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rickovertones

Tuesday, September 25, 2012

Microorganisms that crashed to Earth embedded in the fragments of distant planets might have been the sprouts of life on this one, according to new research from Princeton University, the University of Arizona and the Centro de Astrobiolog?a (CAB) in Spain.

The researchers report in the journal Astrobiology that under certain conditions there is a high probability that life came to Earth ? or spread from Earth to other planets ? during the solar system's infancy when Earth and its planetary neighbors orbiting other stars would have been close enough to each other to exchange lots of solid material. The work will be presented at the 2012 European Planetary Science Congress on Sept. 25.

The findings provide the strongest support yet for "lithopanspermia," the idea that basic life forms are distributed throughout the universe via meteorite-like planetary fragments cast forth by disruptions such as volcanic eruptions and collisions with other matter. Eventually, another planetary system's gravity traps these roaming rocks, which can result in a mingling that transfers any living cargo.

[Images and video can be seen at http://www.princeton.edu/main/news/archive/S34/82/42M30. To obtain high-res images, contact Princeton science writer Morgan Kelly, (609) 258-5729, mgnkelly@princeton.edu]

Previous research on this possible phenomenon suggests that the speed with which solid matter hurtles through the cosmos makes the chances of being snagged by another object highly unlikely. But the Princeton, Arizona and CAB researchers reconsidered lithopanspermia under a low-velocity process called weak transfer wherein solid materials meander out of the orbit of one large object and happen into the orbit of another. In this case, the researchers factored in velocities 50 times slower than previous estimates, or about 100 meters per second.

Using the star cluster in which our sun was born as a model, the team conducted simulations showing that at these lower speeds the transfer of solid material from one star's planetary system to another could have been far more likely than previously thought, explained first author Edward Belbruno, a mathematician and visiting research collaborator in Princeton's Department of Astrophysical Sciences who developed the principles of weak transfer.

The researchers suggest that of all the boulders cast off from our solar system and its closest neighbor, five to 12 out of 10,000 could have been captured by the other. Earlier simulations had suggested chances as slim as one in a million.

"Our work says the opposite of most previous work," Belbruno said. "It says that lithopanspermia might have been very likely, and it may be the first paper to demonstrate that. If this mechanism is true, it has implications for life in the universe as a whole. This could have happened anywhere."

Co-authors Amaya Moro-Mart?n, an astronomer at CAB and a Princeton visiting research collaborator in astrophysical sciences, and Renu Malhotra, a professor of planetary sciences at Arizona, noted that low velocities offer very high probabilities for the exchange of solid material via weak transfer, and also found that the timing of such an exchange could be compatible with the actual development of the solar system, as well as with the earliest known emergence of life on Earth. Dmitry Savransky, a Princeton mechanical and aerospace engineering doctoral student, conducted the simulations.

The researchers report that the solar system and its nearest planetary-system neighbor could have swapped rocks at least 100 trillion times well before the sun struck out from its native star cluster. Furthermore, existing rock evidence shows that basic life forms could indeed date from the sun's birth cluster days ? and have been hardy enough to survive an interstellar journey and eventual impact.

"The conclusion from our work," Moro-Mart?n said, "is that the weak transfer mechanism makes lithopanspermia a viable hypothesis because it would have allowed large quantities of solid material to be exchanged between planetary systems, and involves timescales that could potentially allow the survival of microorganisms embedded in large boulders."

All about velocities

The Princeton-Arizona-CAB paper cites two previous studies that present the odds of solid matter from one planetary system being captured by another as being more or less dismal.

The first, a 2003 paper published in Astrobiology by Jay Melosh, a Purdue University earth and atmospheric sciences professor, questioned the probability that meteorites have ever escaped a terrestrial planet in Earth's solar system and wound up on a terrestrial planet in another system. The report concluded that the chances ? about one in 10,000, or 0.01 percent ? are "overwhelmingly unlikely" considering the speed a meteorite would need to travel (about six kilometers per second) and the roominess of space.

Belbruno and his co-authors calculated that under this scenario of high velocities and dispersed planetary systems, the probability of solid material from any planetary system striking another falls to as little as five in 100,000, or 0.005 percent.

Star birth clusters, which are tightly confined groups of stars and planetary systems, were introduced as a possible setting for lithopanspermia in a 2005 Astrobiology paper by David Spergel, Princeton's Charles A. Young Professor of Astronomy on the Class of 1897 Foundation and chair of astrophysical sciences, and University of Michigan physics professor Fred Adams.

Factoring in velocities of two to five kilometers per second, Spergel and Adams found that the chances of an exchange of life-bearing rocks between star systems clustered in groups of 30 to 1,000 could be as unlikely as one in a million to as good as one in 1,000, or 0.0001 to 0.1 percent, respectively. Spergel and Adams, however, limited their study to binary stars ? or planetary systems with two stars ? which might elevate star-to-star solid matter exchanges, Moro-Mart?n said.

Nonetheless, in clusters similar to those considered by Spergel and Adams, weak transfer involves relative velocities of no more than one kilometer per second, which substantially increases the probability of capture by other stars in the cluster. In other words, star clusters provide an ideal setting for weak transfer, Belbruno said.

Chaotic in nature, weak transfer happens when a slow moving object such as a meteorite wanders into the outer edge of the gravitational pull of a larger object with a low relative velocity, such as a star or massive Jupiter-like planet. The smaller object partially orbits the large object, but the larger object has only a loose grip on it. This means the smaller object can escape and be propelled into space, drifting until it is pulled in by another large object.

Belbruno first demonstrated weak transfer with the Japanese lunar probe Hiten in 1991. A mechanical malfunction left the probe with insufficient fuel to enter the moon's orbit the traditional way, which is to approach at a high speed then fire retrorockets to slow down. Instead, Belbruno designed a weak-transfer trajectory that got the probe into orbit around the moon using a minimal amount of fuel.

Adams, co-author of the 2005 paper with Spergel, said that the work by Belbruno and his co-authors succeeds at pulling together the various factors of earlier lithopanspermia models and adding a substantial new element ? chaos. Adams is familiar with the study but had no role in it.

"This paper takes the type of calculations that have been done before and makes an important generalization of previous work," Adams said. "Their work on chaos in this context also carries the subject forward. They make a careful assessment of a process that is dynamically quite complicated and chaotic in nature.

"They are breaking new ground from the viewpoint of dynamical astrophysics," Adams said. "Regarding the problem of lithopanspermia, this type of weak capture and weak escape is interesting because it allows for the ejection speeds to be small, and these slow speeds allow for higher probabilities of rock capture. To say it another way, chaos, in part, enhances the prospects for lithopanspermia."

To the simulator!

Star birth clusters satisfy two requirements for weak transfer, Moro-Mart?n said. First, the sending and receiving planetary systems must contain a massive planet that captures the passing solid matter in the weak-gravity boundary between itself and its parent star. Earth's solar system qualifies, and several other stars in the sun's birth cluster would too.

Second, both planetary systems must have low relative velocities. In the sun's stellar cluster, between 1,000 and 10,000 stars were gravitationally bound to one another for hundreds of millions of years, each with a velocity of no more than a sluggish one kilometer per second, Moro-Mart?n said.

The team simulated 5 million trajectories between single-star planetary systems ? in a cluster with 4,300 stars ? under three conditions: the solid matter's "source" and "target" stars were both the same mass as the sun; the target star was only half the sun's mass; or the source star was half the sun's mass.

The researchers explored the likelihood that our solar system exchanged solid matter with its closest planetary-system neighbor during the first hundreds of millions of years it existed. At that time, our sun belonged to a tight-knit star cluster filled with other planetary systems. The above simulation shows that two planetary systems (green and blue dots) -- about 3.26 light years apart -- orbit a common center of mass. Over a period of roughly 8.7 million years, various objects (black dots) are pulled in and repelled by the systems' gravity. Displaying weak transfer, one object (red dot) first wanders into the green system's gravity boundary and partially orbits it before being cast off. The red object then drifts before being pulled in by the blue planetary system. Credit: Video by Dmitry Savransky

The odds of a star capturing solid matter from another planetary system under these three scenarios are 15 (0.15 percent), five (0.05 percent) and 12 (0.12 percent) in 10,000, respectively, the researchers report ? probabilities that exceed those under the conditions proposed by Melosh by a factor of 1 billion.

