Punk Era Essays - Punk Rock Genres, Punk Rock, Proto-punk

Punk Era Sex, medications, and awesome was the mobilizing weep for a development that changed American culture until the end of time. Awesome previously frightened the American scene in the mid-1950's, however nobody at that point could have anticipated the striking essentialness and backbone of this new music. The early convention of rock has experienced numerous advances. Provocative and stunning stage clothing and conduct have been a significant asset since the introduction of awesome. Decades following the introduction of awesome, many have seen a consistent ever changing motorcade of haircuts, outfits, motions and props. As the degree of resilience and acknowledgment developed, demigods received progressively odd and stunning pictures. It is in this setting punk rock, seen by some as an alarming new course in the late 1970's must be thought of. Awesome music accomplished another decency and force simultaneously (Ward, Stokes, Tucker, Rock of Ages, 547). Punk was rock's most outstanding endeavor in the late 1970's to infuse furious, insubordinate, chance bringing documentations into the music. The melodic style called underground rock created in the United States out of crude and enthusiastic music played by the carport groups of the mid-sixties. These groups were primarily youngsters playing essential guitar harmonies, and flopping endlessly at drums and cymbals in their own carports. This brought about sounds that were harsh, crude, and musically wayward, which communicated their inclinations and carried music to their level (Charlton, Rock Music, 204). Given that the best carport groups could grain play, we may accept not just that virtuosity has nothing to do the structure, yet additionally that the Utopian long for each man and craftsman can work out as expected right here, in our rural place that is known for new chances at life - a definitive evidence that awesome is the generally vote based and all-American of fine arts (Miller, History of Rock and Roll, 261). While young carport groups were turning into a hit and making it onto the pop outlines, marginally more established, masterfully prepared however spiked performers were composing verse and singing about urban rot. This creative articulation was most certainly not the principal, this kind of thought far aesthetic articulation had been at the foundation of a few scholarly, aesthetic, and melodic styles in the twentieth century, counting the dadaist development and the Beat development (Charlton, Rock Music, 204). The dadaists, a gathering of specialists from Switzerland, communicated their perspectives of frenzy and turmoil exemplified by World War I. The dadaists saw this sort of decimation and demolition of human life that occurred during the Was, and communicated their perspectives by forming craftsmanship out of garbage or other material put together in a riotous structure. A similar dread of the potential human creature had for brutality, alongside the magnificent intensity of current weapons, impacted numerous later specialists to share the worries and copy crafted by the dadaists (Charlton, Rock Music, 204). The Beat artists and essayists of the fifties, coordinated their sentiments of outrage towards society in their verse and compositions. The way in which the Beats straightforwardly went up against the issues that a great many people disregarded, as well as the dada, affected want to deliver an enemy of workmanship to communicate the conviction that society had lost all feeling of significant worth was at the philosophical base of the punk development, which in the long run brought forth a style of music (Charlton, Rock music, 204). The most terrific case of a hazardous, forceful, skeptical yet eager reasonableness worming it route into the stone world was the man many called a adoptive parent of punk: Lou Reed (Ward, Stokes, Tucker, Rock of Ages, 547). Lou Reed remains as urgent figure in 1970s stone. Reed composed verse about road life, prostitution, and medications in New York. He was Classically prepared to play the piano, yet felt he was unable to communicate what he needed to state about society playing Mozart (Charlton, Rock Music, 204). Reed consolidated questionable basic spots with a significant negativity to yield music. Reed kept up a profoundly antagonistic relationship with his crowd. He would affront them one moment and challenge them the following. Reed's impact on others, fortunate or unfortunate, can be heard in the work of different rockers, for example, David Bowie and The New York Dolls. Before there was Lou Reed as an independent craftsman, there was the Velvet Underground, a band that in the middle of the idealistic, opportunity adoring, feel-great 1960's, proffered end of the world, compulsion, and feel terrible. The Velvet Underground left customary awesome styles aside to explore different avenues regarding new types of articulation. The Velvet Underground comprised of Lou Reed, Sterling Morrision, John Cale,

Motorcycle and Hero Honda Essay Example

Cruiser and Hero Honda Essay File 1. Prologue to HERO MOTOCORP 2. Organization Profile 3. Rundown of Board of Directors 4. Grants and Achievements 5. 4P’s of the Company 6. Item Information 7. Item Mix 8. Division 9. Dissemination procedure 10. Rivalry 11. SWOT Analysis 12. Overview 13. List of sources Hero MotoCorp formerly Hero Hondaâ is aâ motorcycleâ andâ scooter maker situated in India. Legend Honda began in 1984 as a joint endeavor between Hero cyclesâ of India and Honda of Japan. The organization is the biggest bike maker in India. The 2006 Forbes 200 Most Respected organizations list has Hero Honda Motors positioned at 108. In 2010, When Honda chose toâ move out of the joint venture, Hero Group purchased the offers held by Honda. Along these lines, in August 2011 the organization was renamed Hero MotoCorp with another corporate personality Termination of Honda joint endeavor In December 2010, the Board of Directors of the Hero Honda Group have chosen to end the joint endeavor between Hero Group of India and Honda of Japan in a staged way. The Hero Group would purchase out the 26% stake of the Honda in JV Hero Honda. Under the joint endeavor Hero Group couldn't fare to global markets (aside from Sri Lanka) and the end would imply that Hero Group would now be able to send out. Since the start, the Hero Group depended on their Japanese accomplice Honda for the innovation in their bicycles. So there are worries that the Hero Group probably won't have the option to continue the exhibition of the Joint Venture alone Hero MotoCorp The new brand character and logo, Hero MotoCorp, was created by the London firm  The logo was uncovered on 9 August 2011 in London, the day preceding the third Test coordinate among England and India. We will compose a custom article test on Motorcycle and Hero Honda explicitly for you for just $16.38 $13.9/page Request now We will compose a custom article test on Motorcycle and Hero Honda explicitly for you FOR ONLY $16.38 $13.9/page Recruit Writer We will compose a custom paper test on Motorcycle and Hero Honda explicitly for you FOR ONLY $16.38 $13.9/page Recruit Writer Legend MotoCorp would now be able to fare to Latin America, Africa and West Asia. Legend is allowed to utilize any sellers for its segments rather than just Honda-affirmed merchants. Company’s execution During the financial year 2008-09, the organization sold 3. 7 million bicycles, a development of 12% over a year ago. Around the same time, the organization had a piece of the pie of 57% in the Indian market. Saint Honda sells more bikes than the second, third and fourth positioned bike organizations set up. Saint Hondas bike Hero Honda Splendorâ sells more than one million units for every year. Absolute unit deals of 54,02,444 bikes, development of 17. 44 percent Total net working pay of Rs. 19401. 15 Crores, development of 22. 32 percent Net benefit after assessment at Rs. 1927. 90 Crores Total profit of 5250% or Rs. 105 for each offer including Interin Dividend of Rs. 70 for each offer on face estimation of each portion of Rs. 2 each EBIDTA edge for the year 13. 49 percent EPS of Rs. 96. 54â - History Hero MotoCorp was begun in 1984 as Hero Honda Motors Ltd. 1956 Formation of Hero Cyclesâ in Ludhiana(majestic auto restricted) * 1975 Hero Cycles becomes biggest bike maker in India. * 1983 Joint Collaboration Agreement with Honda Motor Co. Ltd. Japan consented to Shareholders Arrangement marked * 1984 Hero Honda Motors Ltd. consolidated * 1985 Hero Honda bike CD 100 propelled. * 1989 Hero Honda cruiser Sleek propelled. * 1991 Hero Honda bike CD 100 SS propelled. * 1994  Hero Honda bike Splendorâ launched. * 1997 Hero Honda cruiser Street propelled. * 1999  Her o Honda bike CBZ launched. 2001  Hero Honda cruiser Passionâ and Hero Honda Joy propelled. * 2002 Hero Honda bike Dawn and Hero Honda cruiser Ambition propelled. * 2003 Hero Honda , bike CD Dawn, Hero Honda cruiser Splendor, Hero Honda bike Passion Plus and Hero Honda bike Karizmaâ launched. * 2004 Hero Honda bike Ambition 135 and Hero Honda bike CBZ* propelled. * 2005 Hero Honda bike Super Splendor, Hero Honda bike CD Deluxe, Hero Honda cruiser Glamor, Hero Honda bike Achiever and Hero Honda Scooter Pleasure. 2007 New Models of Hero Honda bike Splendor NXG, New Models of Hero Honda cruiser CD Deluxe, New Models of Hero Honda bike Passion Plus and Hero Honda bike Hunkâ launched. * 2008 New Models of Hero Honda bikes Pleasure, CBZ Xtreme, Glamor, Glamor Fi and Hero Honda bike Passion Pro propelled. * 2009 New Models of Hero Honda bike Karizma:Karizma ZMR and restricted version of Hero Honda bike Hunkâ launched * 2010 New Models of Hero Honda bike Splendor Pro and New Hero Honda bike Hunk and New Hero Honda Motorcycle Super Splendor propelled. 2011 New Models of Hero Honda bikes Glamor, Glamor FI, CBZ Xtreme, Karizma propelled. New permitting course of action marked among Hero and Honda. * August 2011 Hero and Honda go separate ways, consequently shaping Hero MotoCorp and Honda moving out of the Hero Honda joint endeavor. * November 2011 Hero propelled its first ever Off Road Bike Named Hero Impulse CHAIRMAN’S PROFILE |  | Dr. Brijmohan Lall Munjal Dont dream in the event that you cannot satisfy your fantasies Brijmohan Lall Munjal is frequently attached to stating. The organizer and patriarch of the $3. 2 billion Hero Group is your exemplary original business person. He is a man who began little, thought ambitiously and utilized a blend of coarseness and determination to make one of the countrys biggest corporate gatherings and the Worlds No. 1 Two Wheeler Company. | Instinctive since early on, Brijmohan Lall made a somewhat uncommon beginning throughout everyday life. Around when the opportunity development in India was coming to fruition in the late 1920s, he strolled into a recently opened Gurukul (Indian legacy school) close to his home in Kamalia (presently in Pakistan). He was just six years of age at that point. In this manner started an unprecedented story of boldness and constancy. Brijmohan started his business story after segment in 1947, when he and his siblings migrated to Ludhiana. The family set up an organization that furnished needy individuals with essential vehicle (cycles). After three decades, as India developed, he included a second critical section which pictured reasonable and mechanically better vehicle than a huge number of white collar class Indians. The rest is history. Building Relationships When Brijmohan and his siblings began, there was no understanding of sorted out vendor systems. Organizations just created, and most sellers worked like dealers. Brijmohan changed the principles of the business by confiding in his gut impulses; presenting business standards that were comparatively radical, and by putting resources into vital connections. Brijmohan assembled a progression of bonds and systems with many relatives, sellers, vendors and representatives. Much like the Japanese keiretsu framework, these systems are currently the paste that holds the Hero Group together. On account of the connections that we have supported so energetically in the Hero Family, the more youthful ages of a portion of our bike vendors have become sellers of Hero MotoCorp. These connections have made due through ages through terrible occasions and great occasions the patriarch now memories. Other than holding with his merchants and sellers, Brijmohan has been by and by answerable for fuel a feeling of business enterprise among his workers, and today, 40 of his previous representatives are effective business visionaries. Remaining Ahead Though not in fact qualified in the ordinary sense, not many of his counterparts have comprehended the elements of innovation better than Brijmohan Lall has. He could generally imagine the appropriateness of innovation before others could. For instance, during the 1980s, when every one of the bike organizations in India settled on two-stroke motor innovation, Brijmohan favored a four-stroke motor an innovation that significantly expanded eco-friendliness and diminished support costs. This innovation was perhaps the most compelling motivation for Hero MotoCorps terrific achievement. A Corporate Citizen A thrifty childhood and a worth framework displayed on the renowned Gurukul framework which focuses on the sacredness of the instructor understudy relationship soaked up in Brijmohan a solid feeling of social duty and obligation. There is an extraordinary spot in his heart for Ludhiana, the city where he took roots. Today, Ludhiana is a cutting edge, clamoring city, yet Brijmohan has assumed no mean job in its advancement. A few schools and instructive establishments in Ludhiana owe their reality to the Munjal family. The Ludhiana Stock Exchange owes its reality to Brijmohans vision as does the Ludhiana Flying Club. Hes likewise set up the not-revenue driven Dayanand Medical College and Hospital-an organization presently evaluated as a standout amongst other clinical universities in India, as far as foundation, nature of staff and graduated class profile. In and around Dharuhera, close to the primary Hero MotoCorp plant, Brijmohan and his family have left their stamp of charity. The Raman Kant Munjal Foundation which Brijmohan set up in memory of his oldest child, today runs a higher auxiliary school and an exceptionally present day and well-prepared 100-bed medical clinic at Dharuhera. The gathering has likewise embraced various towns and gives instruction, professional preparing, drinking water, streets, streetlights and sewerage. Dr. Brijmohan Lall Munjal Chairman Message from Management What the caterpillar considers the end the remainder of the world calls a butterfly. ~Lao Tzu~ Constant improvement has been the key fuel that has controlled the motors of this organization since initiation. Cheerfully, we are presently expanding on that force to go further in our excursion of market authority and corporate greatness. Subsequent to producing together one of the universes generally productive and fruitful joint endeavors for o

