Global Impact of Terrorism and Genocide Coursework

Global Impact of Terrorism and Genocide - Coursework Example The exploitation of fear within the global population, organizations and small social units helps to realize these terrorist goals. The September 11, 2001 attacks were a prominent example of terrorism in the 21st century. The incident involved a series of four separate, but well-coordinated terrorist invasions launched by the al-Qaeda on the New York City and the Washington, D.C. in the United States. The attacks impacted the Macro-system in the sense that the World Trade Centre was closed, and the economic system of Lower Manhattan nearly ground to a halt. Cancellations of international flights and business relations between the world and the two American cities had a substantial effect on the world markets. The Wall Street was also closed for nearly one week, and the civilian airspace three days in United States and Canada. In the Meso-system, different organizations such as churches, schools, and businesses suspended their operations and evacuated in the aftermath of the attack. At the individual and group level or microsystem, people were gripped with fear of a repeat of the attacks that had claimed about 3000 civilian lives. As Schlenger (582) has established, those who lost their loved ones, property or good physical health, have been enduring serious psychological disorders for more than 12 years now. America, Canada, their European allies and the whole world in general have since changed their security policies to eradicate cases of terrorism since then. Pham, P.N., H.M. Weinstein, and T. Longman. "Trauma and PTSD Symptoms in Rwanda: Implications for Attitudes Toward Justice and Reconciliation." Journal of the American Medical Association, 292.5 (2004):

Article Public Opinion of Police by Different Ethnic Group Essay Example for Free

Article Public Opinion of Police by Different Ethnic Group Essay Down though the years there has always been tension and an on and off relationship between the community they serve and law enforcement agencies. And as with any relationship between two people there are misunderstanding, break-up and disagreements and the same is with the relationship between the community and its law enforcement agencies but just with any relationship at day’s end both the community and law enforcement have and share common concerns such as justice and deterrence. With many of communities in America being incursion of immigrants within the last few decades; with this incursion of immigrants many communities are being bombard with so many new language and cultures diversity. Because of this wide range of ethnicity now living within many the walls of our communities and society on a whole now have different opinions and views of law enforcement. Now due to the various ethnicities flooding our communities the author will investigate how a few of these ethnicity groups like: African Americans, Asians and the Hispanics neighborhoods views racial profiling, discrimination and past experience with law enforcement agencies. Taking a look at the traumatized relationship and association between the two, as well as the interaction and reaction from the law enforcement agencies and the communities they serve. Since the conception of the law enforcement agencies race has long since been a vital playing card in policing. Even with the knowledge, awareness and understanding of this there has been some improvement but not enough. Racial opus of law enforcement alongside the racial outline of arrest, the raise in the number of arrest of non- minority like â€Å"Caucasian† by non-white law enforcement officers, while there were lower numbers of arrest by the same officers on other ethnic groups. On the flip side of that coin, more. â€Å"Caucasian† officers had a boost in the number of non-white arrest in comparison to the number of arrest involving â€Å"Caucasians†. Race has been a polarizingelement the in the society of America for years. And this is every so prevalent within the criminal justice system. Clashes involving both the communities and law enforcement are the flashpoint for practically every current inner- city riot. Ethnic Groups The raise of culture variety and immigration has from time to time made interaction with law enforcement difficult. Hispanics and Asian neighborhoods are often apprehensive of law enforcement officers due to their past occurrence. Their past incidents vary from their motherland of origin that was overwhelmed by civil unrest and war. This included exploitation of power by those of authority as well as much dishonesty within law enforcement agencies of that country. For this cause many minorities groups have a apprehension and more often than not an aversion to law enforcement officers. Like within the Hispanic neighborhoods, they often feel that law enforcement agents differentiates them by racial profiling them all because of their nationality. In Arizona this is a very contentious SB 1070 unlawful migration bill that passed given law enforcement agents the power and authority to inquire of certain individual (Hispanic) of proof of documentation of legal right to be in America. This law is being adopted in other states as well like New Jersey and Texas, any where there is a high population of Hispanics. IthasbeenreportedbytwoethnicgroupsAfricanAmericansandHispanic/Latinos affirm subordinate levels of agreement concerning their relationship with police officers as compared to those of their counterpart â€Å"Caucasians†. African Americans and Hispanic/Latinos claims that there is less willingness to obey and to follow orders given by authorities especially of Caucasian origin. Racial profiling has consistently been one of the most confounding, divisive and controversial issues the police department confronts. A perception that police target members of specific ethnic or racial groups creates a deep divide between the police and the communities we serve. But as an officer who has spent a lot of time patrolling the citys streets, I just dont think the perception is accurate. (Dutta, 2010) True racial profiling, in which people are targeted solely because of race or ethnicity, is both illegal and immoral. It destroys public trust and reduces the effectiveness of the police. There is no place for it in law enforcement. And I firmly believe that most LAPD officers support that viewpoint. Even the reported statement of the officer that he couldnt do his job without racial profiling was most likely misinterpreted. (Dutta, 2010) Differentiation between minorities and Caucasians is how they relate and response to law enforcement agents and how fairly or unjustly he or she feels their treatment was. This is a how many African Americans and Hispanic/Latinos responded when asked by authorities regarding their relationship with law enforcement agencies this is less equality than when Caucasians reported.