To estimate the actual amount of solid matter that could have been exchanged between the sun and its nearest star neighbor, the researchers used data and models pertaining to the movement and formation of asteroids, the Kuiper Belt ? the solar system's massive outer ring of asteroids ? and the Oort Cloud, a hypothesized collection of comets, ice and other matter about one light year from Earth's sun widely believed to be a primary source of comets and meteorites.

The researchers used this data to conclude that during a period of 10 million to 90 million years, anywhere between 100 trillion to 30 quadrillion solid matter objects weighing more than 10 kilograms transferred between the sun and its nearest cluster neighbor. Of these, some 200 billion rocks from early Earth could have been whisked away via weak transfer.

For lithopanspermia to happen, however, microorganisms first have to survive the long, radiation-soaked journey through space.

Moro-Mart?n and Malhotra consulted a 2009 paper an international team published in the Astrophysical Journal that determined how long microorganisms could survive in space based on the size of the solid matter hosting them. That group's computer simulations showed that survival times ranged from 12 million years for a boulder up to 3 centimeters (roughly one inch) in diameter, to 500 million years for a solid objects 2.67 meters (nearly nine feet) across.

The researchers estimated that under weak transfer, solid matter that had escaped one planet would need tens of millions of years to finally collide with another one. This falls within the lifespan of the sun's birth cluster, but means that lithopanspermia by weak transfer would have been limited to planetary fragments at least one meter, or about three feet, in size.

Matching the theory with life

As for the actual transfer of life, the researchers suggest that roughly 300 million lithopanspermia events could have occurred between our solar system and the closest planetary system.

But even if microorganisms survived the trip to Earth, the planet had to be ready to receive them. The researchers reference rock-dating evidence suggesting that the Earth contained water when the solar system was only 288 million years old and that very early life might have emerged before the solar system was 718 million years old.

The sun's birth cluster ? assumed to be roughly the same age as the Earth's solar system ? slowly broke apart when the solar system was approximately 135 million to 535 million years old, Moro-Mart?n said. In addition, the sun could have been ripe for weak transfer up to 700 million years after the solar system formed.

So, if life arose on Earth shortly after surface water was available, there were possibly about 400 million years when life could have journeyed from the Earth to another habitable world, and vice versa, the researchers report. If life had an early start in other planetary systems and developed before the sun's birth cluster dispersed, life on Earth may have originated beyond our solar system.

The paper stops short of calculating the likelihood of extrasolar life taking root on a terrestrial planet such as Earth, but the higher probability the researchers determined for solid-matter transfer makes that a more worthwhile pursuit, Moro-Mart?n said.

"Our study stops when the solid matter is trapped by the second planetary system, but for lithopanspermia to be completed it actually needs to land on a terrestrial planet where life could flourish," Moro-Mart?n said. "The study of the probability of landing on a terrestrial planet is work that we now know is worth doing because large quantities of solid material originating from the first planetary system may be trapped by the second planetary system, waiting to land on a terrestrial planet.

"Our study does not prove lithopanspermia actually took place," Moro-Mart?n said, "but it indicates that it is an open possibility."

###

The paper, "Chaotic Exchange of Solid Material between Planetary Systems: Implications for Lithopanspermia," was published Sept. 12 by Astrobiology

Princeton University: http://www.princeton.edu

Thanks to Princeton University for this article.

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rickovertones

Here is a recent decision of the Tax Court of Canada in Kossow.? http://decision.tcc-cci.gc.ca/en/2012/2012tcc325/2012tcc325.html

Docket: 2005-1974(IT)G

BETWEEN:

KATHRYN KOSSOW,

Appellant,

and

HER MAJESTY THE QUEEN,

Respondent.

____________________________________________________________________

Appeal heard on April 26-29, May 2-6, & July 19, 2011,

at Toronto, Ontario

Before: The Honourable Justice Valerie Miller

Appearances:

Counsel for the Appellant:
A. Christina Tari,

Jason Puterman,

Cindy Chiu
Counsel for the Respondent:
Arnold H. Bornstein,

John Grant,

Lorraine Edinboro,

Patricia Lee

____________________________________________________________________

JUDGMENT

The appeal from the reassessments made under the Income Tax Act for the 2000, 2001 and 2002 years is dismissed in accordance with the attached Reasons for Judgment.

Costs are awarded to the Respondent.

? ? ? Signed at Ottawa, Canada, this 14th day of September 2012.

?V.A. Miller?

V.A. Miller J.

Citation: 2012TCC325

Date: 20120914

Docket: 2005-1974(IT)G

BETWEEN:

KATHRYN KOSSOW,

Appellant,

and

HER MAJESTY THE QUEEN,

Respondent.

REASONS FOR JUDGMENT

V.A. Miller J.

[1]? ? ? ? In 2000, 2001 and 2002 the Appellant participated in a leveraged-charitable donation[1] arrangement promoted by Berkshire Funding Initiatives Limited and Talisker Funding Limited (the ?Berkshire Program? and sometimes ?Program?). As a participant in the Berkshire Program, she made purported donations to and received charitable tax receipts from Ideas Canada Foundation (?Ideas?) in the amounts of $50,000, $60,000 and $50,000 in 2000, 2001 and 2002 respectively (the ?Donations?). In the present appeal, the Appellant?s Donations were funded by 20% cash from her and 80% from a 25 year, non-interest bearing loan provided to her by one of the promoters of the Berkshire Program.

[2]? ? ? ? The Appellant claimed a tax credit in respect of the Donations of $50,000, $60,000 and $50,000 in 2000, 2001 and 2002. By notices of reassessment dated September 2, 2004, the Minister of National Revenue (the ?Minister?) disallowed 80% of the tax credit claimed for each year. In a reassessment dated September 9, 2005, the Minister disallowed the entire tax credit for the 2002 taxation year.

[3]? ? ? ? The issues in this appeal are: (a) whether the Donations made by the Appellant were gifts within the meaning of subsection 118.1(1) of the Income Tax Act (the ?Act?); (b) whether the general anti-avoidance rule is applicable to deny the tax credits to the Appellant; and, (c) who has the onus of proving the Minister?s assumptions when those assumptions involve third parties.

[4]? ? ? ? Based on my analysis of the facts and law, the appeal cannot succeed because I have concluded that the decision in Mar?chaux v. The Queen, 2010 FCA 287 is determinative of the first issue in this appeal. As a result, I have also concluded that I do not have to address the second issue. In the circumstances of this appeal, it is not necessary for me to decide who had the onus of proving the Minister?s assumptions as there was sufficient evidence presented at the hearing which allowed me to make my decision.

[5]? ? ? ? At the hearing, the Respondent called the following witnesses who held the following positions during the years at issue. All witnesses, except the Canada Revenue Agency (?CRA?) employee, gave their evidence under subpoena issued by the Respondent.

Yeti Agnew, lawyer for the MacLaren Art Centre;

? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ?

William Moore, Executive Director of the MacLaren Art Centre until December 2003;

? ? ? Jack Keslassy, Administrative Director of Berkshire Funding Initiatives Ltd., President of Berkshire Foundation Ltd. and Talisker Funding Ltd.;

? ? ? Allan Beach, lawyer for James Penturn, Berkshire Funding Initiatives Ltd., Talisker Funding Ltd., Joan Krawczyk Fine Art Inc. and Jennings Art Consultants Ltd.;

? ? ? David Sanderson, Executive Director of Ideas;

? ? ? Cheryl McCann, Valuation Specialist with the Canada Revenue Agency.

[6]? ? ? ? There were copious documents tendered as evidence in this appeal and the hearing lasted ten days.

[7]? ? ? ? Prior to deciding whether the Donations made by the Appellant were gifts and to put the Donations in context, I will summarize the main points in the evidence and, in so doing, will describe the Berkshire Program and what happened to the Donations after they were received by Ideas.

Background

[8]? ? ? ? In these reasons, I have used the term Participant to represent an individual who made a donation to Ideas.

[9]? ? ? ? The Appellant obtained her Masters in Business Administration with a speciality in marketing in 1978 from York University. She conducted marketing research in the pharmaceutical industry first as a sole proprietor and later through Kossow Research and Associates which she had incorporated in 2001.

