Ethics Final

Humans decided to start categorizing, and grouping humans based on various things. Research shows that man is of but one kind, and not like an animal of several species (Schaefer, R, T. (2006).. Humans have assumed that because people with different skin color, different cultural beliefs, or different ways of thinking that they must be of a different biological race (Schaefer, R, T. (2006). Society has created everything from what foods to eat, what music to listen to, to what they teach their children and true generations about acceptance of each other and passing on racial beliefs.Politicians and people of wealth have been notorious for labeling groups and racial profiling to get the higher up so to speak, or to create justification in the community. Race began simply a categorization of physical biological characteristics such as hair type, shape of the eyes and nose, and skin color (Schaefer, R, T. (2006). White was white, and black was black; then came the categorizing of additi onal attributes such as afro-textured hair and large noses on African Americans, or olive skin, slanted yes, and shiny Jet black hair in Asians.Biologically speaking there is nothing as simple as black and white. For many, many years people have relocated or traveled all over the world and mingled and procreated with other races which has now mixed traits, and been passed down generation after generation. It seems virtually Impossible to truly Identify a person's race, because I find It hard to believe there would be any â€Å"purebreds† during this day and age. 2. How has the media contributed to prejudice and discrimination against Asian Americans? How might these problems be remedied?The media has contributed to the prejudice and discrimination against Asian American in several ways that demonstrate insensitivity and biased reporting. According to our textbook, the media has had a negative Impact on the views of Aslant Americans by using Inappropriate clicks, mistaken Iden tity, personalization, using ethnic slurs, biased and inflammatory reporting, bashing their native Japan, media Invisibility, and even model minority which sets the positive standards of Aslant Americans too high (Schaefer, R, T. (2006).Stereotyping them as a â€Å"model minority† creases tenet chances AT acceptance when It comes to social programs, employment, and other social ills (Schaefer, R, T. (2006). Asian Americans are often times viewed as well-educated and successful. Little does society notice that these Asian Americans do not normally hold high corporate positions, rather they are running their small own business and employ their family, taking care of one another as best they can. The media and even entertainment honchos never embrace Asian Americans as athletes or potential celebrities with mainstream roles. AsianAmericans are never heard and asked for their input when the media is addressing problems in their community, as well when it comes to issues regarding Asia (Schaefer, R, T. (2006). These problems of negative portrayal against Asian Americans held by the media can be remedied by first of all overcoming the idea that they are a â€Å"model minority' and realize that they work hard, love their families, sought the United States to live the â€Å"American Dream† and try to escape poverty. The media can choose their words wisely refraining from any slur words or phrases such as â€Å"Asian Invasion† or â€Å"OrientExpress†. The media should also express the increased population in areas of heavy Asian descent I also believe the media should tell or write stories of influence such as Asian Americans striving in America, working 7 days a week to make ends meet. I think the media should exploit the poverty side of the Asian American community to help decrease the model minority views so they may be eligible for more minority programs. References Schaefer, R, T. (2006). Racial and ethnic groups (10th deed. ). Upper S addle River, NJ: Pearson Prentice Hall.

Pressures students face Essay

Imagine sitting in a classroom full of college students. They are from all walks of life. What could possibly be going on in the heads of those students? For instance could it be about the girl or boy that they have a crush on? Maybe they are wondering what they will do after school today? No, most of these students are working jobs to pay bills and tuition for the college they are attending. Also trying to maintain a good grade average which has to be a C or higher. These are some of the pressures that most college students have to face in this time of their lives. First, the pressures to perform academically are one of the primary causes of stress for all students. Most colleges recommend that students maintain a 2. 0 GPA and a C average or better in order to keep the finical aide they received and to pass their semesters. First, coursework can be very demanding. For instance students who want to do their best and excel in school will want to make the top grades and struggle to get into graduate schools places a lot of pressure on them. If a student falls below a C average they will not pass the semester that they are taking and will lose what finical aide that was acquired for them to attend college. So keeping good grades is the main pressure they have to face besides having to pay to go to college. In addition to paying for college is another pressure that a college student has to face every year Students have to make sure there are enough funds for books, classes, supplies, and if so rooms. Many students face financial stresses. Students have to find enough money to pay for their tuition as well as getting enough funds to cover living expenses and traveling expenses back and forth while attending college. Furthermore students that have sufficient funds to pay for college still have to worry about repaying the loans that they have gotten before even graduating from college and joining the work force. Finally, being a full time student and working a full time job can be overwhelming for college students. Taking full time classes and juggling a job puts a lot of pressure on students and leaves little time for them to study and attend classes. Friedrich Nietzsche once quoted That which does not kill us makes us stronger. Meaning that if students can juggle jobs and college that will only make them stronger and better at what they do. Therefore, college students face pressures by trying to work, making sure they maintain good grades and having enough tuition to pay for the college. Students have to face so many pressures going to college this is only a few of them. Being a full time student and working is not an easy job but people who want to get anywhere in their lives have to better their education so they can get better job opportunities. Many students with a lot of pressures just want to give up and quit at times. But as Winston Churchill once quoted Never, never, never give up. They just need to keep trying and no matter what once they graduate and have degree in their hands it will be well worth the pressures they had to endure during college.

Ap Human Geography Green Revolution

For the greater half of the 20th century and the start of the 21st century, The Green Revolution has taken off as the mission to end world hunger. It proves that humans have the power to â€Å"engineer crops† and change the way they grow and how sustainable they are. It alters the concept of agriculture as a whole. The Green Revolution is the future. Executed correctly, and it might be the solution to our food supply problems. Using safe modifications and pursuing further ventures in research is one way we can continue on the path of the Green Revolution. Also, implementing and refining concepts that we know have worked in the past can allow for advancements and more prominent results. In many countries, due to scarcity of land, farmers practice double cropping. This allows for two crop seasons a year. The only problem with this is that there would have to be two monsoons, on natural and the other â€Å"artificial. † India, which has found more efficient sources of food after their infamous Bengal Famine, has been one of the first countries to take an initiative in the green revolution. By using genetics to create HYVs, or High Yield Value seeds, they have been able to claim foreign acclaim and produce crops with increased viability. Agriculture is the largest employing industry in the world. The Green Revolution will keep that number high because of the amount of lateral facilities and resource plants that are affiliated with agriculture. Despite limits, such as falling short of demands and global implementation, the Revolution has shown tremendous results that show high prospects for the road ahead.