Working with families is difficult and complex. Essay -- Social Issues

Working with children, young people and their families can be seen as difficult and complex for many different reasons. However, before these topics can be discussed and explored fully, it is important to completely understand the difference between the words ‘difficult’ and ‘complex’. ‘Difficult’ implies that things are not easily or readily done, where it requires much effort much effort, labour and skill to be performed effectively. In the same way, ‘complex’ implies a hard to deal with situation, but also involves many interconnected parts or complicated arrangements that consist of emotional attachment. Social work is rarely working with one individual, as stated in O’Loughlin and O’Loughlin (2008); it will involve working with the whole family which is constantly changing making it complex and diverse. It may consist of parents or carers who share the same race, class, culture, or sexuality, but alternatively it may not. Members within the family help to determine our behaviour, roles, rules and stereotyping. To add to this, people are constantly entering and leaving the family system either by marriage, divorce or death. These complexities are shown in ecomaps or genograms. It is important to understand that the child’s welfare is paramount, but in order to achieve positive outcomes for the child, effective work will need to be done within the family. Relationships within a family are known as a system with the family being viewed as a whole, rather than as many individuals. Within family relationships, everyone seeks to uphold the equilibrium so if one member seeks to change, the others seek to resist. However, difficulties include maintaining good relationships and knowing boundaries between professional and personal... ...children, young people and their families can be both complex and difficult. Social work practice is one of the most challenging as it involves work with a diverse range of both professionals and service users. However, there is more that one single reason for this. As all professionals, agencies and parents continue to work together in various different cases, a variety of skills are required including: communication, preparation, intervention skills, assessment of significant harm, research of current legislation and decision making skills, all of which contribute to the complexities and difficulties of social work. It could be argued that these difficulties are highlighted most in many public cases of child abuse; moreover these cases can be seen to be changing social work practice, affecting the difficulties and complexities of working within this profession.

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

Occupational Medicine Essay

Asbestos is a mineral that is crystalline in nature and that has high degrees of durability, flexibility and resistance to corrosion by chemicals and heat. Asbestos is commonly used for making building materials for example floor tiles, ceilings, asbestos cement products, fireproofing material and insulation products, gaskets, coatings, textile products and automotive brakes. Shipbuilders use asbestos for insulation of hot water pipes, steam pipes and boilers. Globally, the incidence of disease related to asbestos is expected to peak around 30 to 40 years following the period when there was peak usage (CDC, 2003). Many of the patients who have lung disease related to asbestos have a history of exposure, often this history is strong but there are occasions when significant disease occurs in patients who have had minimal exposure and sometimes even with unknown exposure (Oreilly et al, 2007). Asbestos fibres are often expelled after an individual has swallowed or inhaled them, however not all the fibres are expelled. Some are left in the lungs and remain lodged there permanently. Upon accumulation they cause scarring of lung tissue and inflammation too. This then results in lung disease which affects breathing and air exchange (Solicitor advice, 2007). When inhaled, asbestos fibres leads to a variety of conditions, among these being lung cancer, pleural plaques, asbestosis, malignant mesothelioma and benign pleural effusion among others. Patients present with these conditions related to asbestos exposure long after they have been exposed. The latent period from the time of exposure to the manifestation of the clinical disease is very long. Initially the signs and symptoms are not specific and therefore occupational history becomes a good guide to suspicions that the clinician may have. Risk factors for development of lung disease related to asbestos include exposure to asbestos such as in occupations like construction workers, shipyard workers, boilermakers and rail road workers. Minimizing and avoiding further exposure are important in reducing further damage when one has been diagnosed with the asbestos related disease. Patients who smoke have an even higher risk of developing these conditions making cessation of smoking