[10]? ? ? The Appellant learned of the Berkshire Program in October 2000 from her investment advisor, Donnovan DePass of Capital Management Group. She became a Participant in 2000 and 2001 through Mr. DePass. In 2002, she met directly with Jack Keslassy[2] (?Keslassy?) to become a Participant. (Later in these reasons, I will describe Keslassy?s role in the Berkshire Program.)

[11]? ? ? It was the Appellant?s evidence that she was attracted to the Berkshire Program because, according to its promotional material, Ideas donated to several arts related organizations and the Program would allow her to make a larger donation than she could otherwise make to support the arts. According to the Appellant, the tax savings was a secondary consideration.

[12]? ? ? I note that from 1988 to 1999, the Appellant made charitable donations which ranged from $201 to $1,360.

The Berkshire Program

[13]? ? ? I do not know when the idea for the Berkshire Program was first conceived. However, Allan Beach (?Beach?), a partner with Fasken Martineau DuMoulin LLP (?Fasken?), testified that he became involved in the Berkshire Program in the early summer of 2000.

[14]? ? ? The Berkshire Program was conceived by a fundraising group and an art dealer group who worked in concert to develop the details of the Program.

[15]? ? ? The individuals in the fundraising group were James Penturn (?Penturn?), Richard Glatt (?Glatt?) and Jack Keslassy (?Keslassy?). It was their idea that the Donations from the Participants would consist of an interest-free loan component and a cash component.

[16]? ? ? The art dealer individuals were Hazel Hett (?Hett?), Gerard Jennings (?Jennings?), Joan Krawczyk (?Krawczyk?) and Elizabeth Sumption. The corporate entities in this group were Jennings Art Consultants Limited (?Jennings Art?), Joan Krawczyk Fine Art Inc. (?JKFA?) and Gower Street Gallery Limited, later renamed GSG Limited and hereinafter referred to as ?GSG?. The art dealers arranged for works of art to be acquired by the MacLaren Art Centre (the ?MacLaren?) using the funds raised in the Berkshire Program. The MacLaren is located in Barrie, Ontario.

(a) The Fundraising Group

[17]? ? ? The individuals in the fundraising group had, at various times, been involved in the sale of tax shelter programs.

[18]? ? ? Keslassy worked for Penturn and Glatt since the early 1990s. Prior to the Berkshire Program, he had been the Administrative Director of AFE Consultants Limited, an art purchase and donation tax shelter. It was his evidence that he worked for Penturn at AFE Consultants Limited. When this tax shelter was impacted by the February 2000 budget, the Berkshire Program was created.

[19]? ? ? As early as August 25, 2000, Keslassy, as Administrative Director of The Berkshire Foundation Limited, contacted individuals and investment advisors to interest them in participating in the Berkshire Program. The Berkshire Foundation Limited was later renamed Talisker Funding Limited (?Talisker?) and I will refer to it as Talisker in these reasons. Keslassy was the President, director and sole shareholder of Talisker and he processed the paperwork for the Berkshire Funding Initiatives Limited (?Berkshire?).

[20]? ? ? Both Berkshire and Talisker promoted the Berkshire Program. Berkshire was the fundraiser and Talisker made the loans to the Participants.

[21]? ? ? Neither Penturn nor Glatt testified at the hearing. However, the evidence established that they were Co-Presidents of Berkshire.

[22]? ? ? On or before August 21, 2000, Penturn engaged David Sanderson to be the Executive Director of Ideas. David Sanderson had worked for James Penturn and his father, Norton Penturn in various tax shelter programs since the 1980?s.

[23]? ? ? Ideas was settled as a charitable trust on September 22, 2000 and it became a registered charity effective November 1, 2000[3]. Its role in the Berkshire Program was to issue charitable receipts to the Participants, to make donations to charities and to facilitate the circular flow of the Donations through an escrow account.

[24]? ? ? Berkshire recruited lawyers, accountants and investment advisors from across the country to be sales agents for the Berkshire Program. These sales agents signed an agency agreement with Berkshire and they were paid a commission based on the quantum of Donations they raised[4].

[25]? ? ? The sales agents were provided with promotional materials to describe the Program to their clients. According to these materials, some of the features of the Program were:

-? ? ? Support of educational and cultural institutions

-? ? ? Cash contribution of 30% of total donation; 20% used for the donation and 10% as a security deposit

? ? ? -? ? ? Loan for 80% of total donation

? ? ? -? ? ? Loan is interest free for 25 years

-? ? ? Security deposit to be invested by lender and guaranteed to meet or exceed benchmarked rate of return

? ? ? -? ? ? Loan processing fee of 1-5%

-? ? ? Tax opinion from the law firm of Thorsteinssons, Canada?s largest law firm dealing exclusively in the area of taxation

-? ? ? Cumulative cash flow advantage of 40.88% in 2000, 52% in 2002 for residents of Ontario when they donated $50,000

-? ? ? Key Benefits ? cash donation; no valuation risk; tax advantages

[26]? ? ? The Berkshire Program was in existence from 2000 until 2003. During this period, Talisker made more than $160,000,000[5] in loans to approximately 1200 Participants. Talisker stopped making loans in February 2003[6] because of proposed amendments to the Act[7].

[27]? ? ? Sometime in 2003, a new program called the Millennium Charitable Foundation came into existence and the Appellant participated in this program through Keslassy. I do not know any details about the Millennium Charitable Foundation except that the Appellant paid $16,000 to receive a charitable receipt of $48,000 from it.

(b) The Art Dealers and The Art

[28]? ? ? According to this component of the Program, 88% of the Donations to Ideas were deposited into an escrow account held by Fasken on account of a gift which Ideas wanted to make to the MacLaren. However, the MacLaren had no control over 87.5% of those funds. They had to be used to purchase art which the dealers made available to the MacLaren at a price which the dealers dictated.

[29]? ? ? On a review of the evidence, I have concluded that Hett was the person who planned the art component of the Berkshire Program. Sometime prior to October 4, 2000[8], she agreed to help William Moore raise funds for the MacLaren through Ideas. They intended that the MacLaren would acquire an inventory of Rodin bronzes which it could sell over a period of years to raise money.[9] The MacLaren wanted to build a project called Art City in the city of Barrie, Ontario.

[30]? ? ? Hett negotiated an agreement with Gary Snell, owner of Gruppo Mondiale (?Gruppo?), that Gruppo would manufacture, in Italy, 12 sets of Rodin bronzes for the MacLaren. Each set was to contain 51 bronzes for a total of 612 bronzes. These were called the MacLaren Edition. Hett negotiated that the MacLaren Edition would be sold to JKFA for US $6,000,000[10].

[31]? ? ? Within a two day period, there were four contracts which were signed with respect to the MacLaren Edition of the Rodin bronzes. In the space of these two days, the price for the bronzes increased 18 fold from US $6,000,000 to US $108,840,000. The details were as follows.

[32]? ? ? On November 30, 2000, JKFA entered into a written contract with Gruppo for the MacLaren Edition of Rodin bronzes. At this time, JKFA also received 612 signed ?Bills of Sale & Certificates of Title? which were to be released to the MacLaren as Gruppo was paid for each set. The contract specified that delivery, inspection and acceptance of the bronzes were to take place in Italy at JKFA?s expense.

[33]? ? ? A day after signing the contract with Gruppo, JKFA assigned its interest in the contract to GSG. Hett was a consultant to GSG. The same day, that is, December 1, 2000, GSG consigned the MacLaren Edition to Jennings Art for US $108,840,000. The sale was governed by a ?Marketing and Consignment Contract? which had been made between the parties on August 15, 2000.

[34]? ? ? Again on December 1, 2000, Jennings Art agreed to sell the MacLaren Edition of Rodin bronzes to the MacLaren for US $108,840,000. There was no negotiation on the price to be paid by the MacLaren. It was decided by the vendor[11] with the use of a purported ?Valuation Summary? prepared by Stewart Waltzer. I refer to the valuation as purported because it was not based in reality. It was prepared before the Rodin bronzes were manufactured; it was based on ?numerous suppositions?; and, Stewart Waltzer had not even seen the plasters from which the bronzes would be made.