Waitlist Wrap-Up 2008

Waitlist Wrap-Up 2008 This afternoon, we notified the 64 students remaining on the waitlist that we do not have any more room in the class, and will not admit any additional students from the waitlist this year. The decision not to admit any more from the waitlist was especially difficult, as there were many really great students on the waitlist who we wished we had room for. We appreciate your having been able to wait with us into the early summer. This was an extraordinary year across the admissions landscape, with some of our peer institutions needing to admit greater than 200 students from their waitlists. Large waitlist movement at a few schools has ripple effects, requiring longer waitlists at many colleges this year. Were glad that things have now settled down enough that we can conclude our admissions for this year and let the remaining waitlist students focus on their schools for the fall. To those of you who stuck with us on the waitlist, thank you, and we wish you all the best at your college in the fall we know you will have a terrific and successful experience. Best wishes, MIT Admissions Waitlist Committee

Hookah Bar Business Plan - Free Essay Example

Sample details Pages: 14 Words: 4281 Downloads: 10 Date added: 2017/09/19 Category Business Essay Type Argumentative essay Did you like this example? Cowboy HookahTM Business Proposal Executive Summary Cowboy Hookah is a hookah bar concept that will be located in Laramie, WY to serve as an alternative place for customers to relax and enjoy a cultural experience. The focus will be to bring in students from the University of Wyoming and community members as well as young professionals in the area. The bar will be located in downtown Laramie and be managed by a team of four owners. The business will generate revenues through the sale of flavored tobacco, non-alcoholic beverages and snacks. Cowboy Hookah will enter the market with a competitive advantage given that there are no hookah bars in Laramie. Cowboy Hookah projects to be earning profits by its first year of operation. Below are the projected gross income, total expenses and net income. The business projects growth of 50% the first year and 25% the next two years with more sustainable growth after that period. Since the company is in the introductory stage it is exp ected to see a lot growth after opening. 1. Objectives Cowboy Hookah’s objectives for the first year of operations are: †¢Effectively corner a niche market for a previously non-existent business. Turn in profits from the first month of operations. †¢Maintain a 65% gross margin. 2. Keys to Success The keys to success will be: †¢Store design that is deemed legally acceptable and will be both visually attractive to customers, and designed for efficient operations. †¢Employee training to insure the best education and knowledge of products and preparation techniques. †¢Marketing strategies aimed to build a solid base of loyal customers, as well as maximizing the sales of high margin products, such as our line of hookah products. 3. Mission Cowboy Hookah will give its best effort to create a unique place where customers can socialize with each other in a comfortable and relaxing environment while enjoying the best brands of smoking tobacco and products i n town. We will be in the business of helping our customers to relieve their daily stresses by providing piece of mind through great ambience, convenient location, friendly customer service, and products of consistently high quality. Cowboy Hookah will invest its profits to increase the employee satisfaction while providing stable return to its shareholders. Company Summary Cowboy Hookah is a new company that provides knowledge and expertise in hookah smoking along with a lounge for people to relax in a cultural environment with their friends while enjoying smoking flavored tobacco. The concept for our hookah lounge centers around the community of Laramie and being available to the people for them to have a new experience. The business will launch its first hookah lounge in Laramie within the next six months and hopes to create a modern, cozy, hookah bar with knowledgeable employees and guaranteed high quality service and products while at a reasonable price. The business will earn revenues through the sale of tobacco (multiple flavors), drinks (coffee, tea, and juices), food (Pastries, hummus and chips, etc) and hookah products. The customers are expected to be those interested in hookah and hookah culture, and young (18-25 years old) students interested in a community-oriented experience that is an alternative to bars serving alcohol and coffee shops. 4. Company Ownership Cowboy Hookah will be registered as a Limited Liability Corporation in the state of Wyoming. 5. Start-up Summary We will need initial start-up funding of approximately $265,000 to get our hookah bar up and running. The funding will be mainly through financing but we will need at least 20-30% through equity in order to have enough money in the deal to make this a favorable loan. We will maintain a cash reserve at startup in order to cover approximately two months of expenses. The expenses covered by this reserve will not include cost of goods sold as we will also have enough dedicat ed cash equivalents to purchase two months of inventory. †¢Legal expenses for obtaining licenses and permits totaling $1,300. †¢Marketing promotion expenses for the grand opening of Cowboy Hookah in the amount of $3,500 and as well as flyer printing (2,000 flyers at $0. 4 per copy) for the total amount of $3,580. †¢Insurance (general liability, workers compensation and property casualty) coverage at a total premium of $2,400. †¢Premises remodeling in the amount of $20,000, which, we consider to be sunk costs because it will not significantly increase the value of the property. †¢Other start-up expenses including stationery ($500) and phone and utility deposits ($2,500). The required start-up assets of $235,000 include: †¢Operating capital in the total amount of $40,000 which includes cash reserves of $27,000 and inventory for the first two months of operation. Start-up inventory of $7,657, which includes: oHookah tobacco $3,000 oCoffee filters, baked g oods, salads, sandwiches, tea, beverages, etc. $3,450 oRetail supplies (napkins, coffee bags, cleaning, etc. ) $920 oOffice supplies $287 †¢Equipment for the total amount of $25,000: oSmoking apparatus and equipment $3,000 oFood service equipment (microwave, toasters, dishwasher, refrigerator, blender, etc. ) $3,000 oStorage hardware (bins, utensil rack, shelves, food case) $2,720 oCounter area equipment (counter top, sink, ice machine, etc. $4,750 oServing area equipment (plates, glasses, flatware) $1,495 oStore equipment (cash register, security, ventilation, signage) $5,935 oOffice equipment (PC, fax/printer, phone, furniture, file cabinets) $3,600 †¢Purchase and remodel of the Building in the amount of $190,000: oBuilding $170,000 oRemodel (Sunk Costs) $20,000 Funding for the company comes from two major sourcesowners investments and lender financing. The owners will contribute $80,000, $20,000 of which will be immediately sunk into the remodel. The rema ining $185,000 needed to cover the start-up expenses and assets will come from two bank loans and short-term debt instruments. The two loans will consist of a 10 year loan in the amount of $29,000 and a 30 year mortgage on the building of $136,000. Both loans will be secured through the First National Bank. The additional $20,000 of financing needs will use distributor financing through their accounts payable and will be used in the purchasing of inventory and other supplies. Start-up Requirements Start-up Expenses Legal$1,300 Stationary$500 Brochures/Flyers$3,500 Insurance$2,400 Remodeling$20,000 Other$2,300 Total Start-up Expenses$30,000 Start-up Assets Cash Required$27,000 Start-up Inventory$6,500 Other Current Assets$6,500 Long-term Assets$195,000 Total Assets$235,000 Total Requirements$265,000 Start-up Funding Start-up Expenses to Fund$30,000 Start-up Assets to Fund$235,000 Start-up Funding Required$265,000 Assets Non-cash Assets from Start-up$195,000 Cash Requirements for S tart-up$13,000 Additional Cash Raised$0 Cash Balance on Starting Date$27,000 Total Assets$235,000 Liabilities and Capital Liabilities Current Borrowing$29,000 Long-term Liabilities$136,000 Accounts Payable$20,000 Other Current Liabilities$0 Total Liabilities$185,000 Capital Planned Investment (Owner Contributions)$80,000 Additional Investment Required$0 Total Planned Investment$80,000 Loss at Start-up($30,000) Total Capital$40,000 Total Liabilities and Capital$195,000 Total Funding$265,000 6. Company Locations and Facilities Location and Legalities The majority of funding will go towards our building and property. We will be purchasing a two unit commercial building in downtown Laramie on the corner of 1st and Grand Avenue. We believe this to be a prime location which will have a large positive impact on our exposure and growth. Because of the remodeling needed to convert one unit of 106/108 Grand Avenue into an outdoor patio we have elected to purchase the building rather tha n rent. This does increase our initial costs but the remodel is necessary in order to conform to the smoking ban, Title 8, Chapter 8, of Laramie, WY Municipal Code. For this remodel we have budgeted $20,000 which we consider to be sunk costs as it will not significantly affect the value of the property. The remodel will consist of removing upper portions of two walls and installing additional supports and sliding glass doors. By doing this it will allow us to conform to Laramie Municipal Code because the structure will then have only two walls and be considered an outdoor patio, which therefore will fall under 8. 56. 