A perfect job for a finance major Essay Example | Topics and Well Written Essays - 250 words

A perfect job for a finance major - Essay Example Since these activities are much needed in the current business society, the need of financial planner remains the high in all seasons. In addition, the job pays off even during the recession or financial crisis because financial planners are much needed for getting out the state of turmoil. The tasks that are expected from a financial planner begin from procedural classification of finance over the year. A strategy is designed in order to make sure that financial assets are providing enough profit that consumption rate is settled. A financial planner needs keep updated about information flow so that the concerned authorities are able to make expected moves. The situation of the finances should be effectively communicated to the client by a financial planner. The demand of financial planner is very high in different regions of the world, especially, in Australia, Canada and Europe. Since the need of financial planner remains high, the compensation is also high round the year providing more and more chances for financial planners to experience growth

Strategic Management Essay Example | Topics and Well Written Essays - 2000 words - 28

Strategic Management - Essay Example In future, Intel needs to acquire the knowhow of building similar chips. The brand awareness of the firm is high in the industry; and with such strategic changes, Intel would be able to rule out competition of ARM Holdings. The case study examines the strategic management operations of Intel. From 2012 to 2013, the industry has experienced an excellent rate of turnover, which is as high as 4.8%. This industry is dominated by certain giant corporations like, Intel, Samsung and Broadcom. This examination will be done by studying the business environment where the company operates, along with its current business strategies on basis of the case study. Finally, the report will analyze ways through which Intel would be able to sustain competitive advantage in the industry as it has been noticed that companies like, ARM Holdings, are encroaching on large proportion of assured market demand of Intel. The forecasts regarding business of the semiconductor industry are made by the World Semiconductors Trade Statistics Organization (WSTS). Hence the firms in the industry are highly conscious about the reports published by this agency, as it influences their brand images in the market. The royalties and licenses of new technological developments are provided to the firms of semiconductor industry in each nation by public governing authorities. Hence the firm’s operational freedoms are highly manipulated and controlled by the public authorities. The companies within the industry experience high degree of competition among them. Perhaps this is the reason for which the firms like Intel and ARM are found to invest large amount of money for product and process development procedures in business. The degree of communicational integration has enhanced with rise in use of internet. This has spurred demand for technological smart gadgets

Case Study Essay Example | Topics and Well Written Essays - 1500 words - 6

Case Study - Essay Example Having discussed the requirements of the document, the other team members John and Theresa decided to leave the task of writing the document to be done by Laura alone. In the meeting it seems John is frustrated by the document that has been done by Laura and after some discussions, they agreed on certain amendments to be made on the document. Having done that, they still delegated Laura to work on the amendments on her own. Given this situation, it can be seen that there is no proper willingness to work together as a team where all the members would pull their contributions together towards the attainment of one goal. In an organisation, workers ought to contribute their ideas as well as resources together so as to attain the organisational goal. In this case, it is the responsibility of the team to work together in designing the document on behalf of the client but it seems they are neglecting the task but indeed leaving it to be done by only one person who is a junior in the organisation for that matter. At the end of the day, it is the organisation’s responsibility to make sure that they give the client a satisfactory order since it will suffer the consequences of being discredited by clients in the event that they fail to provide a standard document to the client. It is not Laura who will be blamed but the organisation as a whole. The way they even conduct their meetings show that there is lack of proper cooperation to a certain extent. The last meeting is characterised by jokes and the way John leaves the meeting inexcusably shows that he is not very considerate about what is taking place. It can be seen from the given case study that there is an element of insubordination where the juniors are expected to do much of the tasks within an organisation. Other team members feel that they are not supposed to be doing that task but it is their responsibility together as a team.

Characteristics of unplanned economies Essay Example | Topics and Well Written Essays - 250 words

Characteristics of unplanned economies - Essay Example Market/unplanned economy and command/planned economies occupy the two polar extremes in the economic activity organization. The main difference is found in mechanisms used to determine prices and labor division or production factors. The market economy activity is unplanned, that is, it has no organization from the central authority and gets determined by the goods’ demand and the supply services. On the contrary, the command economy gets organized by the officials of the government who also direct and win the production factors (Meade, 2013). Currently, all modern economies are mostly pragmatic economies. The economies reject the thought function of representing, describing or mirrorring reality, but instead, they consider it as an instrument, action for problem solving. The two views of confrontation of the modern capitalism; state and neoliberal capitalism, will identify the economy of the social market that creates a new future pragmatism. Therefore, pragmatism is an indispensable and fundamental way of a rational economic management (Daniels & VanHoose,

Organizational Behavior Forces Discussion Term Paper

Organizational Behavior Forces Discussion - Term Paper Example Ikon had incurred a loss of $94 million because of restructuring. The resulting effect on the organization was enhancing the communication system that would enable organizational learning and also clarify accountability of results (Abstracts, 2010). Organizational mission- The aim of Great Lakes Landscaping is to provide total satisfaction through its services. The company tries to attain top results from its performance. This mission serves as the driving force behind its organization behavioral activities. This is demonstrated by the company’s focus on the development of a highly trained staff and maximizing the expertise in their respective fields (Great Lakes Landscaping, 2008). Similarly, the mission of capital One Financial Corp is lending the best possible of financial services to its customers. A wide of variety of service has been designed considering this mission. Fiscal Policies- External factors like fiscal policies greatly affect the way companies operate. This is most relevant for companies like Ikon. Fiscal policies would mean injection of money in the economy where individual incomes would also be high. Thus, people would be in a better position to buy luxury items. Thus fiscal policies influence the decision making in organizations. The price strategies are determined by the decision making. ... The rates of interest in the market, the purchasing power of consumers, etc would influence their strategies. During recession, a number of companies were seen to alter their interest rates to lend more support to the consumers. However, during times of prosperity their competitive strategies remain different. Also, during recession, employees are faced with a lot of insecurity and instability. During these times, the management is required to focus on greater security of employees. Employee relations are given greater priority. Economic factors influence the designing of pricing structures of Great Lakes Landscaping in order to remain competitive in the market. The price structure not only determines the competitive position of the company but helps in retaining and maintaining a constant customer base. The company goes out of its way to demonstrate how investments can be minimized and results can be maximized (Great Lakes Landscaping, 2008). Customer demands- Consumer demands would play a major role for a company like Starkey. This is because the product is very demand specific. It is very crucial that the company makes a thorough analysis of the market conditions, like the demand in the market for such products or the population demographics. An ageing population would necessarily mean that there would be a greater demand for hearing aids in the market. It also holds true for a company like Great Lakes Landscape. It would depend on consumer awareness about the society’s environment. Globalization- globalizations and communication has made the availability of foreign product more easily accessible to consumers in different countries. Goods and services can also now be available at cheap prices. The price of a product produced by Ikon would