an essential factor in reducing risk (Oreilly, McLaughlin and Beckett, 2007). The risk increases with the duration of smoking, therefore it is necessary to stop smoking and also avoid second hand smoke through passive smoking. Smokers who have been exposed to asbestos have a greater predisposition to development of lung cancer than those exposed to asbestos who are non-smokers. For a long time Australia has lagged behind other countries such as the UK and the USA in terms of regulation and legislation concerning asbestos related disease and worker’s compensation. This was the case especially in the I970s when the there were few common law claims by victims of asbestos related lung disease even in situations where the conditions resulted from negligence by the asbestos industries (Formato and Gordon, 2007). This was despite the fact that there was a considerable increase in the number of people suffering from mesotheliomas among those working in Wittenoom for ABA Limited, a company that mined and milled asbestos. Some of the obstacles facing the claimants were overwhelming and it is highly probable that the Statute of Limitations was a barring factor for most of these claims. In addition getting hold of company information was also very difficult and often the corporate end withheld information from the claimants and their legal advisers. Presently, Postal, Defence and Telecommunications employees and other government employees are covered by a no fault benefit scheme referred to as Comcare Australia. The entitlements under this scheme are such that the employee is required to choose between compensation entitlements under the Common Law Damages or under the Comcare Act. One of the most significant barriers under the Comcare Act is the complexity of the legislative framework. Not until the government agency has received the claim for purposes of determination and then reconsideration can one get into a court or a tribunal (Formato and Gordon, 2007). The laws for compensation show some variance from one State to another. In a general sense, however compensation claims can be made under common law for a variety of reasons. These include, medical (these include expenses for hospitalization and treatment) and pharmaceutical expenses for the past and the future, for pain and suffering and for loss of the capacity to earn an income as well as for loss of income (Solicitor advice, 2007). The courts also award compensation for other things such as domestic assistance costs for the future and the past as well as damages for loss of life expectancy (Solicitor advice, 2007). When making a claim for damages it is best to make the claim as early as possible upon diagnosis of the condition. This helps one to avoid the barriers that come with the statute of limitations on period. For latent conditions such as those related to asbestos, the period may be extended but even then it is best to act soon. For a long time in Western Australia, victims of asbestos related disease could only hope to receive worker’s compensation entitlements. This is because though claims for common law damages were available the tendency was that they were not pursued. The common law claims were faced with the rather harsh and extreme statute of limitations period. It had no provisions for extension beyond six years. There have however been amendments that were introduced which have made it a little less difficult to make claims for diseases related to asbestos. There have however been restrictions on common law claims seeking damages for negligence amongst employers. This was previously unrestricted for all employees not just victims of asbestos related disease. In New South Wales, the compensation scheme for workers is Workcover NSW. The Dust Diseases Board is where Dust Diseases workers can make their claims. A specialist tribunal for dust diseases was set up to hear claims for asbestos related disease. Amendments were later made that did away with the statute of limitations in issues of dust disease. Other amendments included legislation on survivorship where in case a victim passes on before a claim is resolved, the damages are entitled to his/her family (Formato and Gordon, 2007). In all the other states (Victoria, South Australia and Queensland) each state has its own act for worker’s compensation and provisions for limitations. For instance Victoria allows for trial by jury in claims for damages under common law. It has also followed the New South Wales in legislation on survivorship. Only Western Australia has its special court for claims for asbestos related disease. However, there are processes that have evolved for the purpose of fast tracking those claims that are urgent. In determining the risk posed by exposure a history of environmental and occupational exposure is necessary. Some of the issues that need to be established include the specific occupation, how long the person worked at the same occupation and how much (intensity) exposure there was, an example here would be whether the