050 where smoking is not regulated. This conforms to the City of Laramie’s Attorney recommendations. The floor plan will include a 50 square feet back office and a 1200 square feet Hookah bar, which will include a seating area with 10 tables, a kitchen, storage area and two bathrooms. The space in the hookah bar will be approximately distributed the following way1,200 square feet (i. . , 55% of the total) for the seating area, 600 square feet (26%) for the production area, and the remaining 440 square feet (19%) for the customer products service area. This property is located in a commercial area within a walking distance from the University of Wyoming campus on the corner of a major thoroughfare connecting affluent neighborhoods with the busy downtown commercial area. The commercially zoned premises have the necessary water and electricity hookups and will require only minor remodeling to accommodate the hookah bar, kitchen and storage area. The hookah bars open and clean interior design with modern wooden decor will convey the quality of the served beverages and snacks, and will be in-line with the establishments positioning as an eclectic place where people can relax and enjoy their hookah experience. The clear window displays, through which passerby will be able to see customers enjoying the atmosphere, and outside electric signs will be aimed to grab the attention of the customer traffic. 7. Product Description/Products Hookahs for Sale range from $30. 00 to $150. 00 to purchase These include the following pieces: Pyrex Bowl †¢Snap-on tray †¢Stainless Steel Valve †¢One-way valve †¢Glass Base †¢Custom Hose †¢Bowl Grommet †¢Hose Grommet †¢Base Grommet The Python: 28 Multiple Hose Rotating Hookah The Python Multiple Hose Hookah is the first type of Hookah model to be fully customized for todays Hookah smoker. This Hookah has been designed with superior craftsmanship for complete authenticity and quality. The Python rotates a full 360 degrees to allow for durability and flexibility with the individual Hookah smoker. The Python may always be converted depending on how many users are available. This Hookahs durable design allows for ease with setup and maintenance. The Neptune: 33 Double Hose Hookah The Neptune is a larger Hookah model designed specifically for producin g a great smoking experience. This Hookah model may be converted to a one hose model if two users are not available. This Hookahs durable design allows for ease with setup and maintenance, while providing entertainment for years to come. The Zeus: 33 Single Hose Hookah The Zeus is a larger Hookah model designed specifically for producing a great smoking experience. This Hookahs durable design allows for ease with setup and maintenance. The Colossus: 33 Triple Hose Hookah The Colossus is primarily used by Hookah smokers who are interested in smoking with a larger group of friends. Although this model allows for up to three hookah users, it may always be converted into a two or one hose model. This Hookah may be used for both decorative and smoking pleasures, providing entertainment for years to come. The Helios: 26 Triple Hose Hookah The Helios is a smaller version of the Colossus, but still offers a great smoking experience. This Hookah allows for up two three users, but may alwa ys be converted into a two or one hose model. Whether smoking alone or with a group of friends, this Hookah is guaranteed to make an undeniable presence at any party. Hookah Sessions- Each session consists of the customers’ choice of size of hookah. Larger crowds usually get larger hookahs with more hoses. Then they can choose flavors of tobacco to use. Flavored tobacco for hookah pipes will be sold as well for $15 for the first round and $12 for subsequent rounds. Each round last approximately from 30 to 45 min. Flavors include: †¢Cherry †¢Strawberry †¢Blackberry †¢Mixed Fruit †¢Apple †¢Blue Mist †¢Candy †¢Jasmine †¢Banana †¢Rose †¢Grape †¢Pistachio †¢Lemon †¢Cola †¢Mint †¢Orange †¢Peach †¢Vanilla Mango †¢Blueberry †¢Grape †¢Purple Haze †¢Raspberry †¢Coconut †¢Melon Berry A quick lighting coal made by Miraculum Coal brand. Miraculum Coals formula allows for the charcoal to light faster as well as maintain a more even and consistent burn throughout without interfering with the flavor of tobacco, making it the most sought after quick lighting charcoal brand available. These Charcoals are manufactured in Holland, and are specifically designed for smoking with the Hookah. Cowboy Hookah wants to keep our prices low and competitive. Each customer has the option of what hookah size they want to use and how many types of tobacco they would like. We hope to keep bringing new flavors to the shop so people can continue to try new things. In the future we would also like to start selling hookahs of different sizes and shapes. Food and Drink The initial menu includes: †¢Assortment of organic teas †¢Assortment of organic coffees †¢Fruit juices and juice blends †¢Salads †¢Pita or pita chips and hummus/other dips †¢Assorted pastries 8. Sales Literature Two thousand flyers will be distributed in the adjacent neighbo rhood, on the University campus, and in the selected office buildings within two weeks prior to the opening of Cowboy Hookah. Subsequently, free postcards with Cowboy Hookah endorsement will be printed to increase the company visibility among the patrons. Market Analysis Summary U. S. tobacco consumption has shown level growth. They favor new and interesting smoking experiences and demand great service. Laramie, Wyoming, with its liberal and outgoing populace and long winter, has traditionally been a great place for establishments that have great atmosphere. Cowboy Hookah will strive to build a loyal customer base by offering a great atmosphere in a relaxing environment of its hookah bar, located close to the ustling University of Wyoming campus. The market for hookah bars in the United States has grown significantly in the past decade. Hookah-bars. com reports that, as of October 2008, there were at least 470 hookah bars in the U. S. and an average of five new hookah bars were o pening every month. From these numbers, it can be estimated that 2-5 million current hookah smokers live in the United States. Of these hookah smokers, approximately 90% are of American origin but have grown to embrace hookah culture. In Laramie, Wyoming, Cowboy Hookah Bar will focus on college students, Community members and young professionals. . Market Segmentation Cowboy Hookah will focus its marketing activities on reaching the University students and faculty, people working in offices located close to the hookah bar and on sophisticated adults who are eighteen years old or older. Our market research shows that these are the customer groups that are most likely to buy our products. Since tobacco consumption is universal across different income categories and mostly depends on the level of higher education, proximity to the University of Wyoming campus and local bars will provide access to the targeted customer audience. College Age Residents: College students who seek an alt ernative to bars and parties on campus seek out different ways to hang out with friends. Hookah bars provide such an experience because of their exotic ambiance, colorful atmosphere, focus on group dynamics, and a unique place in Laramie without alcohol. Furthermore, those between the ages of 18 and 20 can patronize hookah bars while they cannot go to the bars that serve alcohol. Laramie has plenty of bars, but lacks spots for those under 21 to socialize with each other. Young Professionals: 18-30 years-old professionals who are tired with bar culture here in Laramie are looking for other activities. They seek locations where they can socialize with friends, talk, and share a new experience. Hookah bars make a great substitution for these individuals. According to the 2000 census there were 27,204 people living in Laramie. Out of this 31. 8% were 18-24. This group of 8,651 makes up our market segment. According to our survey that participants took online, 50% of people ages 18-20 would be patron of a hookah bar in Laramie. Out of the participants surveyed, 48% in the age range of 21-24 said they would patronize a hookah bar in Laramie. This means that roughly 50% of the 8,651 or 4,325 individuals between the ages of 18-24 in Laramie would patronize a hookah bar in Laramie. 10. Target Market Segment Strategy Cowboy Hookah will cater to people who want to unwind and enjoy the company of friends in a relaxing atmosphere. Such customers vary in age, although our location close to the University campus means that most of our clientele will be college students and faculty. Our market research shows that these are discerning customers that gravitate towards a new experience. Furthermore, many college students consider hookah bars to be a convenient studying or meeting location, where they can read or meet with peers without the necessity to pay cover charges. For us, this will provide a unique possibility for building a loyal client base. To attract these yo ung students and young professionals residing in Laramie, Cowboy Hookah will position itself as an alternative to bars. We will attract them by giving them a place to socialize without having to drink alcohol. This will also give young students between the ages of 18-20 a place where they can hang out at night since they can’t go to any bars in Laramie. Along with having hookahs available to partake in smoking we will also market snacks and non-alcoholic beverages. Competition There is currently no hookah bar in Laramie; the company will have no competitors within this industry. Bars and the bowling alley will not be considered as competitors as a substitute for our services since most are restricted under the smoking ban. That means our customer will be willing to come to any location in Laramie to relax at a hookah bar. With no competitors we will not need to worry about differentiating our service or product. This makes it easy for us to meet the needs of our custome r. Website Marketing Strategy The website for Cowboy Hookah will be promoted through public relations, direct advertising, search engine optimization, and the growing community of customers. †¢Public relations events will include handing out handbills around campus. Hanging posters around the town at popular locations promoting an event. †¢Direct advertising will include Google ads and Facebook ads. We can advertise directly to our target market with Facebook. The community of customers will generate word-of-mouth and online referrals by inviting friends to become fans of Cowboy Hookah on Facebook. Development Requirements Development of the website requires an experienced Web development firm. The website will include the following in its basic, front end: †¢About Us background on the business and its concept and mission †¢FAQs about hookah smoking, etc. †¢Menu of food, drinks, and tobacco †¢Photo gallery †¢Contact page †¢Location and Direct ions page with connection to maps from Google Maps Furthermore, the management will create and regularly update a Facebook fan page. They will update the information on the fan page including: †¢Upcoming events, including live music and bands †¢Photos of the events and the hookah bar †¢New flavors, products or discounts 11. Market Needs General trend toward quality among U. S. consumers definitely plays an important role in the recent growth in the hookah bar industry. Additionally, such factors as desire for small indulgencies, for something more exotic and unique, provide a good selling opportunity for hookah bars. 12. Industry Analysis Tobacco consumption has shown a level growth rate in the United States over the last decade. In 1994, total sales of tobacco were approximately $7. 