Briefly outline the court system in England and Wales, and in Essay

Briefly outline the court system in England and Wales, and in particular the role of the Crown Court - Essay Example The Courts of England and wales are made up of the following different courts namely, the magistrate’s courts, the country courts, the Crown court, the High Court of justice, the Court of Appeal and the Supreme Court which work in line with the European court of Justice and the European Court of Human Rights (Clarissa, 2004). These courts are subdivided in to three main divisions namely the senior courts, the subordinate Courts and the special courts. The senior courts include the Supreme Court, the Court of Appeal, and the Crown Court. The Subordinate courts include the magistrates’ court and the county courts while the special courts and tribunals include the ecclesiastical courts and the coroners’courts. These are smaller specialized courts dealing with various matters. The tribunals in England and Wales include the Employments Tribunal, Employment Appeals Tribunal and the first tier and Upper tribunals. The Employment tribunal and the Employment Appeal Tribunal are established to hear industrial disputes. The First-Tier and Upper tribunals have taken up most of the roles and functions that have traditionally been conducted by various tribunals. Other special courts are the Coroner court and the ecclesiastical courts which date back to over 1000 years ago (Richard, Amanda &Amanda, 2011). The coroner’s courts deal with causes of death for individuals who pass away in suspicious circumstances or in foreign countries. The Ecclesiastical courts are based on the Church of England’s legal system, which is the official state church. The court has jurisdiction over marriage and divorce matters, defamation and testamentary matters. The jurisdiction of the court has however narrowed down to the clergy men of the Church of England. These are subordinate local courts established to hear mainly criminal cases and some civil matters at the first instance. These courts are staffed by

Precis for two articles or write a good topic you think Essay - 2

Precis for two articles or write a good topic you think - Essay Example Even though population size is larger in developing countries and has higher growth rate, the greater threat is still developed countries. Developing countries however contribute to the threat of higher consumption through emigration to developed countries or through efforts for improving living standards and per capita consumption such as in China. China is a fast growing economy. While its current per capita consumption is 11 times lower than the one for developed countries, its large population means that continued increase in its per capita consumption would be a great threat to sustainability. Increase in its per capita consumption to 32 would increase global oil consumption by more than 100 percent and global metal consumption by almost 100 percent (Diamond 1, 2). If India could also join China to the 32-consumption level then the global consumption rate would increase by 300 percent while improvement of consumption in all developing countries would increase global consumption by about 1100 percent. Even though Americans suggest that improved governance and better policies could improve lifestyles in developing countries, these may not be valid solutions because economies may not be able to sustain increased consumption levels. Americans are also critical of countries with increasing consumption rates yet these rates are well below that in America. While developing countries may seek to improve their consumption rates towards equality, resource scarcity is a limitation and developed countries may not be willing to reduce their rates. Some of the factors to high consumption rates are however wasteful and minimizing them can ensure a balance with a level of sustainability. Political goodwill appears the necessary tool to this success (Diamond 2 , 3). Malakoff David authored the article, ‘Be fruitful and multiply?’ that the Conservation Magazine published in December 2009. The author identifies conflicting opinions on global