dust was visible or not. Significant exposure is defined as a minimum of several months of exposure to exposure to visible dust that started ten years before (Wagner, 1997). Physical assessment of the patient to determine exposure to asbestos includes a history of occupation and physical signs and symptoms of disease as well as laboratory investigation of the chest by x-ray or CT scan. In this client’s case the history for significant exposure has already been established by the fact that he worked in mining and mixing of asbestos for a period of five years. In addition another identified risk factor is the fact that he used to smoke where he increased his susceptibility to asbestos related lung disease. History also includes the patients reports of exertional dyspnea, Assessment also includes chest spirometry to determine lung function and how much lung function may have been compromised by the condition. Any abnormal results in chest spirometry are followed by pulmonary function tests which involve measuring lung volumes and diffusion capacity. These are also performed in those patients found to have abnormal findings on imaging. Assessment will begin with a head to toe assessment of the client. This will involve checking for signs of poor tissue perfusion as a result of inadequate oxygen uptake by the tissues when lung function of ventilation and air exchange has been compromised. Some of these include finger clubbing and bluish lips. Other symptoms that the patient may report include shortness of breath, tightness around the chest, pain in the chest, dry crackling sounds when breathing in, a cough that is productive and persistent and loss of appetite. These presenting symptoms are however non-specific and generally indicate pathology of the respiratory system. Consequently other methods are used to determine asbestos exposure. Signs of exposure to asbestos include formation of plaque, changes in the pleura of the lungs (thickening) and collection of fluid around the lungs (Betterhealth, 2007). Bodies of asbestos can be identified by a use of a staining technique using a special iron. This confirms actual exposure to asbestos. Formation of pleural plaques is one of the most common responses of the respiratory system to asbestos inhalation with plaques occurring in up to fifty per cent of people exposed to asbestos. They are consequently used as a measure of exposure to asbestos (Boffetta, 2004). These plaques may sometimes not be visible on chest radiography and this leads to the requirement for high resolution CT-scans which have the capacity to identify up to fifty per cent of the plaques that will be found on autopsy. CT scans are commonly used when there is diagnostic uncertainty or for the purpose of making confirmatory tests (Boffetta, 2004). The plaques developed from exposure to asbestos characteristically occur on the lateral walls of the chest and sometimes may occur on the domes of the diaphragm. This causes lung expansion to be impaired making air entry difficult and may account for the chest tightness and chest pain. A computed tomographic scan of the chest helps to demonstrate further the remodelling that may occur as a result of lung tissue destruction. This leads to a decrease in the exchange of oxygen. To diagnose carcinoma of the bronchus a surgical biopsy is required which is done under anaesthesia. From this metastatic cells can be detected. Other methods that can be sued include bronchoscopy, mediastinoscopy and CT scan. This will serve as a confirmatory test for the signs and symptoms which may have been reported by the patient which include, unexplained weight loss, breathlessness, bronchitis that is recurrent, chest pain, blood streaked phlegm, recurrent chest infections or pneumonia and a persistent or changed cough or wheeze (Betterhealth, 2007). The detection of asbestos in the lungs of this patient is important because it means that then the cause of his lung carcinoma can be associated with asbestos and not only cigarette smoking since some of his symptoms are indicative of asbestos exposure. Measurement of the plaques will also assist in proving this link even further since most plaques are an indication of asbestosis-related disease. Clinically, lung cancers associated with asbestos and smoking alone are generally indistinguishable but the risk for lung cancer is increased in smokers (Liddell, 2001). Asbestos and cigarette smoke have an effect of synergism in the causation of lung cancer and in the patient ‘s case his accumulated pack years of cigarette smoking led to the increased risk for asbestos related disease (Hodgson and Darnton, 2006). In lodging his claim for damages the patient will have to present information on treatment that he has undergone as well as the results for all diagnostic tests related to the condition. This will help to make his case stronger as they will provide an indication of the costs of treatment, medication and also the effect of losing means of earning an income to his life and that of his family.