[35]? ? ? According to Beach, a dispute arose between JKFA and Gruppo and only 10 of the 12 sets of bronzes were completed, inspected and title transferred to the MacLaren. JKFA paid US $5,000,000 for the 10 sets. None of the bronzes was landed in Canada. The MacLaren has never received any of the MacLaren Edition bronzes.

[36]? ? ? There was no evidence before me which showed that the MacLaren Edition of the Rodin bronzes actually existed. None of the witnesses who appeared before me saw or inspected them. The declarations of inspection of the bronzes were completed by Hett or Gerard Jennings or Joan Krawczyk [12], the art dealers who helped to plan the Berkshire Program. The declarations of inspection were not made exhibits and no documents were submitted which would allow me to conclude that the MacLaren Edition of the Rodin bronzes were actually manufactured.

[37]? ? ? The MacLaren received title to 10 sets of the Rodin bronzes. However, even after it was apparent that the MacLaren would not get title to the remaining two sets of Rodin bronzes, funds continued to be deposited to the Fasken escrow account for the benefit of the MacLaren. The art dealers had to arrange for the MacLaren to acquire other pieces of art to support the amounts being deposited to the escrow account. They then arranged for the MacLaren to receive a collection of prints by Henry Moore in substitution for the two remaining sets of bronzes. Pursuant to a letter dated October 25, 2002, Jennings agreed to sell a set (676) of Henry Moore prints for US $35,000,000 to the MacLaren.

[38]? ? ? The complete collection of Henry Moore prints consisted of 693 prints. This collection had been sold to JKFA for US $1,450,000 on February 11, 2002 by Gilles Abrioux, an art dealer in Chicago.

[39]? ? ? Hett also arranged for the MacLaren to acquire 17 Rodin plasters which she owned. The cost of these plasters to the MacLaren was $3,256,000. There was no evidence with respect to the cost of these plasters to Hett. There was no evidence concerning the valuation of these plasters.

(c) The Appellant as a Participant

[40]? ? ? To become a Participant in the Berkshire Program, the Appellant was required to complete the following steps, which she did in 2000, 2001 and 2002:

(a)? ? sign a Pledge to Ideas for the full amount of her Donation;

(b)? make a Loan Application for a 25 year, interest-free loan equal to 80% of her Donation to Talisker (I will refer to this as the ?Loan Amount?);

(c)? ? sign a cheque for 20% of her Donation made payable to Talisker ?as agent?;

(d)? ? pay Talisker a security deposit equal to 10% of her Loan Amount which was to be invested for the purpose of increasing to the Loan Amount in 25 years;

(e)? ? pay Talisker a loan processing fee of 1-5% of the Donation;

(f)? ? sign a document called a promissory note for the Loan Amount, due 25 years from the date on the note.

[41]? ? ? Ideas was the designated charity on the Loan Applications and the Loan Amounts could only be used to make donations to Ideas.

[42]? ? ? The Donation was conditional on the Loan Application being approved. If it was not approved, the Appellant?s deposit (20% of the Donation) would have been returned to her.

[43]? ? ? Talisker forwarded the Loan Amounts and the funds received ?as agent? to Ideas who then sent charitable receipts to the Appellant.

[44]? ? ? The particulars of the Appellant?s transactions were as follows:

Year
Donation
Loan

Amount
20% of

Donation
Security

Deposit
Loan

Processing

Fee
Charitable

Receipt
2000
$50,000
$40,000
$10,000
$5,000
$2,000
$50,000
2001
$60,000
$56,400[13]
$12,000
$6,000
$2,400
$60,000
2002
$50,000
$40,000
$10,000
$5,000
$2,000
$50,000

[45]? ? ? As a result of the charitable receipts from Ideas, the Appellant claimed the following Tax Credits:

Year
Tax Credits
2000
$20,046
2001
$24,060
2002
$20,045

[46]? ? ? Pursuant to a power of attorney, Talisker invested the security deposits in mutual funds chosen by the Appellant from a list determined by Talisker.

[47]? ? ? The Appellant testified that she now believes that the investments will not be sufficient to repay the Loan Amounts at the maturity dates. She stated that she has invested additional funds so that she can meet her obligations when the loans mature. However, this testimony was not supported by any documentary evidence.

[48]? ? ? I note that Talisker has assigned the Appellant?s security deposits and debts to GSG. According to the statements received by the Appellant since 2003, her security deposits have been deposited in GSG Collateral Security Account. She testified that she has not made any inquiries about this investment.

(d) The Circulation of the Loans Amounts

[49]? ? ? The circular flow of the Loan Amounts was succinctly described in the Respondent?s Submissions as follows:

In a nutshell, Talisker borrowed money from a Canadian lender in order to make the loans to the participants. Talisker borrowed money from an offshore lender in order to repay the Canadian lender. The offshore lender used funds directed to it from the ?donations? to make these loans to Talisker. Transactions involving parties other than the participants ensured that Talisker would be able to repay the Canadian lender[14].

[50]? ? ? In 2000, Talisker borrowed monies from Standard Mercantile Bancorp., Limited Partnership (?Standard?) pursuant to a Credit Facility Agreement, dated December 4, 2000. The amounts borrowed from Standard were used to make the loans to the Participants[15].

[51]? ? ? Beach described the circulation of the monies as follows:

His loan was designed ?? sorry, the Standard loan was designed as a daylight loan which would effectively move money through, I think, in this case, a series of accounts, bank accounts, established for each of the parties in the chain of payments.? The end result of which would be some or all of that loan would end up back with Standard within 24 or 48 hours[16].

[52]? ? ? The return of the Loan Amounts to Standard within 24 to 48 hours was made possible through the use of an escrow account held by Fasken, a set of Directions which had been prepared by Beach and bank accounts held by each party in the chain of payments at various branches of the TD Bank in Toronto.

[53]? ? ? The parties in the chain of payments, the Directions and the circulation of the funds were as follows (For clarity, I have attached a diagram at Appendix ?A? to these reasons which illustrates the circulation of the Loan Amounts):

(a)? The advances from Standard were deposited to the bank account of Irwin Singer (?Singer?), in trust, who directed the TD Bank to credit the advances to the bank account of Talisker.

(b)? Talisker directed the TD Bank to combine the advances from Standard with the amounts paid to it ?as agent? and issue bank drafts to Ideas in the names of each of the Participants for 100% of their Donation. Talisker gave the TD Bank a list of the Participants? names with the Donation made by each Participant.

(c)? Ideas directed the TD Bank to deposit the proceeds of the bank drafts to its bank account. It then authorized the TD Bank to debit its account for 88% of the Donations and deliver a cheque or bank draft for this amount to Fasken on account of a gift to be made by Ideas to MacLaren.

(d)? Ideas directed Fasken to deposit 88% (on some occasions 86%) of the Donations to an escrow account held in trust for the MacLaren. (Ideas paid Berkshire 11% of the Donations for its fundraising services. The remaining 1% of the Donations was used by Ideas to pay its expenses and salaries and to make donations to charities chosen by Sanderson.)

(e)? The MacLaren authorized and directed Fasken to pay all amounts received from Ideas, except 0.5%, to Jennings Art. The 0.5% was paid to the MacLaren for its building fund.

(f)? Jennings Art directed Fasken to pay amounts to GSG. I assume that Jennings Art received a commission but the percentage was not put into evidence.

(g)? GSG directed Fasken to pay ?the amounts as may from time to time be requested? in writing by Wigmore Investments Limited (?Wigmore?).

(h)? Wigmore directed Fasken to pay Talisker those amounts which Fasken had received on its behalf from GSG. According to the evidence, I conclude that GSG received at least 80% of the Donations and it directed that the Loan Amounts be paid to Wigmore who directed that they be paid to Talisker[17]. Elizabeth Sumption in Barbados gave directions for both GSG[18] and Wigmore[19]. According to Beach, these amounts were Wigmore?s advances to Talisker under their loan agreement[20].

(i)? ? Talisker directed Fasken to deposit the amounts received from Wigmore into Talisker?s bank account at the TD Bank.

(j)? ? Talisker directed the TD Bank to credit 80% of the Donation (the Loan Amount) to the account of Irwin Singer in trust.

[54]? ? ? The loan agreement between Talisker and Wigmore was made on October 12, 2000 and it specified that the advances given to Talisker could be used only for the Berkshire Program. Any amounts advanced by Wigmore to Talisker were interest free until December 31, 2010.