5 billion. The retail tobacco industry is remaining consistent. The local climate, with a long winter season, is very conducive for the consumption of items in an indoor setting. At the same time, hot dry summers drive people into cafes to order iced drinks and other amenities. 13. Buying Patterns The major reason for the customers to return to a hookah bar is a great products, quick service and pleasant atmosphere. Although, as stated before, tobacco consumption is uniform across different income segments, Cowboy Hookah will price its product offerings competitively. We strongly believe that selling tobacco with a great service in a nice setting will help us build a strong base of loyal clientele. Strategy and Implementation Summary Cowboy Hookah’s marketing strategy will be focused at getting new customers, retaining the existing customers, getting customers to spend more and come back more often. Establishing a loyal customer base is of a paramount importance since such customer core will not only generate most of the sales but also will provide favorable referrals. 4. Competitive Edge Cowboy Hookah will position itself as a unique hookah bar wher e its patrons can not only enjoy a relaxing smoke but also spend their time in an ambient environment. Comfortable sofas and chairs, dimmed light and quiet relaxing music will help the customers to relax from the daily stresses and will differentiate Cowboy Hookah from any incumbent competitors if we eventually get any. 15. Sales Strategy Cowboy Hookah employees will handle the sales transactions. To speed up the customer service, at least two employees will be servicing clientswhile one employee will be preparing the customers order, the other one will be taking care of the sales transaction. All sales data logged on the computerized point-of-sale terminal will be later analyzed for marketing purposes. In order to build up its client base, Cowboy Hookah will use banners and fliers, utilize customer referrals and cross-promotions with other businesses in the community. At the same time, customer retention programs will be used to make sure the customers are coming back and spendi ng more at the hookah bar. 16. Sales Forecast Food costs are assumed at 25% for coffee beverages and pastries, 50% for retail tobacco sales and products. Proximity to the University campus will dictate certain sales seasonality with revenues slightly decreasing during the school vacation periods. The chart and table below outline our projected sales forecast for the next three years. Sales Forecast Year 1Year 2Year 3 Sales Tobacco Products$150,000$225,000$281,250 Tobacco$37,500$56,250$70,313 Food and Beverages$62,500$93,750$117,187 Total Sales$250,000$375,000$468,750 Direct Costs of SalesYear 1Year 2Year 3 Tobacco Products$32,142$48,215$60,267 Tobacco$16,073$24,107$30,135 Food and Beverage$26,785$40,178$50,223 Total Direct Cost of Sales$75,000$112,500$140,625 18. Management Team Gaps Despite the owners and managers experience in the industry, the company will retain the consulting services of Sahara Smoke. This company has over twenty years of experience in the Hookah industry and has successfully opened dozens of hookah bars across the U. S. Consultants will be primarily used for market research, customer satisfaction surveys and to provide additional input into the evaluation of the new business opportunities. 19. Personnel Plan The table below outlines the personnel needs of Cowboy Hookah. Personnel Plan Year 1Year 2Year 3 Owners$80,000$100,000$110,000 P. T. Employees$12,000$22,000$27,000 Total People677 Total Payroll$92,000$122,000$137,000 Financial Plan Cowboy Hookah will capitalize on the strong demand for new and unique experiences. The owners have provided the company with sufficient start-up capital. With successful management aimed at establishing and growing a loyal customer base, the company will see its net worth doubling in two years. Cowboy Hookah will maintain a healthy 65% gross margin, which combined with reasonable operating expenses, will provide enough cash to finance further growth. We have assumed very conservative interest r ates of 5. 25% for our commercial mortgage of 80% of property value and 8% for our small business loan. These loans are amortized over 30 and ten years respectively with all interest expense and depreciation being tax deductable. We plan to each work as needed and draw a $20,000 salary for our time during the first year. To provide additional help we will also hire part-time servers at an expense not to exceed $12,000 for the first year. We have budgeted $30,000 and an additional $15,000 for staff increases over years two and three respectively. We have also assumed a 25% payroll tax and a 15% income tax over the first three years. 20. Important Assumptions Financial Assumptions Year 1Year 2Year 3 Mortgage Interest Rate5. 25%5. 25%5. 25% Long-term Interest Rate8. 00%8. 00%8. 00% Tax Rate15. 00%15. 00%15. 00% 21. Projected Cash Flow As the chart and table below present, the company will maintain a healthy cash flow position, which will allow for timely debt servicing and funds ava ilable for future development. Pro Forma Cash Flow Cash from OperationsYear 1Year 2Year 3 Cash Sales$250,000$375,000$468,750 Total Cash from Operations$250,000$375,000$468,750 ExpendituresYear 1Year 2Year 3 Cost of Goods Sold$75,000$112,500$140,625 Cash Spending$26,275$39,932$51,761 Bill Payments$133,237$177,490$201,283 Total Expenditures$234,512$329,922$393,669 Net Cash Flow$15,488$45,078$75,081 Cash Balance$16,213$21,359$44,679 22. Break-even Analysis With average monthly fixed costs of $20,300 in FY2001 and an average margin of 65%, Cowboy Hookah’s break-even sales volume is around $31,300 per month. As shown further, the company is expected to generate such sales volume from the out start. Break-even Analysis Monthly Revenue Break-even$19,561 Assumptions: Average Percent Variable Cost35% Estimated Monthly Fixed Cost$13,003 23. Projected Profit and Loss Annual projected sales of $250,000 in FY2010 translate into $156. 25 of sales per square foot, which is in line wit h the industry averages for this size of hookah bar. Overall, as the company gets established in the local market, its net profitability increases from $15,264 in FY2010 to $75,956 in FY2012. The table below outlines the projected Profit and Loss Statement for FY2010-2012. Pro Forma Profit and Loss RevenueYear 1Year 2Year 3 Sales$250,000$375,000$468,750 Sales Allowance($2,500)($3,750)($4,688) Net Sales$247,500$371,250$464,063 COGS($75,000)($112,500)($140,625) Gross Income$172,500$258,750$323,438 Expenses Payroll($92,000)($122,000)($137,000) Marketing($20,000)($30,000)($37,500) Loan Principle($1,429)($1,995)($2,102) Depreciation($8,525)($8,525)($8,525) Utilities($3,600)($4,140)($4,761) Insurance($2,400)($2,520)($2,626) Payroll Taxes($23,000)($30,500)($34,250) Other($3,500)($5,250)($7,875) Total Expenses($154,454)($204,930)($234,659) EBIT$18,046$53,820$88,779 Interest Expense($10,118)($9,795)($9,448) Taxes($1,189)($6,604)($11,900) Depreciation$8,525$8,525$8,525 Net Income$15,264$45 ,946$75,956 24. Projected Balance Sheet The companys net worth is expected to increase from approximately $212,000 by the end of FY2010 to approximately $443,000 in FY2013. The table below summarizes the projected balance sheets for this period. Pro Forma Balance Sheet AssetsYear 1Year 2Year 3 Current Assets Cash and Equivalents$27,000$21,359$44,679 Other Current Assets$13,000$24,500$36,375 Total Current Assets$40,000$45,859$81,054 Long-term Assets Equipment and Furnishings$25,000$35,000$45,000 Building$170,000$178,500$187,425 Total Long-term Assets$195,000$213,500$232,425 Total Assets$235,000$259,359$313,479 Liabilities and Owner’s Equity Liabilities Short-term Debt$20,000$20,000$20,000 Long-term Debt$155,000$152,106$147,756 Total Liabilities$175,000$172,106$167,756 Owner’s Equity$60,000$87,853$145,723 Total Liabilities and Owner’s Equity$235,000$259,359$313,479 25. Business Ratios The table below outlines the companys business ratios. The last column rep resents industry average business ratios for Specialty Tobacco Places (SIC 5812). Ratio Analysis Year 1Year 2Year 3Industry Profile Sales Growth0. 00%50. 00%25. 00%7. 60% Inventory7. 83%6. 30%5. 23%3. 60% Other Current Assets0. 00%0. 00%0. 00%35. 60% Total Current Assets80. 11%86. 41%90. 46%43. 70% Long-term Assets19. 9%13. 59%9. 54%56. 30% Total Assets100. 00%100. 00%100. 00%100. 00% Current Liabilities14. 31%9. 56%7. 13%32. 70% Long-term Liabilities7. 40%4. 44%2. 54%28. 50% Total Liabilities21. 71%13. 99%9. 67%61. 20% Net Worth78. 29%86. 01%90. 33%38. 80% Percent of Sales Sales100. 00%100. 00%100. 00%100. 00% Gross Margin65. 00%65. 00%65. 00%60. 50% Selling, General Administrative Expenses47. 94%48. 47%47. 37%39. 80% Advertising Expenses2. 26%2. 18%2. 26%3. 20% Profit Before Interest and Taxes23. 27%22. 47%23. 85%0. 70% Main Ratios Current5. 609. 0412. 690. 98 Quick5. 058. 3811. 950. 65 Total Debt to Total Assets21. 71%13. 9%9. 67%61. 20% Pre-tax Return on Net Worth62. 87%44. 64% 37. 71%1. 70% Pre-tax Return on Assets49. 22%38. 40%34. 06%4. 30% Additional RatiosYear 1Year 2Year 3 Net Profit Margin17. 00%16. 58%17. 62%n. a Return on Equity46. 93%33. 48%28. 12%n. a Activity Ratios Inventory Turnover10. 9110. 1110. 11n. a Accounts Payable Turnover11. 2512. 1712. 17n. a Payment Days273029n. a Total Asset Turnover2. 161. 741. 44n. a Debt Ratios Debt to Net Worth0. 280. 160. 11n. a Current Liability to Liability0. 660. 680. 74n. a Liquidity Ratios Net Working Capital$177,858$284,304$408,334n. a Interest Coverage48. 1662. 07104. 13n. a Don’t waste time! 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Teacher and Students - 6350 Words