Clear research essay instructions

Clear research essay instructions Research essay One of the common assignments that professors give to students is writing a research essay. In order to produce an original work, you should bear in mind the following points:Select a fascinating subject. Thus, it will be easier for you to prepare the paper. In addition, the very process will not be boring. Conduct thorough research to gather valuable material on the explored matter. Write your work.As it is seen, there is nothing complicated in taking these steps. However, professors are often dissatisfied with the submitted papers. They say that students essays lack clarity. Therefore, it is necessary to find out how a work of the finest quality should be produced. Consider the following: First, you should select a great subject from a huge variety of research essay topics. Note that there are some cases when professors give students topics for examination on their own. For example, you may need to explore The history of Europe of the 20th century. Therefore, your task may be to identify significant events of that period and show how they have influenced peoples lives. You may also need to describe the most important people of that time and examine how they may have changed the history of the continent. For this reason, you should select a key historical event of the 20th century. If your topic seems too general, you should narrow it. Note that it may be hard to cover a broad subject. The thing is that you may collect enough useful information about the issue. Nonetheless, you will not know how to organize your work in the right way. When choosing a topic for your paper, you should avoid the following topic The development of European countries in the 20th century. It is better to formulate the topic in the following way: The legal system of Austria and its influence on the political and economic development of the country. If the subject of your piece of writing is specific, it will be easier to analyze it. In this case, you will surely understand how to write a research essay properly. When you are assigned to examine a particular issue, you need to analyze it in detail. You should not just provide readers with available information about the subject. If you explore it carefully, your professor will see that you are well aware of every detail about it. In order to write exclusive research essays, it is necessary to do detailed extensive research. Therefore, you should read books, articles, or journals containing concrete and interesting facts about the issue. Note that the best way to prepare a top-notch essay is to formulate the main idea clearly. There is no need to explore a few subjects at once. When the topic is selected, you should write a research essay outline. It is necessary to admit that each academic work consists of some basic parts. Thus, your paper should include Introduction, Body, and Concluding paragraph. When writing an introductory paragraph, you need to present your topic. The main body is a fundamental element of your essay. It usually includes a few paragraphs. Each of them discusses a particular idea relating to the topic. Students sometimes do not know how to organize the body appropriately to cover all the required aspects of the research essay. However, you should find and adopt a suitable method for constructing it. Do not forget to present your opinion on the matter and that of other researchers. The conclusion paragraph should summarize the main point of your work logically.

How Mark Antony manipulates the crowd after the death of Caesar Essay Example

How Mark Antony manipulates the crowd after the death of Caesar Essay Example How Mark Antony manipulates the crowd after the death of Caesar Essay How Mark Antony manipulates the crowd after the death of Caesar Essay Julius Caesar the Roman tragedy was written by the famous English playwright William Shakespeare in the year of 1599. The play is based on factual events, such as the assassination of Julius Caesar, the Roman dictator. Although Julius Caesar is set in Rome over 2000 years ago it explores themes such as ambition, greed, superstition, revenge, assassination and the universal theme of politics most of which are relevant to the present day and Shakespeares own time, the Elizabethan era. Julius Caesar was assassinated; the link to the Elizabethan era for this would be that several plots to kill Queen Elizabeth I were carried out. The link to our own time in this instance is the assassination of JFK president of the United States of America. In all three scenarios the conspiracies were set against extremely powerful people who were in leading roles during their lives. It is because of these links that the play Julius Caesar appealed to the people in Shakespeares time. Shakespeares Globe theatre kept the audience engaged and produced plays that were relevant to them. The people of the Elizabethan era were superstitious people, subsequently Shakespeare wrote his plays with elements of superstition in them e.g. ghosts spirits. In his play Tempest he has numerous spirits. In Macbeth Macbeth kills the king and then later dies a horrible death himself. We know that the people of the Elizabethan era believed in the divine order which means that they believed kings or queens were appointed by god and therefore only god could remove them from the seat of power. Consequently if anyone tries to remove them they will die horrible deaths. Shakespeare wrote for three audiences: the plebeians in the play, the Elizabethan audience and the contemporary audience. However the Elizabethan audience was the main audience partly because there were a lot more of them than the other audiences and partly because Shakespeares globe theatre relied mostly on