Critique a Research Study Essay Example for Free

Critique a Research Study Essay The nursing research study I chose at the beginning of the semester was Impact of health literacy and patient trust on glycemic control in an urban USA population. The research article begins with a description of Diabetes, its consequences of the disease process, complications, economic cost, and the public health crisis that is foreseen over the next few decades. Research has shown that improvement of glycosylated hemoglobin concentration (HbA1c) in diabetics can have a significant positive impact on this impending critical condition. The second component of the article evaluates the impact health literacy and patient trust has on controlling and maintaining glycemic control in diabetics. The purpose of this article was to research a â€Å"quantitative study conducted to examine health literacy and patient trust as predictors of glycemic control (Mancuso, 2010)†. I believe the credibility of the research article was trustworthy, based on the research topics evaluated that are known in medicine to be accurate and valid. As a nurse, I am well aware of the impact health literacy and patient trust effect disease process and glycemic control. The research sample size evaluated by the article included one hundred and two participants with diabetes selected from two urban primary care clinics in the United States. Although I believe the sample size could’ve been larger, the final conclusions of health literacy and patient trust showed how important those factors are in influencing glycemic control. According to Polit, the presumed cause is the independent variable, and the presumed effect is the dependent or outcome variable (Polit Beck, 2014, p. 43)†. The Quantitative type of research design used in this study was Non-experimental/Observational study on the effects of health literacy and trust on glycemic control. â€Å"When researchers study the effect of a cause they cannot manipulate, they design correlation studies that examine relationships between variables. Correlation studies can be detected through statistical analysis ((Polit Beck, 2014, p. 159)†. The independent variables consisted of health literacy, patient trust, knowledge of diabetes, performance of self-care activities, and depression. These variables were measured with testing at the beginning of the study that yielded statistical results used to associate between variables. The dependent variable was the Hemoglobin A1c. Often the dependent variable can have multiple causes, which are examined in the article. The study also considered other related factors such as: demographics, socio-economic status, diabetes knowledge, self-care activities, and depression. I would categorize these variables with health literacy and patient trust as independent variables. The variation of factors can have a significant influence on the final outcome of HbA1c. This is the reason that research is essential for diabetes, to determine the influence these factors have on glycemic control. Evidenced-based interventions and approaches to improving glycemic control in the US population will help improve the current health crisis this country is facing, and will continue to face in the decades to come. â€Å"This was a cross-sectional study of patients with diabetes, utilizing several survey instruments and data sources (Mancuso, 2010)†. These 102 participants with diabetes were chosen from two free primary care clinics in the U. S. that met the criteria for the study. Reading comprehension test, scales, and screening through the use of surveys examined the independent variables. Testing for Hemoglobin A1c, a blood test, was conducted every six months to measure glycemic control for research purposes. I believe the design was appropriate because it was particular on the types of participants used for the study and factors that influenced the outcome according to the research article. Regardless of the level of participants, results of the study based its findings on the needs of the diabetic population. One of the strengths I identified early on in the research article was the research design chosen to evaluate glycemic control. The cross-sectional study of patients with diabetes utilized several survey instruments and data sources. The framework of the study helped to assess and predict the relationships between variables. Second, I felt the methods used to gather data was appropriate and beneficial to the research study. The data received was sufficient enough to research and observe. Finally, another strength I identified in the article was its reliability that correlated to Evidenced-Based data that guides clinical practice in nursing today. The final findings of the article support that the data collected and examined would help patient’s outcomes on increasing their glycemic control. Distinct weakness in the research study I identified first was the size of the sample that was chosen. With only one hundred and two participants from two different clinics, I felt that the sample size could have been more effective with larger numbers studied and in more areas of the country. The study also identified the recruited participants were from an uninsured population and identified the groups to have poor glycemic control. I believe the research study should have had a more diverse population of patients that would demonstrate how the US really is. Finally, the research article was evaluating health literacy; I believe that most patients who are illiterate would have been reluctant to participate in the study for fear of judgment and humiliation, thus not portraying the most accurate recruits. Evidenced-Based research is an essential component for the continual evolution of professional nursing practice. Research provides us with a solid foundation to ensure that nursing practice and interventions are based on scientific principles that have been proven to be effective. As professional nurses, we should strive to achieve the best outcomes for our patients. Through nursing research, we can expand our nursing knowledge and development to deliver healthcare based on guided research decision-making. In studying my research article, I believe that the strengths outweighed the weaknesses because the findings did correlate with Evidence-Based practice already known. After critiquing the research article, I support its findings on health literacy and glycemic control; they definitely contribute to Evidence-Based practice that should be implemented in nursing practice. Diabetes is a major health problem in the United States and also a major risk factor for other types of disease processes related to it. Health literacy, the ability to read, comprehend and comply with medical instructions is directly related to improved glycemic control. The research article I have chosen reflect the effects between health literacy and glycemic control in the United States population. Conclusions from the articles emphasize the need to communicate and educate patients effectively with low health literacy. As an emergency room, healthcare teaching plays an important role when discharging patients home with the correct information and education to manage their symptoms and disease processes. This research article applies to my nursing practice by pointing out the need to assess health literacy in-patients sent home or admitted with Diabetes. When we can determine that health literacy impacts glycemic control, we can take measures to help patients maintain their diabetes effectively. By understanding the relationship between education and health care outcomes, nursing can make a significant impact through effectively assessing the needs to provide adequate healthcare teaching. References Mancuso, J. (2010). Impact of health literacy and patient trust on glycemic control in an urban USA population. Nursing Health Sciences, 12(1), 94-104. doi:10. 1111/j. 1442- 2018. 2009. 00506. x Polit, D. F. , Beck, C. T. (2014). Essentials of nursing research: Appraising evidence for nursing practice. Philadelphia, PA: Wolters Kluwer Health /Lippincott Williams Wilkins.