[55]? ? ? Talisker relied on advances from Standard in 2000 and 2001 to fund the Loan Amounts to the Participants in the Program. By 2002, Talisker used its own funds to fund the Loan Amounts[21]. However, even in 2002, the Loan Amounts circulated through Wigmore and returned to Talisker.

[56]? ? ? In cross examination, Beach was asked why GSG was directing the escrow account to make payments to Wigmore. The question and his answer follow:

Q.? ? ? ? ? ? ? ? ? Why was Gower Street Gallery permitting your firm or your escrow account to make payments to Wigmore?

A.? ? ? ? ? ? ? ? ? This was the mechanic in which it was ?? well, it is part of the daylight loan we are discussing now, but this is how some or all of the money that originated with Irwin Singer would be ultimately repaid to Irwin Singer[22].

He was later asked the same question but answered that he did not know the answer.

[57]? ? ? In conclusion, I could not ascertain the exact quantum of monies which was transferred between Jennings and GSG and Wigmore. However, I concluded from Beach?s evidence and exhibit R-7, Tab C1 page 24 that the Loan Amounts circulated through the escrow account and were returned to Standard within 24 to 48 hours.

(e)? ? The Amounts Reported in the Information Returns

[58]? ? ? Ideas reported the following amounts in its Information Returns. Its fiscal year end was August 31.

August 31, 2001
August 31, 2002
August 31, 2003
Gifts

Received
$81,725,350
$85,551,485
$37,894,705
Gifts to

MacLaren
$71,771,420
$75,605,932
$33,157,540
Gifts to Other

Charities
? ? $235,458
? $183,500
? ? $15,000

[59]? ? ? Beach informed the MacLaren that the following amounts had been paid on its behalf.

December 11, 2000 to

August 31, 2001
September 1, 2001 to

August 31, 2002
September1, 2002 to

February 18, 2003
$71,771,420
$75,405,932
$32,986,620

He wrote that $141,831,761 went towards the acquisition of 10 sets of the Rodin bronzes; $3,256,000 went towards the acquisition of 17 Rodin plasters; and, $35,076,211 went towards the acquisition of 433 Henry Moore prints. The MacLaren also received $1,314,817 towards its building fund.

[60]? ? ? In its Information Returns, the MacLaren reported in its fiscal year end December 31, 2000, that it had received $63,975,933 and in its fiscal year end December 31, 2001, that it had received $71,124,299 from a registered charity. In its fiscal year end December 31, 2002, it reported that it had received nothing from a registered charity.

[61]? ? ? The essence of the Berkshire Program was that little cash was given to a few charities and the MacLaren was required to acquire art from the creators of the Program with the Donations allocated to it.

[62]? ? ? In conclusion, I note that the Appellant was not aware of most of these individuals or the transactions described above when she first became a Participant in the Berkshire Program. The aspects of the Program which directly affected her were described under the heading ?The Appellant as a Participant?.

[63]? ? ? When the Appellant became a Participant in the Berkshire Program, she was not familiar with Ideas. However, she made no enquiries about it and she did not read the details related to her participation in the Program. She signed the Loan Application and the power of attorney without reading their terms.

[64]? ? ? I noted earlier that the Appellant stated that she was attracted to the Berkshire Program because it allowed her to make a larger donation than she could otherwise make to support the arts and that the tax savings was a secondary consideration.

[65]? ? ? On a review of the evidence, it is my view that the tax savings were the Appellant?s principal reason for making the Donation.

Analysis

[66]? ? ? Section 118.1 of the Act allows a tax credit for individuals with respect to gifts made to a registered charity and other organizations. That section reads as follows:

118.1(1) In this section,

?total charitable gifts?, of an individual for a taxation year, means the total of all amounts each of which is the fair market value of a gift (other than a gift the fair market value of which is included in the total Crown gifts, the total cultural gifts or the total ecological gifts of the individual for the year) made by the individual in the year or in any of the five preceding taxation years (other than in a year for which a deduction under subsection 110(2) was claimed in computing the individual?s taxable income) to a qualified donee, to the extent that the amount was not included in determining an amount that was deducted under this section in computing the individual?s tax payable under this Part for a preceding taxation year;

[67]? ? ? In Mar?chaux v. The Queen, 2010 FCA 287, the Federal Court of Appeal also dealt with a leveraged-charitable donation program. It agreed with the definition of gift adopted by the trial judge, Woods J., from The Queen v. Friedberg, 92 DTC 6031 (FCA) at 6032. It stated that for the purposes of section 118.1:

?a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor

[68]? ? ? The Federal Court of Appeal also agreed with Woods J. that Mr. Mar?chaux did not make a ?gift? within the meaning of section 118.1 of the Act because he made the payment to the foundation expecting to receive a ?significant benefit? in return. That benefit was an interest-free loan from a lender.

[69]? ? ? In the present case, Ms. Kossow?s Donations to Ideas were not separate from the financing she received from Talisker. Her Donations were conditional on her Loan Applications for interest-free loans being accepted. I conclude that, as in Mar?chaux, Ms. Kossow did not make a gift within the meaning of section 118.1 of the Act. The 25 year interest-free loans were ?significant benefits? which she received in return for making her Donations. The Appellant was able to transfer $50,000, $60,000 and $50,000 to Ideas by using only $17,000, $20,400 and $17,000 of her own money in 2000, 2001 and 2002 respectively. She accomplished this without having to pay interest on a commercial loan for the difference.

[70]? ? ? The appellant in Mar?chaux received a second benefit from a ?put option?. However, it is not necessary that there be two benefits to vitiate a gift. That a benefit flowed to Ms. Kossow in return for her Donation is sufficient to demonstrate that her Donation did not constitute a gift. The comments made by Woods J. in Mar?chaux v. The Queen, 2009 TCC 587 are applicable:

35 I would also comment that, even without the Put Option, the financing provided a significant benefit. It is self-evident that an interest-free loan for 20 years provides a considerable economic benefit to the debtor.

[71]? ? ? Counsel for Ms. Kossow argued that a gift is only vitiated where there is evidence of consideration from the donee to the donor. In support of her position, counsel relied on the recent decision of the Ontario Court of Appeal in McNamee v. McNamee, 2011 ONCA 533 where the court stated:

31. It is helpful to remember that the issue is not whether the donor (or, for that matter, the donee) received some benefit from the estate freeze (Mr. McNamee Sr. accomplished his corporate planning; the boys received their common shares). The issue is whether the donee has provided any consideration to the donor for the transfer of the shares. For the reasons outlined above, the appellant provided no consideration in that regard. The fact that Mr. McNamee Sr. accomplished his corporate planning goals - including capping his value in the company at $2 million, with the right to draw out more if he wished; protection from creditors; and relief from possible tax consequences on his death - do not amount to consideration flowing from the appellant to him. Nor, we would add, did the appellant?s continued employment with McNamee Concrete constitute consideration for the transfer of the shares in the circumstances. The appellant receives a good salary for his services as an employee of the enterprise, and the father?s vague hope that his sons would continue with the company does not constitute consideration flowing from the boys. The shares were not transferred in order to ensure the sons? continued involvement in the company; they were transferred to give effect to the estate freeze plan. Motive underlying a donor?s conduct is not the same thing as consideration flowing from the donee. (emphasis added)

[72]? ? ? It is my view that the Appellant has taken the statement of the Ontario Court of Appeal out of context and she has misinterpreted its scope. The statement in McNamee was made in the context of a Family Law matter where there was a disagreement whether shares received by the husband from his father were part of the matrimonial property. The question revolved around whether the shares had been gifted to the husband by his father.

[73]? ? ? Further, the statement made in McNamee was not intended to be one of general application. It has to be read in the context of the facts in that particular case. The Ontario Court of Appeal did not impose a restriction on the definition of the word ?gift?. It did not purport to change the definition of gift. It relied on the following definition of ?gift? in making its decision:

24 ? The essential ingredients of a legally valid gift are not in dispute. There must be (1) an intention to make a gift on the part of the donor, without consideration or expectation of remuneration, (2) an acceptance of the gift by the donee, and (3) a sufficient act of delivery or transfer of the property to complete the transaction: Cochrane v. Moore, (1890), 25 Q.B.D. 57 (C.A.), at p. 72-73; Mossman and Flanagan, supra, at p. 441, Bruce Ziff, Principles of Property Law, 5th ed. (Toronto: Carswell, 2010), at p. 157.