A FIELD STUDY PORTFOLIO IN ADVANCE MONTESSORI EDUCATION CENTER OF ISABELA PRESENTED TO: DR. ROMEO Z. TARUN FS INSTRUCTOR IN PARTIAL FULFILLMENT OF THE REQUIREMENTS IN FIELD STUDY 5 (Learning Assessment Strategies) And FIELD STUDY 6 (Becoming a Teacher) MAYFLOR F. GUIYAB BSED III HGBAQUIRAN COLLEGE S.Y-2013(2nd SEMESTER) Table of Contents I. Title Page -------------------------------------------------------------------------------------1 Table of Contents -------------------------------------------------------------------------2 Acknowledgement -----------------------------------------------------------------------3 Dedication ----------------------------------------------------------------------------------3 AMECI Philosophy,†¦show more content†¦The end goal is to be a positive role model for students. My Task To be an effective teacher in the future it is important to be aware of yourvalues about teaching. 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Children vs. Authority Rebellious Attitudes Free Essays

Children vs. Authority: Rebellious Attitudes to Avoid Societal Expectations Children’s literature has an extremely influential way of shaping a child’s outlook on life. When children read stories, they often relate to the characters on a very personal level, whether the character is polite and kind or rude and bratty. We will write a custom essay sample on Children vs. Authority: Rebellious Attitudes or any similar topic only for you Order Now The plots of children’s stories can influence generations of children in negative and positive ways. For over one hundred years, one of these influential texts is still J. M. Barrie’s Peter and Wendy, which originated as a play. The main character, Peter Pan, is a boy ho lives in Neverland and refuses to grow up. He lives by his own rules, with no parental guidance to help him learn right from wrong. The same concept is depicted in Harriet the Spy by Louise Fitzhugh. Harriet, an eleven year old aspiring writer, creates her own rules for being a child rather than conforming to societal expectations. In a book written by Colin Heywood, the historical expectations of children are explored with the conclusion that the expectations of children will continue to change over time, and Heywood is in hopes of this becoming a positive change. During the transition period from child to adult, many children rebel against authority figures, including parents or institutions. In Peter and Wendy and Harriet the Spy, the main characters rebel against authority in such a way as to defy social order. Living in Neverland, Peter refuses to mature and wishes to remain a boy forever, while Harriet could careless about conforming to the typical social requirements of her gender. Heywood discusses the gradual societal changes inflicted upon children from before the writings of J. M. Barrie to current novelists today. Both Peter and Wendy are strong examples of children who oppose parental authority fgures in order to resist the social normalities which proceed adolescence. Barrie’s character of Peter Pan opposes all authority in Peter and Wendy, however, the parental fgure of Neverland -Captain Hook- is the one authoritarian fgure in Peter’s fantasy which he cannot escape. The plot seems to thicken as the story continues, and their is major friction between the two characters: Peter avoids authority while Hook demands it. Peter interacts with parental authority throughout the novel, beginning with the Darlings. He frequently listens to the stories Mrs. Darling tells in the nursery, yet will not commit to the idea of parents and the rules that come along with them. He instead encourages Wendy, Michael and John to fly to Neverland with him, enticing them with â€Å"mermaids† and â€Å"pirates† (Barrie 97-100). This enticement is a depiction of Peter avoiding authority; he is encouraging the children to rebel and leave their parents for a fantasy island with no rules. A second example of Peter resisting authority is his interaction with Captain Hook in Neverland. Hook represents the dominant adult authority in a fantasy land with no ules, therefore, Peter and Captain Hook are polar opposites in the story. Peters constant opposition to boyhood leads to Hooks death to the infamous crocodile. Through Peters defile of authority to both parental fgures in the novel, he is avoiding the social structure which occurs in ones growth from child to adult. Besides blatantly stating â€Å"l always want to be a little boy and to nave tun,† Peter Pan continuously suppresses the idea of parental guidance or any type of authority (Barrie 92). Peter does not want to participate in the normal milestones of life, nstead, he wishes to stay a boy forever. He is constantly avoiding rules, adults, and any concept of responsibility expected from him. Although Peter demonstrates many qualities of a young man, especially with his leadership of the lost boys, he continuously defies the social normalities which follow adolescence. In an article written about J. M. Barrie, it states that Peter and Wendy stand out from other works for its use of â€Å"childhood innocence, the island as a retreat from society, separation, the fantastic, and the need for social order† (Schoenberg and Trudeau 2). Social order s a reoccuring theme in Barrie’s novel; the evident lack of social order emphasizes the evident need for it. When Wendy travels to Neverland with Peter she begins feeling romantically inclined towards him, however, Peter does not return the same emotion. He is incapable of romance, as he is not a man nor wishes to be one. He demonstrates authority himself, yet will not accept it from others. With the control of his own fantasy in Neverland, Peter eliminates any possibility of having a father and instead takes on the role as he sees fit. How to cite Children vs. Authority: Rebellious Attitudes, Papers