their reactions to make the plays seem more realistic and exciting. The Elizabethan audience would throw orange peels and the like at the actors if the actors were acting a part of the play that they did not like, mostly the Elizabethan audience would react in this way when the part of the play would go against their belief for instance the killing of Julius Caesar. Even though the play is named after him, Julius Caesar is by no means the main character because most of the play is based on events after his death. The monarch was replaced by the republic four hundred years prior to the events of the play, when the king of Rome had been removed. From then onwards the senate had led Rome. At the beginning of Julius Caesar Caesar has become so powerful that he himself controls the senate. It seems the senate will declare him king before long. The republicans are appalled because the senate which they are particularly proud of is being destroyed. The senate is a system of government with a very precise and sensible balance of power, not unlike the parliament we have today. With anticipation of Caesar becoming king a band of conspirators including Caesars close friend Marcus Brutus decide to kill him. Antony another great friend of Caesars is enraged at Caesars death and is determined to get revenge no matter what the cost. Domestic fury and fierce civil Strife shall cumber all the parts of Italy. He wants civil war to spread throughout the whole of Italy, and shows Antonys desire for revenge has no limits because he will effectively destroy a country in order to get vengeance. Furthermore Antony mentions Ate With Ate by his side, come hot from hell. Ate is the goddess of vengeance, disorder and mischief. Therefore, in mentioning her one can speculate how far Antony will go in order to get revenge. Antony plans to manipulate the plebeians into rising in mutiny to enable him to get revenge. Blood and destruction shall be so in use. Antony says that blood and destruction will be ordinary events. Blood and destruction are barbaric events and if they are to become normal events then there is no doubt in the fact Antony must mean to bring about mass carnage and war. The time following the death of Caesar is full of carnage and disorder as the republicans -including the conspirators- and Caesars supporters struggle for power. One can ask many questions: is there a form of government that the ordinary people are better off? There are really two forms of government dictatorship and the republic. Dictatorship may lead to the dictator becoming a ruthless tyrant due to the fact of having lots of power at their disposal. The republic however has a major disadvantage as well because it is understood that in a republic people are elected to represent the public, but the people who are elected to represent the public [senators] may not put forwards what the public may want them to but rather do something else to suit their own needs and desires. Other questions such as who would be queen Elizabeth I successor as she had no children of her own. The link to the play in this is that Caesar never had any children but he chose somebody else as his successor. The contemporary relevance of this is that in some countries that are lead in dictatorship e.g. in Saudi Arabia the king chooses a successor to take over after they cease to exist. This can also be relevant to countries that have a parliament but also have a monarchy e.g. England, someone else has to take the place of the monarch after the king or queen die. At Caesars funeral Brutus allows Antony to give a speech after delivering one himself despite Cassius warning. Brutus starts his speech with, Romans, countrymen and lovers. This shows that he is on the same side as the plebeians. Furthermore he speaks in prose on the basis that if he speaks on the level of speech the plebeians speak on they will accept him as one of their own. Not that I loved Caesar less, but I loved Rome more. Brutus is stating that he loves Rome more than he loved Caesar and is highlighting the fact that he is patriotic. In addition he uses balanced sentences throughout his speech for example, as he was valiant I honour him. Brutus appeals to reason and uses balanced sentences as a tool to justify his actions and consequently makes them seem much nobler and more sacrifice like. At the conclusion of his speech Brutus is certain he has won over the crowd. When a plebeian says, Let him be Caesar. This highlights how Brutus has managed to get the plebeians on to his side. Dr Stanley wells says regarding Brutus letting Antony speak second that Brutus makes his mistake by telling Antony to speak second and what he should have really done was let Antony speak first so he knew what he was up against. I disagree with Dr Stanley wells on his opinion that Brutus should let Antony speak first so as to know what he was dealing with because firstly I think that Brutus should not have let Antony speak at all because he never had any concrete proof that Antony was on his side. I further disagree with Dr Stanley wells on the same point when he says as to know what he was up against because Brutus being honourable never suspected that Antony would act against him therefore he would not feel the need to let Antony speak second to find out what he was up against. Antony speaks directly after Brutus and has a difficult task him as he speaks to a hostile crowd outside the Roman parliament where Caesar was stabbed to death. The crowd is hostile because Brutus has spoken to them justifying the killing of Caesar and being fickle they were thoroughly on his side. Before Antony even speaks one of the plebeians says Twere best he speak no harm of Brutus here. This shows that the plebeians are hostile but prepared to listen. However