Bob Knowlton Self Concept Essay Example for Free

Bob Knowlton Self Concept Essay Analysis As part of the analysis we examine Bob’s Self-Concept and the following characteristics with regards to complexity, consistency and clarity. Bob’s locus of control is also considered and the impact this had on his relationships at work with his colleagues. Fester’s individualism is also considered. Bob’s Self Concept Bob’s Low Self-Concept Complexity Bob has a low complexity as he perceives his most important identity to be work related – he defined his self-concept by his work. The positive side of Bob’s low complexity enabled him to become a relatively successful, skilled engineering, as he invested more in his skill development and focused his attention on his work. However, the low complexity caused Bob great stress when his main self-concept, defined by his work), was threatened by the arrival of Fester, a much more brilliant, driven engineer. Bob perceived Fester’s arrival as a threat by challenging all aspects of Bob’s self-concept, not only his technical expertise, but also Bob’s leadership of the team when Fester became the informal leader by default as Bob conceded defeat and essentially abandoned his role as group leader. Bob’s Low Self-Concept Consistency Bob’s has a low self-concept consistency. Bob’s leadership style was focused on teamwork and collaboration and he prided himself on motivating his team by including them in group problem solving and decision making. However, this self-concept was inconsistent with how Bob really perceived himself and the disconnect present between his position as team leader and his ability to lead. Bob acknowledged to himself that the team’s collaborative style brought him a sense of security in that he did not actually have to lead the team. Bob focuses on the team to the exclusion of his leadership role essentially using his team to mask his insecurities with respect to his ability to lead. Another example of Bob’s low inconsistent self-concept is his accepting Dr. Jerold’s praising of Fester, when he clearly did not agree. Bob’s Low Self-Concept Clarity Bob has low self-concept clarity; he does not have a clear, confidently defined, stable self-concept. This is apparent early in the case as evidenced by his belief that his â€Å"stumbling upon† a significant breakthrough led to what he considered his â€Å"miraculous† promotion to team leader of the Photon Unit rather than it being based on his skills and abilities. Bob lacks the confidence to deal with Fester, who he perceives as more brilliant and driven. As the case progresses and Fester brings group conflict and openly challenges Bob’s leadership, we see Bob become inconsistent with his behavior. Fester challenges Bob’s collaborative approach with the team and Bob’s lack of confidence meant that he in essence surrendering his leadership by agreeing to re-examine how the team works together and make it about individual updates. Bob’s Locus of Control and Self-Evaluation Given Bob’s behaviors and reaction to Fester, Bob has a low locus of control and is externally motivated. Bob didn’t feel in control of his environment and was unwilling or unable to take steps to control the environment. We have seen that Bob already believes he received the promotion because of external â€Å"miraculous† forces. Although initially, he does feel he has control as team leader, his underlying external focus of control becomes more apparent when Fester is introduced to the group. Fester’s group interactions and individuality presents a new situation for Bob. Bob internalizes the conflict with Fester and openly wonders if he is there to replace him, causing Bob a great deal of stress as he feels he does not have control over the situation. The situation quickly deteriorates as Bob visibility and relevance to the team are diminished and Fester’s increases. Bob’s Self-Concept Conclusion Bob’s low or negative Self-Concept (low complexity, consistency and clarity) greatly influenced Bob’s behaviour and ultimately his decision to resign. Bob’s low self-concept created a great deal of stress and he experienced immense amount of internal-intra personal conflict and tension. Bob’s low Self-Concept meant that Bob could not adapt to what he perceived as threats outside his control. His perceived inadequacies meant that he was not able to face the issues and overwhelming internal conflict he was experiencing. He consistently avoided confronting any of the issues and thus the only action he could take to release himself of this conflict was to resign. Fester’s Individuality and Group Norms Fester is introduced to the group unexpectedly and although initially helps the team solve a problem previously thought to be unsolvable; he goes against established group norms and almost immediately creates conflict. Fester is clearly â€Å"more brilliant† than any of the team members and his individual approach is in direct contrast to the team –based, collaborative approach establish by Bob. He challenges the group norms directly, suggesting the team meetings are a waste of time and is openly dismissive of others. Fester is very confident in his abilities but lacked the social skills to integrate successfully into the group. Although Fester individuality isolated him from the rest of the group, he dominated the leadership of the group to the point of essentially forcing Bob to change the structure of team meetings, from teamwork based to individual updates. This reinforced Fester’s individual approach. Fester’s individuality influenced the group, and particularly his negative influence on Bob grew and went unchallenged, and the conflict it brought ultimately had a negative impact on the Photon team and Simmons. Recommendations 1. Jerrold should meet with Bob and find out the true reasons for Bob’s resignation. Jerrold should ask Bob to return to Simmons by telling him of the plan to increase Bob’s team and offer Bob a substantial raise to return to Simmons. 2. Jerrold should consider undergoing leadership and communication skills training to help him develop the prerequisite skills to manage his teams effectively. 3. Jerrold should become more involved with the teams under his leadership, through developing a clear and compelling direction for the team and ensure his articulates that directly to this team. 4. Jerrold should strive to increase communication and participate in regular team meetings and incorporate individual meetings to ensure his is aware of and understands any issues or concerns. 5. In the future, the team leader (Bob’s replacement) is included in the recruitment and selection of new team members. 6. Dr. Jerold should meet with the Photon team members individually to gain an understanding of how the situation affected the team and get their feedback on what their needs. Team building and intergroup communication skills should then be introduced to ensure team members have the tools to work effectively together.

