of film techniques such as using different camera shots and foregrounding ideologies throughout, that will contribute towards and further reinforce the attitudes, values and beliefs of Australian identity and...
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...An Analysis of Author’s Purpose in Relation to Theme APA An Analysis of Author’s Purpose in Relation to Theme Thesis: “The Lottery” by Shirley Jackson and “The Rocking-Horse Winner” by D.H. Lawrence differ in author’s purpose in that Jackson satirizes a society that blindly follows tradition, while Lawrence realistically portrays life’s problems; however, both share the theme of family. I. Jackson’s purpose for writing “The Lottery” is to satirize a society that blindly follows tradition. A. Jackson uses the graphic story to show the audience the brutality in society. B. Jackson’s short story also shows how society victimizes those randomly. II. Lawrence uses “The Rocking-Horse Winner” to highlight life’s problems. A. Paul’s mother, Hester, neglects to give her children the attention that they need and deserve to become healthy adults. B. Lawrence grew up in town where coal-mining was the livelihood. Lawrence’s father worked as a coal miner his whole life and expected his sons to do the same. Lawrence knew from an early age that he would not be a miner. C. Lawrence did not do well in school and was often alone and considered different. III. Both Jackson and Lawrence use their purpose for writing to portray theme. A. The lottery is based on family. Each member of every family are listed and must be present during the lottery. B. In “The Lottery” the unlucky person will experience their family turn against him or her...
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...Hyatt Regency walkways collapse left 114 dead and in excess of 200 injured. In addition, millions of dollars in costs resulted from the collapse, and thousands of lives were adversely affected. The hotel had only been in operation for approximately one year at the time of the walkways collapse, and the ensuing investigation of the accident revealed some unsettling facts: During January and February, 1979, the design of the hanger rod connections was changed in a series of events and disputed communications between the fabricator (Havens Steel Company) and the engineering design team (G.C.E. International, Inc., a professional engineering firm). The fabricator changed the design from a one-rod to a two-rod system to simplify the assembly task, doubling the load on the connector, which ultimately resulted in the walkways collapse.1 The fabricator, in sworn testimony before the administrative judicial hearings after the accident, claimed that his company (Havens)...
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...Character types in Schindlers list: Oskar Schindler: Oskar Schindler, war profiteer, womanizer, and Nazi Party member, becomes the unlikely hero and savior of about 1,100 Polish Jews during the Holocaust. He is essentially a con artist and moderately successful businessman who recognizes the potential for profit in wartime. He buys a formerly Jewish-owned enamelware factory and uses bribery and ingratiation to procure military contracts to make war supplies. At the beginning of his quest to become rich, he is indifferent to the Jewish situation, which he sees as merely an unfortunate result of war. A playboy with a large ego, Schindler routinely cheats on his wife and joins the Nazi Party not for ideological reasons but because it will help him make more money. Although he purchases the factory after it has been confiscated from Jewish owners and is given an apartment appropriated from wealthy Jews, Schindler feels no remorse and does not consider the origins of his good fortune. Schindler, initially concerned only with himself and the success of his moneymaking scheme, undergoes a change that prompts him to spend his fortune to save the lives of those he once exploited. His motive is never completely clear—and indeed, the real Schindler never revealed his motivations. However, the film does suggest that at least one of his incentives was obvious: Schindler simply could not sit by and watch people he knew be sent to death. His metamorphosis from a man of indifference to one...
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...Power of Fates: An analysis of Foreknowledge in Das Nibelungenlied Among several mystical components that characterize medieval literature, foreknowledge is the feature that takes a great deal of consideration in practice. Particularly, authors have to determine all kinds of questions as to how, where and what to incorporate in foreknowledge scenes. No matter what decisions being made, they do not go far away from the text’s objectives. Similarly, the thirteenth-century Austrian text Das Nibelungenlied’s author aesthetically integrates foreknowledge into the historical story of the Burgundians in such a creative manner that facilitates its purpose of being a “profoundly moral poem” (Raffel 338). By focusing on the narrative’s two main characters, analyzing how foreknowledge effects their characterizations presents an understanding as to how this supernatural element facilitates the conveyance of moral messages. In form of Krimhild’s dream, foreknowledge appears comparatively early in the narrative. During her protected childhood, this princess has the dream that reveals a heartbreakingly metaphorical incident. On the surface, it unrelatedly displays the image of an ill-fated falcon being killed by two eagles: Living surrounded by splendor Krimhild dreamed a dream: she had a trained falcon, glorious, strong-winged, fierce, and wild, and a pair of eagles tore it apart in front of her eyes. No pain, no sorrows in all the world could be worse than what she’d seen...