Cell Phone vs Regular Phones free essay sample

AC110685 EN120 English Composition Assignment 02 Beginning English Writing August 5, 2011 Cell Phones vs. Regular Phones Although land lines and cell phones serve the same main purpose of making and receiving calls they have a large variety of differences. Regular home phones are limited to the perimeter of the house while cell phones have the mobility to be taken and used anywhere. In case of an emergency, it is said the home phones are much safer since the cell phones rely on signals from antennas and depending on your location you may not be able to get a signal to make a call. Home phones have limited features such as call forwarding, caller id, voicemail, and long distance. On the other hand, cell phones have a wide variety of features including, but not limited to texting, internet, camera, email, application downloads, etc. These cell phones are also known as smart phones or PDAs. We will write a custom essay sample on Cell Phone vs Regular Phones or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Home phone lines are good for DSL internet connection, home security systems and faxes. Personally those are the only reasons why we have a landline in our home. Another difference between the two is pricing. Depending on the type of cell phone and the data package that your phone requires they can be more expensive, while your landline has one monthly bill. Cell phones are such in demand that the local phone companies are now offering cell phone service in addition to regular land lines. While you can record music to your home phones answering machine, a cell phone acts as a whole music system and can store hundreds to thousands of songs depending on the memory on the phone. Add a memory card to your cell phone, another plus that the home phone doesnt offer, and this adds even more memory to your phone where music, photos, applications, contacts and much more can be stored. Once the memory card is removed it can be used in another phone and so you wont lose your information. Cell phones are a good way to keep the kids busy while you are driving by downloading kid friendly games, videos and movies. In conclusion, Cell phones have more capabilities than regular phones and in the end it all boils down to your budget and what you can afford on a monthly basis. As for me, I am going to stick with my portable minicomputer!

Nirma vs Hul free essay sample

Rural inhabitants arent a different species, but consumers as quirky and demanding of marketers as any of their urban cousins. And just as eager to consume maybe even more so, given their access to messages of consumption via TV, but lacking the easy access that makes urban consumer’s blase. For marketers the potential is huge a country waiting eagerly for their products, providing they can make the effort to export inwards, and learn to play the games by rural rules. And if they dont, the chances are that they will be left behind. Even with the minimal effort put in by companies so far, rural India now accounts for majority, or near majority, consumption in many categories. Rural India is clearly not such an area of darkness anymore, and as a further incentive to keep the lights on, remember that farmers get electricity free! One of the most popular and widely accepted Marketing Myth is that the rural consumers will only buy really cheap mass market brands. We will write a custom essay sample on Nirma vs Hul or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page But the stark reality is that though brands like Nirma lead, but penetration of premium products has also been observed even to the lowest SEC. The percentages may be very small, but given the large universe, the actual figures may be significant Thus when we are aware of the fact that brands like Nirma rule the rural market, it would be interesting to study and analyse their basic marketing inputs the 4P†s 1 NIRMA About the Company Nirma is the Rs. 17 billion Detergents, Soaps and Personal Care Products Brand, a market leader in the Indian detergent market and second largest in bathing soaps the brand NIRMA being one of the worlds biggest in its segment result of its mission to provide Better Products, Better Value, Better Living. The man who altered the clothes-washing habits of the Karsanbhai Patel the chairman of the Ahmedabad-based Nirma Ltd. This chemist who manufactured detergents at home in Ahmedabad in 1969 has certainly come a long way. He worked from his backyard which developed into a soap factory, cycled to retail outlets and hawked his brand at one-fourth of the price of similar products then available. A t Rs 6, Nirma, named after his daughter, was the cheapest detergent vying for attention on shop shelves. By the late 1980s, Nirma had become one of the worlds largest-selling detergent powders. That he rewrote history and gave Hindustan Lever, the Indian subsidiary of the Anglo-Dutch foods and toiletries conglomerate Unilever, a huge headache is wellchronicled. Today he is proud owner of an Rs 2,500-crore Ahmedabad-based soaps and detergents major It has been Patels dream to make Nirma a synonym for quality. Nirma is not merely a brand or a product, it is a dynamic phenomenon, a revolution, a philosophy, he once said. Nirma sells over 800,000 tones of detergent products every year and commands a 35% share of the Indian detergent market, making it one of the world’s biggest detergent brands. Towards this end, he tried his hand at many brand extensions. From toothpaste to salt and matchsticks, they all nestled under the Nirma umbrella. Incorporated as a private limited company, Nirma was converted into a deemed public company and then to a public limited one in Nov. 93. Nirma is an over Rs. 17 billion brand with a leadership presence in Detergents, Soaps and Personal Care Products, offering employment to over 15,000 people.

Androstendione essays

Androstendione essays Androstenedione is one of the leading supplements in body building nutrition. Many serious bodybuilders use androstenedione to further help increase their lean muscle size and strength. Androstenedione helps the body build lean mass through the extra supplementation of testosterone. This drug has helped many accomplish what they are looking for but at a price. Androstenedione is also one of the most controversial supplements on the market. It has many side effects and is even been said to cause cancer. Many people do not know the true chemistry behind this drug that makes it all work. Androstenedione is produced in the body from either 17-a-hydroxyprogesterone or dehydroepiandrosterone (DHEA). It is also found in meat and in the pollen of the Scotch Pine Tree. Since this natural testosterone precursor occurs naturally in plants and in the human body, it falls within the classification of a dietary supplement under the Dietary Supplement Health and Education Act (DSHEA). Androstenediones chemical name is 4-androstene 3, 17-dione. It is naturally produced in the adrenal glands, ovaries, and testes and can be converted directly by the liver into testosterone. This chart shows a little more information concerning the true chemistry behind this product. Characteristics: White Crystalline powder As you can see, androstenedione is very similar to that of pure testosterone. This is how it can be so functional because it just increases a chemical that is already in the body. The pictures on the following page also display some additional information regarding the molecular structures of testosterone, androstenedione and other related chemicals. Androstenedione is the most controversial sports supplement there is. This supplement may do a lot of good for most people but they do not tru ...

Describe the function of tolc gene in salmonella and how this function Essay

Describe the function of tolc gene in salmonella and how this function may relate to intracellular pathogenisis in this organism - Essay Example Other substances that are secreted by TolC gene include macrobiotic solvents, and a number of antiseptic peptides (Tegos and Mylonakis, 2012). TolC functions hand in hand with other internal casing mediums in a bid to expunge unwanted elements. Research done over the recent past have posited that a number of mechanisms accountable for dissipating noxious substances from the E. coli cell requires the presence of TolC in order to function properly (Yu, Zhang and Brown, 2013). This function directly relates to the intracellular pathogenesis in salmonella. According to Toone, (2011), the absence of TolC in salmonella as a result of its removal elevates the level of defencelessness or vulnerability of salmonella to the various agents that exterminates or eradicates bacteria, viruses, and other germs, and also chemical composites. It is however important to elucidate the fact that in salmonella, TolC relies on other mechanisms for accountable for the removal of noxious substances from the cells. According to Horiyama, Yamagichi and Nishino (2010), these other mechanisms include "AcrAB, AcrD, AcrEF, MdtABC, MdsAB, EmrAB, and MdfA, MacAB, and MdtK" (p. 1372). In a nutshell, the function of the TolC gene in salmonella is aiding in the secretion of noxious substances from the cells of

Marketing Communications Strategies Case Study Example | Topics and Well Written Essays - 3000 words