Practical Applications Of Transformer

Practical Applications Of Transformer Abstract- Generating power is possible in few stations. The power is generated then has to transmit to the various parts of the country. Large power should be transmitted on very high voltage to reduce the amount of copper material and increase the transmission efficiency. Hence the energy generated is transformed twice, thrice, or even four times before utilized. Such transformation of ac from one voltage to another is done by transformer. DISCOVERY The phenomenon of electromagnetic induction was discovered by Michael Faraday and Joseph Henry in 1831. The relationship between electromotive force or voltage and magnetic flux was formalized in an equation now referred to as Faradays law of induction. This law states that whenever there is a relative motion between the coil and magnet emf is induced in the coil. The induced emf lasts so long as magnetic flux linked with the coil changed. The induced emf is directly proportional to the time rate of change of magnetic flux linked with the coil. Where, ÃŽÂ ¦B is the magnetic flux through the circuit. Fig.1: Faradays experiment with induction between coils of wire TRANSFORMER A electric current will flow in the secondary winding and electrical energy will be transferred from the primary circuit through the transformer to the load. Fig.2: Structure of Transformer PRINCIPLE The transformer is based on two principles: firstly, that an electric current can produce a induced magnetic field by varying with time and secondly that a changing magnetic field within a coil of wire induces a voltage across the ends of the coil. Changing the current in the primary coil changes the magnetic flux that is developed. The changing magnetic flux induces a voltage in the secondary coil. The voltage induced across the secondary coil may be calculated from Faradays law of induction, which states that: Where VS is the instantaneous voltage, NS is the number of turns in the secondary coil and ÃŽÂ ¦ equals the magnetic flux through one turn of the coil. If the turns of the coil are oriented perpendicular to the magnetic field lines, the flux is the product of the magnetic flux density B and the area A through which it cuts. The area is constant, being equal to the cross-sectional area of the transformer core, whereas the magnetic field varies with time according to the excitation of the primary. Since the same magnetic flux passes through both the primary and secondary coils in an ideal transformer, the instantaneous voltage across the primary winding equals. Taking the ratio of the two equations for VS and VP gives the basic equation for stepping up or stepping down the voltage. CONSTRUCTION OF TRANSFORMER Steps are: Coil Winding Core Assembly Core-Coil Assembly Tank-up Transformer Tank Painting and Finishing Fig. 3: Transformer showing each part 1. CONSERVATOR: a) Check the oil level in the conservator. If the level is low than the optimum mark indicated on the oil level gauge, it should be topped with proper grade of transformer oil having suitable breakdown voltage value. b) The tightness of the cap/plug of the oil filler pipe, drain plug or drain valve should be checked. The oil level gauge of the conservator should always be kept clean so that the oil level is visible from a short distance. Fig.4: Conservator 2. BUCHHOLZ RELAY: a) the observation glasses should show that the buchholz relay is properly filled with oil. If necessary, bleeding can be done from the two cocks. The drain plug should be tight and no leaking should be there. b) The cover on the connection chamber should be opened to observe whether connections are properly tight. 3. SHUT OFF VALVE: This should always be in fully open position while the transformer is being energized. 4. BREATHER: a) The plug at the end of the breather pipe is to be removed and breather fitted on to the pipe along with the fly nut. b) It is necessary before fitting the breather to observe the color of the silica gel. If necessary, the breather should be opened and the silica gel properly dried up so that its color is perfectly bluish. c) The chamber at the bottom of the breather should be filled in with dry transformer oil up to the level marked. Fig.5: Showing Tank in oil 5. DIAL TYPE THERMOMETER: If it is provided with alarm and trip contacts, these should be set to proper temperature before energizing the transformer. For guidance purposes, it may be mentioned here that a transformer having temperature rise of 45/55 °C, the trip contact should be set at ambient temperature plus 45 °C and the alarm contact will be 5 ° 10 ° prior to this. 6. WINDING TEMPERATURE INDICATOR: This will be set in the same way as the dial type thermometer excepting that the trip contact should be set at ambient temperature plus 55 °C. 7. MARSHALLING BOX: The windows of the marshalling box should always be kept clean so that the readings of the oil temperature indicator and winding temperature indicator can be easily read from outside. Some dehydrating agent may be kept inside the marshalling box so that the box is kept always in dry condition. Do not keep the Dorr of marshalling box open. It must be locked. 8. EXPLOSION VENT: a) In case an equalizer pipe connection is provided, the valve in the pipe should be kept in open position before the transformer is energized. b) If the explosion vent is provided with an air release device, this should be opened once to release any pressure generated inside and then it should be closed. c) The diaphragm of the vent should be intact. 9. BUSHINGS: To prevent sparking bushings are used when wires at low voltage and transformers wire at high voltage are connected. Fig.6: Showing Bushings 10. COOLANT: Fig.7:Coolant High temperatures will damage the winding insulation. Small transformers do not generate significant heat and are cooled by air circulation and radiation of heat. Power transformers rated up to several hundred kVA can be adequately cooled by natural convective air-cooling, sometimes assisted by fans. In larger transformers, part of the design problem is removal of heat. Some power transformers are immersed in transformer oil that both cools and insulates the windings. The oil is a highly refined mineral oil that remains stable at transformer operating temperature. Indoor liquid-filled transformers must use a non-flammable liquid, or must be located in fire resistant rooms. Air-cooled dry transformers are preferred for indoor applications even at capacity ratings where oil-cooled construction would be more economical, because their cost is offset by the reduced building construction cost. TYPES OF TRANSFORMER 1. ON THE BASIS OF TRANSFORMATON RATIO: A) Step-up transformers A step-up transformer allows a device that requires a high voltage power supply to operate from a lower voltage source. The transformer takes in the low voltage at a high current and puts out the high voltage at a low current. Transformers only work with alternating current. Using direct current will create a magnetic field in the core but it will not be a changing magnetic field and so no voltage will be induced in the secondary coil. Using a step up transformer to increase the voltage does not give you something for nothing. As the voltage goes up, the current goes down by the same proportion. The power equation shows that the overall power remains the same. P=V x I Power = Voltage x Current Fig.8: Step up Transformer Electricity is first produced at the power plants. Electricity is then sent to step-up transformers where low-voltage electricity is changed to high voltage to facilitate the transfer of power from the power plant to the customer. Voltage must be increased so that the electric current has the push it needs to efficiently travel long distances. From the step-up