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...who may not have the finances for after school help and can double as tutoring help. Hope Haven Hope Haven is children’s clinic and family center for our local families in Jacksonville Florida. Hope Haven is recognized as one of the community's leading nonprofit providers of specialized services for children and their families. It provides tutoring services for children and prices range according to income. Scholarships and financial aid are also available for those who are qualified. If needed, this organization also offers tutoring sessions on school sight. This would allow the tutor and teacher to communicate and come up with the best plan for the child. Studies have been shown that out-of –school tutoring has made a great impact on students, “it concludes that OST tutoring can have positive effects on student achievement (in relation to at-risk students who do not participate), and that effect sizes are larger for programs delivering more than 45 hours of tutoring (but smaller for those longest in duration)” (Heinrich, C…2014). This resource can benefit the student and help them in their troubled areas, which will make homework at home such easier. This resource allows families to be involved and learn with their child. http://www.hope-haven.org/tutoring/ PLAN B As an educator I know that money for tutoring may not be in the budget for most families. Though Hope Haven offers finical help, it is crucial to know that is not the only option for students. Our school...
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...Spawning different subgenres and subcategories within each subgenre, reality television has become a behemoth that dominates a large portion of today’s programming schedule. When most people think “reality television” they think of ordinary people doing crazy things, such as living in a house together, competing to win a record deal, or eating weird insects. But, reality television is actually much larger than many people think, with shows such as COPS, Jerry Springer, and Jeopardy also fitting into the reality television genre. As reality television becomes more and more popular, a disturbing trend has emerged in the way the participants of the shows are portrayed. Many reality television programs use different techniques to portray “characters” that are made to be stereotypes of a certain demographic. Race, ethnicity, gender, sexual orientation, age, and many other characteristics that make up a person have been and are being stereotyped in reality television programs. In some cases, people are cast to be in the show because they satisfy a certain stereotype. In other cases, people are made to be more exaggerated representations of their demographic through editing and instructions from producers on how to act while in front of the cameras. This study will try to determine the reasons behind this phenomenon. REVIEW OF THE LITERATURE Many reality television program producers have admitted to selecting certain people out of the large number of possible candidates to fill...
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...York M. McCombs Agendas: Political The political agenda is the set of issues that are the subject of decision making and debate within a given political system at any one time. Significant research specifically on the topic of agenda setting, as opposed to decision making, dates mostly from the 1960s. Early studies of agenda setting were quite controversial because they were often presented as critiques of the pluralist studies of the 1950s and 1960s. Truman (1951) mostly ignored the issue of who set the agenda of political debate. Dahl (1956) discusses the matter in mentioning that ensuring that no group have control over the range of alternatives discussed within the political system is a requisite for democracy. In his study of New Haven he explicitly raises the question of agenda setting, noting that with a permeable political system virtually all significant issues would likely come to the attention of the elites. ‘Because of the ease with which the political stratum can be penetrated, whenever dissatisfaction builds up in some segment of the electorate party politicians will probably learn of the discontent and calculate whether it might be converted into a political issue with an electoral pay-off’ (Dahl 1961, p. 93). In Dahl’s view, then, any issue with a significant potential following in the public would likely find an elite-level champion, though he also notes that issues with no large-scale electoral pay-off might never enter the agenda. 1. Conflict Expansion E. E...
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...hindler’s ListA CRITICAL ANALYSIS In 1993, the greatest filmmaker of our time did exactly what we expected, and then he turned around and surprised us. That year, for the third time in his career, Steven Spielberg broke the record for the highest-grossing film of all time. Big, grand, and exciting, with dynamite special effects, Jurassic Park was a typical Spielberg film. But while Jurassic Park was breaking records, we heard that Spielberg was in Europe filming, of all things, a black-and-white Holocaust drama. This came as a surprise, but it could never have prepared us for the experience of Schindler's List. And what an experience it is. It's not just another day at the movies, another piece of escapist fare. It is entertaining to be sure, but it is much more than that. It is gut-wrenching, emotional, and visionary. Sitting in the theater, I knew this was something special, a film and an experience I would never forget. Schindler's List is the true story of Oskar Schindler, an undeniably flawed man. A native German, he relocated to Cracow, Poland after it fell into German hands so he could capitalize on Jewish labor at slave wages. There he established an enamelware factory and made obscene amounts of money while wining, dining, and bribing Nazi officials to get his way. But while Schindler was profiting from the Jews' work, he was disgusted by the way the they were treated. He underwent an important change, slowly realizing that this was wrong and that he could do something...