Antony has the crowds attention because Brutus tells them to listen to him [Antony]. Secondly Antony enters carrying Caesars body which is used as a dramatic device which enables Antony to capture everyones attention. Antony begins his speech by saying, Friends, Romans, countrymen. He uses flattery to soothe the hostile crowd and to get them on his side. Antony also uses Caesars corpse as a plea for sympathy, which makes the plebeians feel sympathetic towards him. Antony uses the word honourable which is Brutuss best attribute, he was faithful and just to me, but Brutus says he was ambitious, And Brutus is an honourable man. Antony uses the word honourable describing Brutus after giving reason that Caesar was not ambitious. When the poor have cried Caesar hath wept; ambition should be made out of sterner stuff. Yet Brutus says he was ambitious, and Brutus is an honourable man. Antony uses repetition of the word honourable and taints Brutuss greatest attribute. In addition Antony involves the plebeians when he says that when the poor have cried Caesar has wept, Antony says this to make Caesar appear not to be ambitious but also to make the plebeians feel pity for Caesar and dislike his killers. After each stage of using the word honourable Antony manipulates the crowd. Antony uses rhetorical questions which state Caesar was not ambitious after giving reason to believe Caesar was not ambitious. Was this ambition? Antony successfully manipulates the plebeians in to thinking Caesar has been wronged. If thou consider rightly of the matter, Caesar has had great wrong. Antony uses sarcasm when he says honourable because really he is saying they are dishonourable, because the word honourable does not fit in with murderers. Antony gives four reasons as evidence when showing the plebeians Caesar was not ambitious. Firstly he says that Caesar was his friend faithful and just to him. Secondly he mentions that Caesar has bought many captives home to Rome. Thirdly Antony says that when the poor have cried Caesar too has cried. Lastly he says that he presented Caesar with a kingly crown three times which Caesar turned down and refused. Antony uses these four reasons as evidence that Caesar was not ambitious because the things Caesar does in them do not match with the deeds an ambitious person would do but rather a kind, merciful and loving person. Antony deals with Caesars worst point his desire to become king by simply saying, I thrice presented him a kingly crown, which he did thrice refuse. Antony is saying if Caesar wanted to become king he would surely have accepted the crown I offered him, and I did not only offer him the crown once, I offered it to him three times which Caesar refused. After Antony says he offered the crown and Caesar turned it down he uses a rhetorical question. Was this ambition? The rhetorical question gives the plebeians a moment to absorb what Antony has said, it gives them an opportunity to decide whether or not it was ambition. Furthermore Antony makes his point before asking the rhetorical question so what he said will be fresh in the plebeians head when they are given a chance in their minds to decide whether or not it was ambition. Antony mentions examples of Caesars noble and generous behaviour for example the fact that he freed many captives. He hath bought many captives home to Rome, whose ransom did the general coffers fill. Antony uses this example of Caesars generous behaviour to force the plebeians to revise their opinion of Caesar. Antony mentions Caesars noble behaviour When the poor have cried, Caesar hath wept. Antony makes out that Caesar loved the people of Rome in order to make the plebeians view Caesar in good light. Antony then uses a dramatic pause to extend his hold over the crowd with the power of emotion, My heart is in the coffin there with Caesar, and I must pause till it come back to me. Furthermore, Antony uses the dramatic pause as a way to see by how much he has one the crowd but more importantly let the crowd absorb and reflect upon what he has said. Antony is rewarded for using the dramatic pause by a plebeian saying, Methinks there is much reason in his sayings. For Antony this is an indicator on how far he has manipulated the crowd. Antony uses Caesars will as a prop, But heres a parchment with the seal of Caesar; I found it in his closet tis his will. Antony uses the will as a delaying tactic to hold the crowds curiosity, the will is the climax of Antonys speech because it is when Antony mentions the will the plebeians become most interested. The will, the will! We will hear Caesars will! furthermore divine order is mentioned, And dip their napkins into his sacred blood. Antony is clever to play on the plebeians superstition because the Romans believed in divine order. Antony mentions the word sacred as a reference to divine order and reminds the plebeians of their belief in the fact that if they do not do something about the removal of a person appointed by god they will die horrible deaths. Antony tells the plebeians that he does not intend to read out the contents of the will. Which pardon me I do not mean to read. However he tells the enough about the will to make them determined to hear the whole of its contents. Tis a good thing you know not that you are his heirs. Furthermore Antony informs them of how they should react when they hear the will. It will inflame you, it will make you mad. When the plebeians demand that Antony read out the will it gives him a chance to further his hold over them. And let me show you him that made the will. Antony then goes on to ask Shall I descend?, will you give me leave? Antony makes the plebeians think they are controlling him and the situation by asking their permission to descend. When the plebeians give him permission