transformer, transmission lines carry the high voltage electric current long distances through thick wires mounted on tall towers that keep the transmission lines high above the ground. Insulators made of porcelain or polymers are used to prevent the electricity from leaving the transmission lines. B) Step-down transformers A step-down transformer allows a device that requires a low voltage power supply to operate from a higher voltage. The transformer takes in the high voltage at a low current and puts out a low voltage at a high current. A step down transformer has less turns of wire on the secondary coil, which makes a smaller induced voltage in the secondary coil. It is called a step down transformer because the voltage output is smaller than the voltage input. If the secondary coil has half as many turns of wire then the output voltage will be half the input voltage. Decreasing the voltage does not decrease the power. As the voltage goes down, the current goes up. Fig.9: Step Down Transformer 2. ON THE BASES OF WINDINGS: A) Core type transformer: Fig.10: Core Transformer B) Shell type transformer: Fig.11: Shell type transformer 3. ON THE BASES OF SERVICE: A) Power transformer: Power transformers are used in transmission network for voltage ratings of (440kv, 220kv, 110kv, 66Kv) and are generally rated above 200MVA. Power transformer generally operated at full load. Hence, it is designed such that copper losses are minimum. B) Distribution Transformers: Distribution Transformers are used in (33 kV, 11kv, 6.6 kV) voltage levels in Distribution network and are generally rated less than 200 MVA. A distribution transformer is always online and operated at loads less than full load for most of time. Hence, it is designed such that core losses are minimum. IDEALTRANSFORMER The idealizations are as follows: 1. Magnetic circuit is linear and has infinite permeability. The consequence is that a vanishingly small current is enough to establish the given flux. Hysteresis loss is negligible. As all the flux generated confines itself to the iron, there is no leakage flux. 2. Windings do not have resistance. This means that there are no copper losses, nor there is any ohmic drop in the electric circuit. LOSSES IN TRANSFORMER An ideal transformer would have no energy losses, and would be 100% efficient. In practical transformers energy is dissipated in the windings, core, and surrounding structures. Larger transformers are generally more efficient, and those rated for electricity distribution usually perform better than 98%. All transformers have copper and core losses. 1. Copper loss: Copper loss is power lost in the primary and secondary windings of a transformer due to the ohmic resistance of the windings. Copper loss, in watts. Copper Loss I2P RP+ I2S RS Where IP = primary current IS = secondary current RP = primary winding resistance RS = secondary winding resistance 2. Core loss: A) Hysteresis losses Each time the magnetic field is reversed, a small amount of energy is lost due to hysteresis within the core. For a given core material, the loss is proportional to the frequency, and is a function of the peak flux density to which it is subjected. B) Eddy currents Ferromagnetic materials are also good conductors, and a solid core made from such a material also constitutes a single short-circuited turn throughout its entire length. Eddy currents therefore circulate within the core in a plane normal to the flux, and are responsible for resistive heating of the core material. The eddy current loss is a complex function of the square of supply frequency and inverse square of the material thickness. Mechanical losses In addition to magnetostriction, the alternating magnetic field causes fluctuating electromagnetic forces between the primary and secondary windings. These incite vibrations within nearby metalwork, adding to the buzzing noise, and consuming a small amount of power. Stray losses Leakage inductance is by itself largely lossless, since energy supplied to its magnetic fields is returned to the supply with the next half-cycle. However, any leakage flux that intercepts nearby conductive materials such as the transformers support structure will give rise to eddy currents and be converted to heat. There are also radiative losses due to the oscillating magnetic field, but these are usually small. EFFECIENCY WHAT CAUSE LOSSES 1. Due to the large value for the permeance ( ÃŽÂ ¼r of the order of 1000 as compared to air) the magnetizing current requirement decreases dramatically. This can also be visualized as a dramatic increase in the flux produced for a given value of magnetizing current. 2. The magnetic medium is linear for low values of induction and exhibits saturation type of non-linearity at higher flux densities. 3. The iron also has hysteresis type of non-linearity due to which certain amount of power is lost in the iron (in the form of hysteresis loss), as the B-H characteristic is traversed. 4. Most of the flux lines are confined to iron path and hence the mutual flux is increased very much and leakage flux is greatly reduced. 5. The flux can be easily directed as it takes the path through steel which gives great freedom for the designer in physical arrangement of the excitation and output windings. 6. As the medium is made of a conducting material eddy currents are induced in the same and produce losses. These are called eddy current losses. To minimize the eddy current losses the steel core is required to be in the form of a stack of insulated laminations. APPLICATION OF TRANSFORMER 1. Instrument transformers Instrument transformers comprise a large category of current and potential transformers for various voltage, frequency and physical size ranges. We have broken them up into several different groupings: low voltage, which are system voltages under 15kV; high frequency, operating frequency over 1kHz; and size ranges from board mount parts up to current transformers with window sizes of 254mm by 610mm. Read through the different types we supply below and use our Instrument Fig. 12: Instrument transformer 2. Potential Transformers: Used primarily in a step down environment to monitor voltage. They are designed for connection line-to-line or line-to-neutral in the same manner as ordinary voltmeters. The secondary voltage bears a fixed relation with the primary voltage so that any change in potential in the primary circuit will be accurately reflected in the meters or other devices connected across the secondary terminals. Potential transformers can be used with voltmeters for voltage measurements or they can be used in combination with current transformers for watt-meter or watthour meter measurements. They are used also to operate protective relays and devices, and for many other applications, Since they are used in a monitoring capacity, they generally require much greater accuracy in design. Fig. 13: Potential transformer 3. Metering Toroidal Current Transformers: Traditional, window type current transformers for measuring 50-400HZ currents of 5A to 15000A with secondaries of 0.1A, 1A and 5A (special secondary currents are available). Burden: B 0.1 through 1.8 (2.5VA to 50 VA) with Accuracy class: 0.2 to class 5.0 as per IEC 185 or class 0.3, 0.6 or 1.2 as per ANSI C 57.13. Inside diameters of up to 8.00. Many models are available as U.L. recognized devices. Applications include: à ¢Ã¢â€š ¬Ã‚ ¢ UPS systems à ¢Ã¢â€š ¬Ã‚ ¢ Transfer switches à ¢Ã¢â€š ¬Ã‚ ¢ Motor-generator sets à ¢Ã¢â€š ¬Ã‚ ¢ Commercial sub-metering, à ¢Ã¢â€š ¬Ã‚ ¢ 3 CT s in one package for 3-phase metering à ¢Ã¢â€š ¬Ã‚ ¢ Accurate measuring for metering/WATT/VAR à ¢Ã¢â€š ¬Ã‚ ¢ Current sensing, recording, monitoring control à ¢Ã¢â€š ¬Ã‚ ¢ Control panels and drives à ¢Ã¢â€š ¬Ã‚ ¢ Standard CT used as measuring standard for comparison à ¢Ã¢â€š ¬Ã‚ ¢ Winding temperature indicator (WTI) for power transformers à ¢Ã¢â€š ¬Ã‚ ¢ Summation current transformers. Fig.14: . Metering Toroidal Current Transformers Large Frame Current Transformers For measuring 50-400HZ currents in bus bar and other large conductor systems. Typical configuration is 400A to 12000A primary current with secondary of 1A or 5A Inside areas as small as 3.00 X 7.00 and as large as 7.00 X 27.00 and 10.00 X 24.00. All models are available with optional mounting plates for bulk-head mounting. Some models are U.L. recognized devices. 