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...Running head: FILM ANALYSIS OF AKEELAH AND THE BEE 1 Film Analysis of Akeelah and the Bee Miranda Clark (5568546) Word Count: 1561 Brock University Running head: FILM ANALYSIS OF AKEELAH AND THE BEE 2 This film is about an 11 year old girl by the name of Akeelah Anderson who has a hidden talent of being a really great speller. However her environment around her seems to interfere with her ability to be more independent and focus on school. Her dad was shot when she was only six, her family ignores her for their priorities such as work, children, and friends. Akeelah joins a spelling being to avoid having to attend detention for her absences at school suggested by her principal and teachers. Akeelah ends up succeeding and making it to the Scripps National Spelling Bee where she ends up winning the competition. I chose this film over the other films that were options because it was a film I have not seen yet as well as I felt like it would be a great film to analyze because of the black community the film is based in due to the fact that a lot of neglect and racism happens in black communities. Depending on the surroundings of these communities, children react differently based on what occurs. In this film, children and youth are depicted very differently depending on their surroundings as well as family situation. Akeelah is growing up in a community where bullying and racism occurs more often due to race and culture. An example of this in the film is when some...
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...individuals or small groups and can best be understood as “disorganized crime.” Yet there is growing evidence that organized crime groups or mafias are exploiting the new opportunities offered by the Internet. Organized crime and cyber-crime will never be synonymous – most organized crime will continue to operate in the real world rather than the cyber-world and most cyber-crime will continue to be the result of individuals rather than criminal organizations per se. Nevertheless, the degree of overlap between the two phenomena is likely to increase considerably in the next few years. This is something that needs to be recognized by business and government as an emerging and very serious threat to cyber-security. Accordingly, this analysis sets out to do three things: 1. Explain why the Internet is so attractive to criminals in general and to criminal organizations in particular. 2. Identify some clearly discernible trends that provide important clues about ways in which organized crime and cyber-crime are beginning to...
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...Running head: Oedipus-A Tragic Hero Research Paper ENGL 102: Literature and Composition) Fall 2015 Melinda Meeds L26683811 APA Outline Thesis: In Sophocles’ “Oedipus”, Oedipus is exemplified as a tragic hero according to Aristotle’s definition because his story appeals to the reader’s humanity in the way he maintains his strengths after inadvertently causing his own downfall. I. Oedipus A. The noble birth. B. Describe Oedipus’ character. II. Tragedy A. Describe what a tragedy is. B. Describe the tragedies Oedipus has faced. III. A tragic hero A. Describe what makes Oedipus a tragic hero. B. Describe how Oedipus handles life after the pitfalls he has faced. Oedipus-A Tragic Hero Sophocles’ Oedipus is a very well-known tragic hero in dramatic literature. Oedipus, in the story, is a king with a great personality however his morality is what leads him to his demise. This mish mash of Oedipus’ disposition is what leads a reader to feeling sympathetic. In Sophocles’ “Oedipus”, Oedipus is exemplified as a tragic hero according to Aristotle’s definition because his story appeals to the reader’s humanity in the way he maintains his strengths after inadvertently causing his own downfall. According to Aristotle, "a man doesn't become a hero until he can see the root of his own downfall” (Hume, n.d.). In Sophocles’ Oedipus, Oedipus possesses specific qualities that allow him to be considered a tragic hero. These qualities include...
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...With his impact on the 20th century, Heller managed to create an intense feeling of moral conflict and views on the political times of World War II with satirical comedy, his character, Yossarian’s, expressions and his critical orientation on the War setting he is currently situated in. Through Heller and ”Catch-22” ,a solely American phrase was born as the classic ‘Stalemate’ phrase, a no-win situation that applies to real life and veterans at home, something relatable to the public and readers. Imagery of falsehood in reality. Institution is based on expectations and reality in the book. When Colonel Cathcart and Peckham agree to move the bombline and have missions set for Bologna(Ch.12), Yossarian and his mates prepare for suicide as this...
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...Cymbeline, I tended to want to find the archetypal vices in the heros of the play. Among the most honorable characters: Posthumous, Imogen, Guiderius, and Arviragus, we find that only Posthumous seems to have the only recognizable character flaw in bargaining off his wife for gold. In almost all respects, the children of Cymbeline are perfect characters within the Elizabethan patriarchal ideal. The three of them have an incomplete parentage in the play, having an absent mother, and being displaced in the case of the boys. With the role of motherhood being so very important to child-development, the question becomes: how did these perfect characters get this way without the essential role of the mother? Of course in the heavily misogynistic society, the mother plays the part of enemy even in parenting, as the female body and character is something that must be conquered in order to successfully rear virtuous sons. In this play, this challenge is sidestepped by Cymbeline’s claim to motherhood. In Cymbeline, Shakespeare creates a familial fantasy within which the role of the mother is fully excised from the gender play of traditional Elizabethan parenthood, fostering purely masculine childrearing. Cymbeline takes on the role of the mother, embodying a purer space for child development that rids itself of the female body: the source of contamination to the ideal masculine character and form. This makes his children perfect in each of their respective personas, who are at that advantage...
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