to descend Antony brings himself physically to their level unlike Brutus who used a different tactic namely speaking in prose. Once Antony has descended to the level of the plebeians he proceeds to say, If you have tears prepare to shed them now. Again here Antony gives the commoners ideas of what they should do and what he expects from them. Antony lies when he pretends to know who made which cut on Caesars cloak he does this to make the scene more dramatic, the murder more gruesome and the conspirators more treacherous. Look, in this place ran Cassius dagger through: see what a rent the envious Casca made. Antony mentions how close Brutus was to Caesar, For Brutus as you know was Caesars angel. This was the unkindest cut of all, for when the noble Caesar saw him stab, in gratitude more strong than traitors arms. Antony describes the closeness between Brutus and Caesar to highlight how dire the level of treachery was. Antony uses positive adjectives to describe Caesar saying he was a good man. Quite vanquishd him: then burst open his mighty heart. Antony counteracts what Brutus says [in balanced sentences] about the killing of Caesar being more an elegant sacrifice than cold blooded murder. Here, is himself, marrd, as you see with traitors. Antony says that the conspirators mutilated and disfigured Caesar and consequently rejoiced in the act of killing him. Antony finally destroys Brutuss most valued attribute [honour], I fear I wrong the honourable men whose daggers have stabbd Caesar, I do fear it. After Antony says this the plebeians realise that Brutus and his fellow conspirators are not honourable men. They were traitors, honourable men! In saying this Antony effectively stripped Brutus of his greatest attribute. Antony uses flattery while bringing about the subject of mutiny Good friends, sweet friends, let me not stir you up to a sudden flood of mutiny. Antony then goes on to say They are wise and honourable. Antony is being sarcastic because he already knows that the plebeians think badly of the conspirators, Let not a traitor live. Antony makes out that he is not an orator and is not good at giving speeches. For I neither have wit, nor words, nor worth, Action, nor utterance, nor the power of speech. I am no orator as Brutus is, but you all know me as a plain blunt man. Antony is trying to make himself seem plain and simple while at the same time by saying Brutus is the orator and therefore he is the manipulative one. Antony makes out that he is simple in order to give his words more standing. Furthermore if he was to make out he was clever and good at delivering speeches then the plebeians might not trust him because they might suspect him of trying to manipulate them. Antony points out that Brutus is the orator and he himself is a simple man. Antony says Brutus will try and manipulate you in to doing his will but he himself is again feeding ideas of mutiny to the plebeians. But were I Brutus, and Brutus Antony there were an Antony would ruffle up your spirits and put a tongue in every wound of Caesar that should move the stones of Rome to rise and mutiny. After using Caesars will as a delaying tactic Antony finally reveals the contents in a final effort to make the plebeians riot with maximum possible intensity. To every several man, seventy-five drachmas. In that time seventy-five drachmas would be quite a lot of money to a commoner as a result the plebeians would be overwhelmed with gratitude and would want to avenge Caesars death straight away with renewed intensity. However Antony increases the intensity and the sense of gratitude by further adding, He hath left you all his walks Antony mentions a few things like private arbours and newly planted orchards then he says He hath left them to you and your heirs forever. Antony uses the body of Caesar to move the citizens Come, away, away! Well burn his body in the holy place. The citizens move to cremate Caesar but in going they are up and running ready to mutiny And with the brands of fire burn the traitors houses. This highlights Antonys success in manipulating the crowd. While standing over Caesars corpse Antony said, Cry havoc and lets slip the dogs of war. This is just what Antony has achieved. One can say the plebeians are like sheep when one moves they all move. Antony was successful in manipulating the crowd because he appealed to emotion which is very powerful and can if applied correctly make people believe and follow you rather quickly. In addition, Antony uses a dramatic pause, dramatic device [Caesars corpse], delaying tactic when mentioning Caesars will to keep the plebeians attention and he makes out that he is not an orator consequently giving his words credibility and makes them seem like they have come straight from his heart. Antony was successful because he uses a variety of language techniques ranging from repetition to the use of rhetorical questions. It helped Antony that Brutus appealed to the reason of the crowd which in contrast to emotion is weak. Furthermore it further helps Antony that Brutus decides to speak first so then Antony knew what he is up against and how best to counteract what Brutus had said. Julius Caesar is relevant today for many reasons one of them is that like Antony many of the politicians these days manipulate people. Take Tony Blair and George Bush for example they used repetition when talking about weapons of mass destruction and saying they were going to help the civilians of Iraq, while all the while just like Antony appealing to emotion to get their way. Antony is your typical politician, although the circumstances were different then and Antony had a different goal which was to make the plebeians riot the overall goal is exactly the same manipulating people in order to get their own way.