[74]? ? ? Counsel also argued that, if I concluded that the Appellant received a benefit in return for the Donation, the Appellant should receive a tax credit for the cash portion of her Donation, $10,000, in 2002.

[75]? ? ? I disagree. As in Mar?chaux, there was ?only one interconnected transaction here?. No part of the Donation was given as a gift without expectation of a return.

[76]? ? ? The appeal is dismissed with costs to the Respondent.

? ? ? Signed at Ottawa, Canada, this 14th day of September 2012.

?V.A. Miller?

V.A. Miller J.

?

Appendix ?A?

Berkshire Program

?

Source: http://www.globalphilanthropy.ca/index.php/blog/comments/kossow_vs._the_queen_-_abusive_charity_gifting_tax_scheme_-tcc_decides_for_/

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rickovertones · ScienceDaily (Sep. 25, 2012)

ScienceDaily (Sep. 25, 2012) ? Patients given high concentrations of inhaled oxygen during and after cancer surgery may be at higher long-term risk of death, according to a report in the October issue of Anesthesia & Analgesia, official journal of the International Anesthesia Research Society (IARS).

Although preliminary, the study by Dr Christian S. Meyhoff of Copenhagen University Hospital and colleagues provides new evidence on possible risks -- in addition to previous data questioning the benefits -- of administering 80 percent oxygen to patients undergoing major surgery.

80 Percent Oxygen Linked to Higher Mortality Two Years after Cancer Surgery

The researchers evaluated long-term follow-up data from the PROXI study -- a randomized clinical trial performed to evaluate the effects of high concentrations of inhaled oxygen on infection rates after surgery. About 1,400 patients undergoing abdominal surgery were randomly assigned to receive either 80 percent or 30 percent oxygen in the perioperative period: during surgery and for two hours afterward.

In contrast to previous results, the original PROXI study found no difference in the risk of surgical wound infections. There was also a trend toward an increased short-term risk of death with 80 percent oxygen: 4.4 percent, compared to 2.9 percent in patients receiving standard treatment with 30 percent oxygen.

The increase in mortality was not statistically significant. However, it was enough to prompt a follow-up study to determine whether there was any real increase in the risk of death among patients receiving high concentrations of inhaled oxygen -- not only in the short term, but also in the subsequent months and years.

At one to three years after surgery, there were more deaths in the high-oxygen group. The long-term mortality rate was 23.2 percent for patients assigned to 80 percent oxygen, compared to 18.3 percent in the 30 percent oxygen group.

After adjustment for other factors, the difference was significant only for patients undergoing cancer surgery. In this group, the use of 80 percent oxygen was associated with a 45 percent increase in the risk of death. For patients undergoing other types of abdominal surgery, there was no difference in mortality between groups.

The long-term difference in mortality was surprising, because it appeared unrelated to any immediate harmful effects of 80 percent oxygen. (Breathing high concentrations of oxygen can cause harmful effects on the lungs in some cases.) The authors speculate on some possible mechanisms by which high oxygen concentrations could specifically affect the behavior of cancers, potentially increasing the risk of recurrence.

Dr Meyhoff and coauthors emphasize the preliminary nature of their findings -- the study was not designed to detect a difference in long-term mortality risk between 80 percent and 30 percent oxygen. They write, "Further studies are required before an association between perioperative hyperoxia and long-term mortality is established beyond reasonable doubt."

In the meantime, the findings add concerns over long-term mortality to the original PROXI results showing no reduction in infections among patients assigned to high concentrations of inhaled oxygen. The researchers conclude, "Until a clinical benefit of 80 percent perioperative oxygen is well-documented, we recommend abstaining from administering [oxygen concentrations] above what is needed to maintain sufficient arterial oxygen saturation."

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The above story is reprinted from materials provided by International Anesthesia Research Society (IARS), via Newswise.

Note: Materials may be edited for content and length. For further information, please contact the source cited above.

Journal Reference:

Christian S. Meyhoff, Lars N. Jorgensen, J?rn Wetterslev, Karl B. Christensen, Lars S. Rasmussen. Increased Long-Term Mortality After a High Perioperative Inspiratory Oxygen Fraction During Abdominal Surgery. Anesthesia & Analgesia, 2012; 115 (4): 849 DOI: 10.1213/ANE.0b013e3182652a51

Note: If no author is given, the source is cited instead.

Disclaimer: This article is not intended to provide medical advice, diagnosis or treatment. Views expressed here do not necessarily reflect those of ScienceDaily or its staff.

Source: http://feeds.sciencedaily.com/~r/sciencedaily/top_news/~3/9vgRc_2Ra_w/120925114345.htm

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Mark Burns is a Business Development Manager in UCompare Cosmetic Surgery, which is a part of the rapidly expanding UCompare network that provides relevant information and offerings on Cosmetic Surgery from the major cosmetic surgery clinics within that market or sector.

Author: Mark Burns
Article Source: EzineArticles.com
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Related Reading:

Cosmetic Dermatology: Principles and Practice, Second Edition

THE ULTIMATE SOURCEBOOK FOR UNDERSTANDING THE SKIN AND ITS APPEARANCE

?A concise, well-written, and well-illustrated overview of the topic of cosmetic dermatology that will prove useful to all physicians who care for cosmetic patients.??Archives of Facial Plastic Surgery, reviewing the first edition

Cosmetic Dermatology offers complete coverage of the latest, most effective skin care agents and procedures. Spanning the entire spectrum of cosmetic dermatology, it takes you through the most current medications, cosmeceuticals, and procedures. Presented in full color, the book is firmly grounded in an evidence-based, clinically-relevant approach--making it perfect for use in everyday practice.

FEATURES:

Guidance on the efficacy of over-the-counter and prescription skin care products
Step-by-step review of must-know procedures
A focus on the newest drugs and topical agents
NEW! Expanded insights into laser treatments, varicose veins, and cosmeceuticals
NEW! More full-color clinical images in every chapter? 450 in all!
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Surgery Junkies: Wellness and Pathology in Cosmetic Culture"Surgery Junkies is an innovative, fast-paced mix of theory and empirical research that advances our understanding of contemporary bodies, lifestyle medicine, and the making of the embodied, self-fashioned self. Scholars and teachers of cultural and media studies, sociology of the body, and health and society will value its contributions to both their research and their teaching."-Arthur W. Frank, author of The Wounded Storyteller: Body, Illness, and Ethics and The Renewal of Generosity: Illness, Medicine, and How to Live "Whether analyzing Extreme Makeover, 'Body Dismorphic Disorder,' or her own rhinoplasty, Pitts-Taylor makes difficult theoretical concepts clear-and clearly relevant to our lives."-Susan Bordo, author of Unbearable Weight: Feminism, Western Culture, and the Body Despite the increasing prevalence of cosmetic surgery, there are still those who identify individuals who opt for bodily modifications as dupes of beauty culture, as being in conflict with feminist ideals, or as having some form of psychological weakness. In this ground-breaking book, Victoria Pitts-Taylor examines why we consider some cosmetic surgeries to be acceptable or even beneficial and others to be unacceptable and possibly harmful. Drawing on years of research, in-depth interviews with surgeons and psychiatrists, analysis of newspaper articles, legal documents, and television shows, and her own personal experience with cosmetic surgery, Pitts-Taylor brings new perspectives to the promotion of "extreme" makeovers on television, the medicalization of "surgery addiction," the moral and political interrogation that many patients face, and feminist debates on the topic. Pitts-Taylor makes a compelling argument that the experience, meanings, and motivations for cosmetic surgery are highly social and, in doing so, provides a much needed "makeover" of our cultural understanding of cosmetic surgery. Victoria Pitts-Taylor is associate professor of sociology at Queens College and the Graduate Center, City University of New York. She is the author of In the Flesh: The Cultural Politics of Body Modification.