Marketing Communications Strategies - Case Study Example Marketing has moved from customer acquisition (winning new customers) through customer retention (keeping customers for life) towards customer selection (dumping unprofitable customers while selectively seeking and keeping the more profitable ones). The development of marketing communications is the major role of the promotional strategy component off the marketing mix. The marketing mix is essentially a conceptual framework that helps to structure the approach to each marketing challenge. At the heart of a marketing strategy is the target market strategy stemming from the markets segmentation process of segmentation, targeting and positioning. A marketing strategy specifies the segments to target, the brand or product positioning required to appeal to these targeted customers, plus the competitive advantage to be exploited versus rivals. Without a marketing strategy, the marketing mix activities are unlikely to bring significant benefits to the organization and probably will fail to satisfy and retain targeted customers. Core to a marketing strategy is the understanding of competition and the identification of a differential advantage – something unique to one supplier and highly desired by targeted customers. In terms of the overall competitive strategy, there are four broad options : (a) intense growth, when current products and current markets have potential for increasing sales; (b) diversified growth, which occurs when new products are developed to be sold in new markets; (c) integrated growth, owing to forwards, backwards or horizontal integration; and (d) maintenance, of the status quo. The marketing strategy should specify marketing objectives so that marketing performance can be monitored. UK - Soft Drink Industry Review : The roots of the soft drink industry have been engraved in the soil of United Kingdom for hundreds of years. The soft drink industry continued to grow steadily as the nineteenth century progressed. The current UK soft drinks market is 9 billion litres in volume. If adult juice drinks reached this proportion of the total market, the segment would be 360 million litres. The size of the target market must be set in context with the sales by volume of the leading carbonated soft drinks in the UK. Brands such as Lucozade and Lilt have sales of around 100 million litres, while Coca Cola is a massive 1.4 billion litres by volume. Overview : Coca Cola and Pepsi Cola can be identified as market leaders in the Cola drinks industry. They possess significant market share within the soft drinks industry. Coca Cola is a 100-year-old soft drink that started out as anything but soft. It was introduced as a medicine. "A delicious, exhilarating, refreshing, invigorating beverage in addition to being a cure for all nervous afflictions, sick headaches, neuralgia, hysteria, melancholy" said an early advertisement. Coca- Cola is enjoyed all over the world. The figure indicates that 1.6 billion gallons is sold every year, in over one hundred and sixty countries. Coca Cola's main challenger world wide is the Pepsi Cola most commonly referred to as Pepsi. Pepsi follows exactly the same brand and business model. Its differentiation is based on the fact that it was introduced more recently than Coke, and did not create the category. As a challenger, its brand image and market grip are lower. It challenges the leader on three facets: price, product and image. Price : it is a dime cheaper than Coke, at consumer level, but this creates a