Source: http://www.jackiesbazaar.com/womensinterests/cosmetic-surgery/effectiveness-need-of-cosmetic-surgery-procedures-and-clinics-in-todays-environment-34

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2012: Brian Laird '89, Drew Hardyk, Steve Brown, Bill Malchano (-5) The Elks Club Course

2011: Paul Mundy '86, John Gondak, Clark Haley '85, Steve Shisler '86 (-8*) The Elks Club Course

2010: Nick K. '85, Drew Hardyk, Bradd DelMuto '01, Andrew Jenkins '00(-5) The Elks Club Course

2009: Brian Boyer '80, Jim Clelland '80, Gary Black '82 '84 '86, Paul Mundy '85 (-6) The Elks Club Course

2008: Clark Haley '85, Steve Balkey '88, Mike McCahill '83, Brian Laird '89/ Bill Whittaker '73(-6) The Elks Club Course

2007: Beth (Stever) Shisler '86, Harry Smith '84, Gary Black '82 '84 '86, Clark Haley '85 (-3) The Elks Club Course

2006: David Baskwill '81, Don Ziter '81, Zeb Stewart '83, Robert Gifford '89 (-5) Penn State White Course

2005: Don Ziter '81, Paul Mundy '85, Rob Boulware '86, Robert Gifford '89 (-5) Penn State White Course

2004: Mike McCahill '83, Rick Kanuck, Doug Scharsu, Clark Haley '85 (-5) Penn State White Course

2003: Harry Smith '84, Steve Balkey '88, Chris Herr '85, Tom Rapp '81 (-2) Penn State White Course

2002: Robert Gifford '89, Brian Laird '89, Clark Haley '85 (-3) Penn State Blue Course

*Multiple names engraved on the cup*

Source: http://psutafalumnigolf.blogspot.com/2012/09/the-top-of-podium-two-weeks-in-row.html

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FRESHLY MINTED?WOODROW WILSON SCHOOL?DEAN?CECILIA ROUSE?WANTS MORE LUNCH OPTIONS, HAS A SUPREME MIDDLE NAME, SAYS HARVARD IS FUN

Name: ?Cecilia Elena Rouse
Hometown: Del Mar, CA

What did you do this summer?
I spent a good part of the summer with my family in France, Switzerland, and Prague.? We took a long overdue vacation.

What do you think are the most pressing policy issues, domestic and international, that we need to work on?
I believe that ensuring public institutions (of all kinds) are structured adequately for our changing population and the increasingly global economy is key, especially as we continue recovering from the Great Recession.? I?m thinking of not only of reform of our entitlement programs and provision of education and health care, but also of the various policies in place that affect the business environment.

Who?s your favorite Princetonian, living or dead, real or fictional?
There are too many wonderful Princetonians to choose from.

What?s the best meal you?ve eaten in Princeton?
My husband?s chicken with black beans and rice.

In one sentence, what do you actually do all day?
At the moment, as dean I?m spending a lot of time listening.

What is your greatest guilty pleasure?
Watching bad movies.

What is the one thing you want to change the most about Princeton/WWS?
More places to go for lunch and dinner.

What?s your personal anthem?
Practice makes easier.

What?s your favorite family activity??
Playing board games or card games.

Any course recommendations??
Everyone should take a good class in introductory economics.

What?s hanging above your desk and/or bed??
Hanging next to my bed is a picture of my husband with our children.

What?s the most dangerous thing you?ve done in the past year?
Careening down a mountain in Provence on a narrow (one lane) road in an underpowered car, not having a clue where we were headed.

Last book you managed to read for pleasure??
Walter Isaacson?s biography of Steve Jobs.

Favorite Olympic sport?
Hard to pick ? perhaps Track and Field.

Harvard, Princeton, and the White House: which is the most stressful? Most fun?
The White House was the most stressful; Harvard the most fun ? but I suspect that?s correlated with my stage in life!

Do you know all the words to Old Nassau?
Sadly, no.

What is your biggest fear?
Driving off a bridge in a car with my children in the back seat ? ugh!

What?s your drink?
A double cappuccino ? and sparkling water.

Who is your mortal enemy?
Pestilence?? War?

Where do you do your best thinking?
In my home office ? in the middle of the night.

What makes someone a Princetonian? ?
A love of Princeton.

Source: http://www.universitypressclub.com/archive/2012/09/21-questions-with-dean-cecilia-rouse/

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Imagine, for a minute, you pull into a gas station near your workplace in the morning with your gas warning light on and a long drive ahead of you after work. You drive toward the pumps hoping to fill up, but every one of them is occupied ? and the drivers of all the other cars have wandered off to chat or buy something in the convenience store, so that every hose is in use.

Except that some of the cars? tanks have filled up since they sauntered away.

Now, imagine that this isn?t a momentary situation but that the other drivers will not return for hours.

Do you:

(a) Resign yourself to not doing the drive after work?
(b) Go in search of the other drivers and ask to use their hoses?
(c) Take a hose out of someone else?s gas tank and put it in your own?

Welcome to the brave new world of electric car ownership, which can often mean encountering such a dilemma in places like Sacramento?s city hall parking garage, where the single row of charging spaces is nearly always full on weekdays ? mostly with electric cars, but sometimes with what the electricati are calling ?I.C.E.?s? (for internal combustion engines).

Indeed, an academic paper has already been prepared on the subject by Nicolette Caperello and Kenneth S. Kurani, researchers at the University of California, Davis.

They and her colleagues did more than 20 in-depth interviews with drivers of electric vehicles, asking questions like whether a person using a retailer?s charging space has an obligation to shop there, or how co-workers at a company that provides a charging facility handle the issue of freeing up plugs.

In the latter case, the paper said, one company?s employees worked out their own system.

The P.E.V. [plug-in electric vehicle] drivers created a system of rules for charging. The primary rule seems to be ?first come, first serve,? but this is subject to several conditions. They have created rules and processes to handle exceptions, e.g., someone needs to charge to get somewhere else during the day. In these instances, the person wanting to charge their car sends an e-mail to a listserv of P.E.V. drivers to see if someone who is parked at or connected to a Level 1 outlet or Level 2 charger can make it available. These requests are generally granted.

Electronic media makes communications easier, one interviewee said.

Drivers have developed a Wiki?a Web site that allows anyone to revise content using only a Web browser ? to communicate with each other.?it?s a Wiki so anyone can edit it?generally it [has] questions about when spots are available and people talk about the [charger] software, what to expect as a new driver, vacating a spot, plug in whoever is on deck, it?s all a little community.?

Sandra Berg, a member of the California Air Resources Board, brought up the issue at a board hearing on Thursday, reporting that when there is a space for her Nissan Leaf but no plug, she will choose option (c) if the other car?s battery is full.

She said she then leaves a note on the other car?s windshield saying, ?I noticed you were fully charged and I needed a charge to get to my destination and so I unplugged your car. I wanted you to know why your charger was unattached.? She signs the note and gives her e-mail address, she added.

So far, no one has e-mailed her to bless her action or denounce it. But, based on an informal survey she has taken of other drivers at places like the Sacramento parking lot or the lots at Los Angeles International Airport, she estimated that about six out of 10 drivers say ?Fine? and the other four say ?Don?t touch my car!?

When there are no spaces and no available plugs, she said, she takes her car to the nearest Nissan dealership and leaves it there to charge.

According to a report released last month by California?s Plug-In Electric Vehicle Collaborative, an estimated 35,000 electric vehicles have been sold nationwide, half of them in California. And NRG, a company that inherited the debts of Dynegy in California, has agreed to build $100 million worth of electric-car infrastructure as recompense related to a lawsuit in which the state claimed that Dynegy overcharged it in a power contract.

As part of the agreement ? which is now being challenged by other companies that build electric-car infrastructure ? NRG pledged to build hundreds of fast-charging stations in the San Francisco Bay Area, the Los Angeles area and the Central Valley and at least 10,000 individual charging stations like the ones now being filled up in the Sacramento parking garage.

But as long as electric vehicles have small driving ranges and parking areas have limited charging offers, the whose-plug-is-it problem is likely to get worse, not better.

Source: http://green.blogs.nytimes.com/2012/09/21/the-etiquette-of-electric-car-ownership/?partner=rss&emc=rss

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rickovertones

In the last Pinterest marketing blog post, we began discussing how you can attract more Pinterest followers to maximize your marketing efforts. Using the ?Follow Me? button, connecting with other social media sites, following others and inviting friends are a few of the simpler methods for building a list of followers. To help you attract even more followers, here are more top secrets to begin using immediately. They?ll enable you to attract followers while boosting the success of your Pinterest marketing campaign.

Secret #5 ? Use the Comment and Like Features

Pinterest allows you to comment on the pins of other users. A like feature is also available. One of the best ways to build your list of Pinterest followers is to start interacting with other users, which can be done by using the comment and like features. Keeping active in the community is essential and using the comment and like features allow you to engage other users.

As you engage with others, they?ll be more likely to begin following your account. Adding comments to pins from popular accounts also brings you exposure, which may bring more visitors to your account. Just make sure that comments are relevant to the pin for the best results.

Secret #6 ? Post Engaging Content

Posting engaging content is another Pinterest marketing secret that can help you attract more followers. While this may seem obvious, bringing in new followers will require you to pay more attention to the details when posting new content.

First, make sure your content is visually attractive. Pinterest is all about images, so content posted should grab the attention of viewers. Low quality images will not provide you with good results. People want to see quality, eye-catching images.

You should also work to post your own content. While repinning the content of others is fine, some of your pins should be original. Pinterest users enjoy seeing great repins, but they love seeing new content too.

Secret #7 ? Post on a Regular Basis

Another top secret to attracting Pinterest followers is to post on a regular basis. Most users don?t want to follow others who have old, stale boards. Users want to follow people who are adding new content on a regular basis. Posting regularly will let other users know that you are active, making them more likely to follow you.

Of course, you want to avoid going overboard as well. Spamming users with pins relating to your products or services is a big mistake. Pin too much and the followers you have will get bored or frustrated and then will stop following you. Post regularly but avoid looking like a spammer.

Secret #8 ? Make Boards and Pins Easily Searchable

Pinterest offers a search feature, allowing users to search through pins and boards by keywords. Since many users use the search feature, it?s important to make sure that your boards and pins are easily searchable.

Users searching for specific content may find your pins or boards and choose to follow you. However, they won?t be able to find you if you don?t focus on making your boards and pins searchable. Adding relevant keywords to pin descriptions makes pins easy to search. Using board names that include keywords will ensure your boards are easy to find.

Building a good list of Pinterest followers is an essential step in your Pinterest marketing campaign. Begin using these tips to attract more followers to your account, which will help boost your marketing success.

Make sure you check back for our next Pinterest marketing blog. We?ll be discussing important search engine optimization tips for Pinterest and it?s packed with great information and tips that you can?t afford to miss!

Source: http://needanarticle.com/index2/pinterest-marketing-top-secrets-attracting-pinterest-followers-part-2/

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rickovertones

Victory Christian Center is shown on Wednesday, Sept. 19, 2012 in Tulsa, Okla. Five employees at the center face criminal charges for waiting more than two weeks to report the alleged rape of a 13-year-old girl on the south Tulsa campus. (AP Photo/Justin Juozapavicius)

This handout photo provided by the Tulsa County Sheriff's Office shows Chris Denman. Denman was arrested Sept. 5 for allegedly raping a 13-year-old girl at Victory Christian Center in Tulsa, Okla. Five ministry employees of the megachurch have been charged by authorities for waiting two weeks before reporting to police the alleged rape. Police say the girl is among at least three victims of alleged sex crimes by two former church employees. (AP Photo/Tulsa County Sheriff's Office)

Victory Christian Center is shown on Wednesday, Sept. 19, 2012 in Tulsa, Okla. Five employees at the center face criminal charges for waiting more than two weeks to report the alleged rape of a 13-year-old girl on the south Tulsa campus. (AP Photo/Justin Juozapavicius)

This handout photo provided by the Tulsa County Sheriff's Office shows Israel Shalom Castillo. Castillo was arrested Thursday morning after turning himself in at the Tulsa, Okla. jail. He is charged with making a lewd proposal to a child and using a computer to commit a sex crime. Five ministry employees of Victory Christian Center, in Tulsa, Okla. have been charged by authorities for waiting two weeks before reporting to police the alleged rape of the 13-year-old. Police say the girl is among at least three victims of alleged sex crimes by two former church employees. (AP Photo/Tulsa County Sheriff's Office)

TULSA, Okla. (AP) ? A 17,000-member megachurch deep in Oklahoma's Bible Belt has been rattled by allegations that five employees waited two weeks to report the rape of a 13-year-old girl in a campus stairwell, allegedly by a church worker.

Tulsa police say the girl is among at least three victims of alleged sex crimes by two former employees of Victory Christian Center who face criminal charges. A child crimes investigator says more victims could surface as police continue to investigate.

Authorities, however, fear some parishioners in the large, tight-knit south Tulsa congregation may choose to pray about the allegations rather than provide concrete evidence.

Police said this week that the worldwide ministry's pastor and co-founder, Sharon Daugherty, whose daily broadcasts are beamed via satellite to more than 200 countries, knew about the abuse allegations, but trusted ministry employees to follow in-house policies on reporting such incidents.

Former church employee Chris Denman, 20, was arrested Sept. 5 for allegedly raping a 13-year-old girl in a stairwell before a church service on Aug. 13. He also is charged with molesting a 15-year-old girl sometime between Aug. 13 and Aug. 17. He has pleaded not guilty and faces an Oct. 11 preliminary hearing, court records show.

Another ex-employee, 23-year-old Israel Shalom Castillo was arrested Thursday morning after turning himself in at the Tulsa jail. He is charged with making a lewd proposal to a child and using a computer to commit a sex crime.

Prosecutors this week also charged five church employees ? including Daugherty's son and daughter-in-law, who are both youth pastors ? for failing to report the alleged assault between Aug. 15 and Aug. 30. John Daugherty, Charica Daugherty, Paul Willemstein, Anna George and Harold "Frank" Sullivan each face one misdemeanor count of failing to report child abuse and are due to be arraigned Wednesday in Tulsa County District Court.

Tulsa attorney Jason Robertson, who is representing the five employees, did not return a phone message seeking comment Thursday afternoon. An assistant in his firm indicated he was out of town.

The ministry ? founded in 1981 by Sharon and the late Billy Joe Daugherty and shaped in a similar mold to Tulsa televangelist Oral Roberts' charismatic Christian ministries ? issued statements this week accepting responsibility for the lapse in reporting. A request to interview Daugherty was declined by a public relations firm hired by Victory Christian Center.

In a statement to The Associated Press issued Wednesday, the church said its employees failed to follow a written policy requiring any allegation of abuse to be reported by employees to the state's Department of Human Services, and internally within one hour to their department head and the director of human resources.

The church explained that staff in the ministry's youth department learned of the allegations and spent about a week checking it out before reporting it to supervisors and human resources. Once the complaint reached HR, "that department did not follow its own reporting policy," the ministry admitted in the statement.

It was unclear from the ministry statement which of the allegations the youth department checked into on its own.

Sullivan, the HR director, fired the two men Aug. 24, and then left a message with a member of the church who works with an anti-child trafficking organization to seek advice on whom to contact. Sullivan was advised to call police on Aug. 27. The ministry said Sullivan exchanged voicemails with an officer until Aug. 30, when they finally connected and the officer told Sullivan to dial 911, which he did that day.

"We deeply regret that our employees did not report these incidents to authorities within the proper amount of time. This failure within our organization weighs heavily on us, because our purpose is to help people and minister to their needs," the church said in the statement to AP. "Our internal response was unacceptable, and we are taking the proper steps to correct it."

The five employees charged with failure to report abuse have been suspended by the ministry while it decides disciplinary action, the organization said.

Police Det. Cpl. Greg Smith, who works in the child crisis unit, said the ministry has fully cooperated with investigators since the alleged abuse was reported.

"There was a couple of weeks in which they were either unsure of what to do or didn't do it, or who knows what," he said. "There was a couple weeks where we probably lost some evidence."

Smith said police are pursuing cases involving at least two more victims and another suspect. In one of the cases, police have failed to connect with the accuser. In the other, the victim's parents are not cooperating, Smith said,

"They made a comment that the church is handling the situation and they're going to continue to pray about it," Smith said Thursday. "We're still hoping to convince them to go forward with it."

Associated Press

Source: http://hosted2.ap.org/APDEFAULT/3d281c11a96b4ad082fe88aa0db04305/Article_2012-09-20-Oklahoma%20Church-Unreported%20Rape/id-42441910aa734950904e4e2709d341a3

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rickovertones

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