Proposal for Wind Farm Using Windpro Software

Proposal for Wind Farm Using Windpro Software INTRODUCTION: The world is experiencing an extraordinary boom of renewable energy as never before in the history. The main reason for this is mainly global warming, which is reflected by the greenhouse effect, resulting in a large part in rising temperatures. Two figures to visualize this boom; According to IEA (International Energy Agency) two wind turbines are installed every hour in China and every day and according to the same source 500,000 photovoltaic panels are installed throughout the world. So, what makes renewable energies optimistic? The answer is that there are two very powerful motor behind that: The first is the human genius thanks to which we have made giant steps in the renewable energy to the point that they become almost as profitable as the sources of classic energy. For example, according to IRENA (International Renewable Energy Agency) the cost of photovoltaics decreases by 70% between 2010 and 2015 same thing with regard to wind energy with a decrease of 40% When the second engine is the political will with mainly the signing of the decree like the COP, the public subsidy, the different facilities offered, etc. PURPOSE: The main purpose of this report this to make a technical-economic design of a wind farm in a choosing place using wind pro software to attract potential investors. PROBLEM: The criteria for choosing a wind power plant depend on the size, power and number of units. The efficiency of a wind turbine depends on the regularity and the power of the wind. The most interesting sites are generally located by the sea or to the tops of hills and clear mountains. It can also be a solution in countries where the interconnection lines will not succeed because of the low population density even if the winds are not optimum. Having the freedom to choose a site, and coming from Algeria my assessment will be focused in one of the most favourable area to install a wind farm this country, the choice of the size and the number of the turbines will be according to the meteorological and natural conditions of the region and they will be discussed later on. SCOPE : Mainly focused towards fossil fuel energy, the renewable energy sector still poorly exploited in Algeria or at least not at all, the assessments of wind and solar sources are not deeply studied, for the moment the installations available are mostly orientated on experimental basis, few amount for investment and means of research are the principal reason for that despite of the big potential available, specially on solar power where 84% of the country is covert by the Sahara. Until nowadays 98% of the electrical production in Algeria come from gas, the lasts years increase evolutions in power demand, followed by the falling oil prices have caused a significant budget deficit since the state subsidizes in full the gas destined for the production of electricity, up to 5.5 billion $ in 2014 according to Sonatrach (the Algerian energy company) with an increase of 10% of the energy consumption each year. Following that and in view of the circumstances in 2015 the Algerian state has declared a national development program for renewable energy with the target to create 22000 MW of power by 2030, 4500 MW will be realized from here to 2020 according to the CREG (commission for the regulation of electricity and gas). The renewable energy development programme in MW (source www.creg.gov.dz) I. Wind assessment: 1.literature assessment: Several studies about the wind resources in Algeria has been done, and a general wind map was so created with a data measured from a distance of 10m above the ground level, the main methods used were mainly numerical simulations, and extrapolations with the help of meteorological data and several measuring points; In 2000 a study from Dr N. Kasbadji Merzouk aiming to the creation of a wind chart in Algeria has been published and the results of the annual mean wind speed was illustrated in a map: In this case of study, 10 years wind speed data from 26 stations has been used, and additional data from The National Office of Meteorology in Algeria has been included in order to refine the extrapolation results, Further calculation that take the 10 m above the ground results to 25m by interpolation had shown the map below : Lasts research in 2013 that took new meteorological data and much more measurement points compared by the one above has been done by Dr. Sidi Mohammed Boudia show results as follows: Thru those studies we can tell clearly that the main wind speed is concentrated in the south west of the country and specially in the region of Adrar (about 1500km south west of the capital Algiers) where we can see a mean speed of up to 6.5 m/s at 10 m above the ground and up to 7m/s at 25m height, those results are still acceptable for a large onshore project in the way where they push us to know what about the wind speed in up to 100m. In 2013, an open access data platform has been launched by the international renewable energy agency (IRENA) called the global atlas for Renewable energy, this project is the result of international collaboration from several research institutes like DTU wind energy, private companies and governments, the aim was to bring an easy and a simple way for accessing data and analysis for renewable energy assessment. Using this platform, we can find some data that goes up to 200m, we can see the results as below: (a) These maps show successively the wind speed in the country at 50m, 100m, 200m. from here and even if the results are not the most accurate, we can see that the real potential of the wind energy in Algeria is becoming more interesting. 2. WindPro assessment : Having a preliminary knowledge about the wind speed in the country and using the results found on the different research and studies, our assessment using windpro will be focused in the windiest area, namely the Area of Adrar. The characteristics of the terrain strongly influence the wind flow and thus play an important role in the geographical extrapolation of the wind regime. The WindPRO software and the WAsP flow model are used for this study. WAsP requires a terrain definition through the following input data: elevation, roughness and other obstacles to wind flow Site description: Fatiha Ben Miloud and AL, who have moved to the region to identify some sites in which the wind farm can be installed, claimed that a site has been particularly predominant for its proximity to the electrical substations of Sonelgaz (national society of electricity and gas) This site is located about 73 km north of the town of Adrar. with an altitude of about 260 m. The available area is large,the topography is flat and the roughness of the ground is weak. Apart from the substation and the electric poles, there are no obstacles in the vicinity of this site. The pictures taken by Fatiha Ben Miloud below show the morphology of the terrain near the Sonelgaz substation. North side West side East side South side Additionally the site is ideal for transport where it is near the road axis Adrar Timimoun , but the most advantageous is that this site is located close to a HVV substation which reduces construction costs. From here we can choose the right location using windpro, which requires an exact spot in the beginning to do further simulation. the images above shows the site of the wind farm using Windpro and the Openstreetmap data , we can confirm the research done by Fatiha Ben Miloud about the potential of this area ; the availability of the space is huge , the link to the site is easy ,and there is no perturbation with the surrounding. BLABLABLABLABLABL Wind regime on site: defining the wind regime on a chosen site are usually done using meteorological measure instruments called anemometers, those devices are specially used to do wind assessments like speed and direction. It is highly recommended to make up to 2 years of measurements on the site in the beginning of a project, and the more traditional methods of that is to stand a mast. Being the most economical solution compares to Sodar and Lidar which can be very expensive despite de accuracy, the mast can be set up to the desired height of measurement and can carries several instruments for temperature measurement and mainly anemometers. Cups anemometers the most commonly used, figures below can show some designs of those devices, the operating principle is simple; the torque generating from the turning cups under the effect of win, will be transformed in to electrical signal, this last will be calibrated and transformed in to wind speed output. In this case of study. Meteorological data on windpro were given from METAR (METeorological Aerodrome Report) in the closest local aerodrome of Adrar and being designed for only national flight this aerodrome is small and not a very active one, the measurements are taken every 180 minutes from a height of 10m, the table below summaries the monitoring of the wind in the area : Meteo data Adrar_TOUAT_SYNOP_60-620_N27.880_W00.280 Type de station METAR/SYNOP System Cup anemometer Places of observation Control TOWER ( TWR) height 10m Observation Every 180 minuts Intervalle used 01/01/2007 to 13/04/2016 Even if the specification model of the anemometer was not found in the different documentations, the picture below shows clearly the usage of a cup anemometer in the control tower of the  aerodrome. We can also notice and for a software reason that the interval of the measurement stops at 13/04/2016 even if the interval wanted was for 10 years. The data results from the Metar station are listed in the table below: Height M 10 Weibull mean speed m/s 5.9 Weibull A m/S 6.7 Weibull K 2.01 Main wind direction NNE, ENE We normally describe the wind variations at a given site using a Weibull distribution like the one The shape of the curve is determined by a so-called shape parameter equal to 1.750. This graph is a probability distribution (frequency distribution). The probability that the wind blows at any speed (including zero) is necessarily equal to 100%, the area below the curve will always be exactly 1. The statistical distribution of wind speeds varies from place to place as it depends on the local climatic conditions, the landscape and its surface. The Weibull distribution therefore tends to vary, both in form and in average value. These results show the concordance between the research carried out in the literature assessment done in the first part and the data analysis from windpro , where we can see clearly that the dominant wind direction is NNE and ENE , with a mean speed of 5.9m/s Additionally, to this, the WAsP methodology is used to extrapolate selected wind statistics up to 50 m and later on up to the hub height and up to the location of each wind turbine. The purpose of that is to see the real potential of the wind at a more height altitudes. Roughness and elevation are the two crucial factors to do wind measurement, this step is crucial when using windpro and more precisely for WAsP. Elevation: The wind regime can be strongly influenced by elevation differences. The terrain elevation is modeled within a radius of 5 km and is based on the NASAs Radar Topography Mission SRTM data. The contours are then generated with an altitude difference of 10 m between two successive curves. Roughness: The roughness is a key parameter of the equation that models the vertical wind profile Any change in roughness causes a change in the vertical wind profile. The impact at the measuring or hub height can vary greatly as a function of the distance from the change in roughness and atmospheric conditions. Mettre 50 METRE II.WIND FARM : Wind turbines: Whatever in size, power or efficiency, the choice of the wind turbine depends on several parameters; The nature of the terrain where it will be sitting, the wind resources in the area and the noise level are some of the main criteria and specially for a wind farm development. but further that, the availability and reliability of the models needed in addition of the spare parts are very important factor that decide if yes or not the turbine is taken into consideration. And finally, the availability of warranty, and proximity of operation and maintenance teams is also more than desirable. Being heavily integrated in Algeria and specially in the energy field, the choice of the US manufacturer GE (General Electric) was made in a strategic point of view in the way where possessing a very large infrastructure, plus an infallible experience in the country, GE can without a big difficulty manufactured the wind turbines in Algeria, which can minimize the costs and facilitate the transport as well as the installation On this case of study, two different type wind turbines and 16 in total had been choosen: Model N °1: Model reference: GE WIND GE 2.5-120-2,500 number 8 Hub heights: 98.3 m Rotor diameter: 120 m Power rated: 2500 KW Frequency: 50 Hz Noise: 106 dBA Class : IEC IIIs Commissioning : 2014 Technology: Model based controls Cold weather extreme *GE claimed that this model has the worlds most efficient high output wind turbine and has a competitive power value at low wind speed with 98% of reliability from its global fleet. Model N °2: Model reference: GE WIND GE 1.7-100-1,700 Number 8 Hub heights: 96m Rotor diameter: 100 m Power rated: 1700 KW Frequency: 50 Hz Noise: 107 to 105 dBA with low noise trailing edge technology Class : IEC IIIs Commissioning : 2013 Technology: Model based controls, low noise trailing edge, vortex generators, weak grid support *GE claimed that this model has the best in class capacity factor with high energy capture in low wind speed environments. The specific choice of those two model was mainly done because of their high efficiency in low wind speed specially when our farm site has a wind speed lower than 10m/s. Sitting: the choice of the sitting of the wind turbine depend mainly in the available area in the site, the nature of the terrain, and the wind direction, those characteristics define the number of the turbine as well as the way of the sitting. In our case, even with the availability of a big, flat and empty area, the sitting of the wind turbines will be in two straight rows with 8 x GE 2.5-120-2,500 in the front and 8 x GE 1.7-100-1,700, The two rows are facing the wind flow an angle of 127 °. the main reason for this configuration is gain the maximum of power with a smaller area of usage in the way where the more powerful turbines are sitting in front of the less powerful ones, but with a particularity where even if the front turbines will absorb the energy SEE GUIDENCE SITTING PDF TO CONTINUE MICROSITTING figure : // The long-term wind regime expected at the representative height at the location of the wind turbines is shown in Table and Figure The mean wind speed at hub height at the location of each Wind turbine is included in Annex E. Location E 1,377,483 N 3,181,536 WT model GE 2.5-120-2,500 GE 1.7-100-1,700 Height m 98.3 96m Weibull mean speed m/s 9.0 8.9 Weibull A m/s 10 10.08 Weibull K 2.521 8.9 Main wind direction NNE, ENE NNE, ENE figure : ge 2500 Figure GE 1,7 Noise: The noise caused by wind turbines and specially in by a wind farm is an important element of the acceptance, or refusal, of these machines by neighboring populations where it can be a source of annoyance and perturbations. It should therefore be assessed, with special care, during public inquiries; And then checked, after start-up of the machines, by measurements in the field. METTRE LE COMPOSANT QUI FAIT LE BRUITThanks to Windpro, we can perform noise calculations for all the farm. In order to do that, we indicated to the software the average wind speed at this point, but also the height at which we wanted our measurements (the hub), with the help of de wind turbine technical characteristic from the manufacturer. we were able to obtain the results (ANNEXE) in the form of a map in figure It is then found that at the foot of the wind turbine, there is between 50 and 100 decibels of noise, which corresponds to the noise of a washing machine. But when one moves away from it, the noise falls below 35 decibels, which simply corresponds to the noises normally heard in fields or in a forest. It can be concluded that, choosing this clear empty field was a very good idea, even with the existence of a small inhabitant village at 3km nearby, the farm will not be hampered by the noise of wind turbines. This is why we would have the right to install the wind turbines. Having not found the legislation for the distances from the residential premises in Algeria. Distances from some European countries can be given for example. in France, it is not allowed to install a wind turbine within 500m of a dwelling, Denmark and Sweden, the limit is 300m. Shadow: As introduced on the ZVI section. The rotation of the blades causes a periodic interruption of the sunlight (stroboscopic effect) which may possibly be unpleasant. This phenomenon can easily be anticipated. It is highlighted when the sun is low and when the sky is clear of any cloud. The periods of this phenomenon are generally very short and can be seen only near wind turbines. Using windpro, assumptions for shadow calculations are set up as following: -Calculate only when more than 20 % of sun is covered by the blade -Minimum sun height over horizon for influence 3  ° -Day step for calculationà ¢Ã¢â€š ¬Ã‚ ¨Ãƒ ¢Ã¢â€š ¬Ã‚ ¨1 days -Time step for calculation à ¢Ã¢â€š ¬Ã‚ ¨1 minutes The calculated times are worst case given by the following assumptions: -The sun is shining all the day, from sunrise to sunset -The rotor plane is always perpendicular to the line from the WTG to the sun -The WTG is always operating A ZVI (Zones of Visual Influence) calculation is performed before flicker calculation so non-visible WTG do not contribute to calculated flicker values. A WTG will be visible if it is visible from any part of the receiver window. Ones again the we can confirm the good choice of this area, the shadow flickering provided from the wind turbine is out of all king of disruption, where even the near village at 3km down the wind farm wont be exposed by the shadow, the only disadvantage is the flicker on the road nearby where we can see from 10 to 30 hours per year in the worst case but we can conclude that even with that, it will not cause any problems at all. ZVI: The installation of wind turbines modifies the landscape. Given their large size, they mark space and are part of a logic of good landscape integration. Wind turbines need to be placed in sites exposed to the wind. The degree of visibility is influenced by factors such as the type of landscape, the number and design of wind turbines, the way they are arranged on the farm, their color and the number of blades. Other aspect of the visual impact that will be discuss in the next section is the shadow flickering; During rotation, the blades must cast shadows intermittently, resulting in a flicker or blinking effect on the surrounding area. This effect can cause problems for the population close to the wind farms. Its intensity depends on the rotor speed and direction, the number of hours of sunshine and the geographical location of the installation. Assumptions done using WindPro for ZVI calculation are as follow: -Center for calculation: UTM (north)-WGS84 Zone: 30 East: 787,969 North: 3,152,257 -Width of calculation area: 5,118 m -Height of calculation area: 4,893 m -Calculation stepà ¢Ã¢â€š ¬Ã‚ ¨: 25 m -Eye heightà ¢Ã¢â€š ¬Ã‚ ¨:1.5 m -Calculation area: 2,504 ha -Highest relevant visible part of a WTG: Hub height + 1à ¢Ã‚ Ã¢â‚¬Å¾2 rotor diameter -Obstacles used in calculation: 0 -No area objects used in calculation -New WTGs used in calculation: 16 The results of this show that all the 16-wind turbines are visible from the hole calculation area of approximatively 2,500 ha, we can admit that this is one of the biggest disadvantage for having a flat area and specially where it can be visible for the near village situated at 3km down the wind farm , but à ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã‚ ¦ IL FAUT VOIR LA LIMITE

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