4. Split-Core Current Transformers This type of current transformer is available to measure AC currents from 100A to 600A, at 50 to 400HZ. They are very popular in sub-metering applications where existing systems are being upgraded and it is impractical to isolate the primary conductor. It is even possible to install this type of transformer while the conductor is energized, however it is paramount that certain safety precautions be followed under such conditions. Rectangular in shape, standard split-core models are available with window dimensions up to 4.00 X 7.50. Even larger, custom designed sizes are available by special order. Secondary ratings of 5A, 1A, and 100ma are all common in split-core current transformers. Two model groups are available, SP and SPS. The former is provided with a stainless steel screw-clamp band securing the two core halves; the latter has a UV resistant nylon band. All ratios are available in either type. Electrical and magnetic performance is identical for the two groups. Fig.15: Split-Core Current Transformers 5. Miniature Current Transformers These are constructed using one of the following methods: Plastic casing, Resin casted, Resin dipped, Tape insulated,. Typical turns ratio: 4000 : 1 to 500 : 1 and Accuracy: Class 0.1 to Class Applications include: Fig.15: Split-Core Current Transformers à ¢Ã¢â€š ¬Ã‚ ¢ Energy meters for accurate current measurement à ¢Ã¢â€š ¬Ã‚ ¢ Current control à ¢Ã¢â€š ¬Ã‚ ¢ Current signature of motors à ¢Ã¢â€š ¬Ã‚ ¢ Load sensing à ¢Ã¢â€š ¬Ã‚ ¢ Ground fault sensing à ¢Ã¢â€š ¬Ã‚ ¢ Monitoring of process parameters à ¢Ã¢â€š ¬Ã‚ ¢ AC level to logic conversation bar graph à ¢Ã¢â€š ¬Ã‚ ¢ As a transducer in instrumentation 6. Relay Class Protection Current Transformers This type of CT includes oil-immersed bussing and Resin molded versions. Primary current range from 5 Amp to 5000 Amp with secondary current 5A, 1A , or 01.A. Typical Burden B 0.1 through B 4.0 (2.5VA to 50 VA more) and Accuracy Class As per ANSI C 57.13 and IEC 185. Applications include: à ¢Ã¢â€š ¬Ã‚ ¢ Protection relays/Relay panels à ¢Ã¢â€š ¬Ã‚ ¢ Earth fault protection à ¢Ã¢â€š ¬Ã‚ ¢ Bussing type, oil-immersed CT in power transformer à ¢Ã¢â€š ¬Ã‚ ¢ Control panes and switch boards à ¢Ã¢â€š ¬Ã‚ ¢ Air/Gas circuit breakers à ¢Ã¢â€š ¬Ã‚ ¢ Motor control cubicles à ¢Ã¢â€š ¬Ã‚ ¢ Power control centers à ¢Ã¢â€š ¬Ã‚ ¢ Bus bar protection systems à ¢Ã¢â€š ¬Ã‚ ¢ Differential protection systems Fig.16: Relay Class Protection Current Transformers 7. Medium voltage Instrument Transformers These are used with a system voltage 3.3kV to 25kV and BIL 4.5 to 125 full wave crest kV. They are reliably constructed using vacuum cast with epoxy resin/polyurethane resin and are able to withstand heavy fault conditions but are not made for exposure to sunlight.. Single CTs can be built with multiple cores; for example one for measuring and another for relaying are possible. Also multitap secondaries can be provided (up to 4). Typical primary current 5 Amp to 3000 Amp and secondary current 5A/1A/01.A. Applications include: à ¢Ã¢â€š ¬Ã‚ ¢ Metering and Relaying à ¢Ã¢â€š ¬Ã‚ ¢ Energy meter panels à ¢Ã¢â€š ¬Ã‚ ¢ Medium voltage switch gears and control panels à ¢Ã¢â€š ¬Ã‚ ¢ Medium voltage circuit breakers à ¢Ã¢â€š ¬Ã‚ ¢ Motor Control Panels Fig.17: Medium voltage Instrument Transformers 8. PC mount 50 to 400Hz Current Transformers These offer a small footprint for the design engineer looking to sensor current on board. They can also be used for Metering Class (Burden from B O.1 to B 1.8 with accuracy class from 0.3 to 2.4 as per customer requirement. (As per ANSI C 57.13 and IEC 185) and for Relay Class Burden from B 1.0 to B 4.0 and relay voltage class from C 10 to C 400 or T200 as per customer requirement. (As per ANSI C 57.13 and IEC 185) Secondary current range from 0.1 to 5 amp. Typical constructions are plastic casing or resin molded. Applications include: à ¢Ã¢â€š ¬Ã‚ ¢ Sensing current overload à ¢Ã¢â€š ¬Ã‚ ¢ Ground fault detection à ¢Ã¢â€š ¬Ã‚ ¢ Metering PC mount 2OkHz to 2OOkHz Current Transformers These are used for measuring high frequency primary currents up to 15 Amps with primary to secondary isolated to 2500 VAC and have optimum performance over designated current and frequency ranges. Applications include: à ¢Ã¢â€š ¬Ã‚ ¢ Isolated current feed-back signal in switch mode power supplies à ¢Ã¢â€š ¬Ã‚ ¢ Motor current load/overload à ¢Ã¢â€š ¬Ã‚ ¢ Lighting à ¢Ã¢â€š ¬Ã‚ ¢ Switch controls à ¢Ã¢â€š ¬Ã‚ ¢ Ultra-sound current à ¢Ã¢â€š ¬Ã‚ ¢ High resolution sonar current à ¢Ã¢â€š ¬Ã‚ ¢ Isolated bi-directional current sensor with full wave bridge Fig.18: PC mount 50 to 400Hz Current Transformers 9. Air core transformers : Another kind of special transformer, seen often in radio-frequency circuits, is the air core transformer. (Figure below) True to its name, an air core transformer has its windings wrapped around a nonmagnetic form, usually a hollow tube of some material. The degree of coupling (mutual inductance) between windings in such a transformer is many times less than that of an equivalent iron-core transformer, but the undesirable characteristics of a ferromagnetic core (eddy current losses, hysteresis, saturation, etc.) are completely eliminated. It is in high-frequency applications that these effects of iron cores are most problematic. Fig.19: Air core transformers Air core transformers may be wound on cylindrical (a) or toroidal (b) forms. Center tapped primary with secondary (a). Bifilar winding on toroidal form (b). The inside tapped solenoid winding, (Figure (a) above), without the over winding, could match unequal impedances when DC isolation is not required. When isolation is required the over winding is added over one end of the main winding. Air core transformers are used at radio frequencies when iron core losses are too high. Frequently air core transformers are paralleled with a capacitor to tune it to resonance. The over winding is connected between a radio antenna and ground for one such application. The secondary is tuned to resonance with a variable capacitor. The output may be taken from the tap point for amplification or detection. Small millimeter size air core transformers are used in radio receivers. The largest radio transmitters may use meter sized coils. Unshielded air core solenoid transformers are mounted at right angle s to each other to prevent stray coupling. Stray coupling is minimized when the transformer is wound on a toroid form. (Figure (b) above) Toroidal air core transformers also show a higher degree of coupling, particularly for bifilar windings. Bifilar windings are wound from a slightly twisted pair of wires. This implies a 1:1 turns ratio. Three or four wires may be grouped for 1:2 and other integral ratios. Windings do not have to be bifilar. This allows arbitrary turns ratios. However, the degree of coupling suffers. Toroidal air core transformers are rare except for VHF (Very High Frequency) work. Core materials other than air such as powdered iron or ferrite are preferred for lower radio frequencies. 10. Tesla Coil: One notable example of an air-core transformer is the Tesla Coil, named after the Serbian electrical genius Nikola Tesla, who was also the inventor of the rotating magnetic field AC motor, polyphase AC power systems, and many elements of radio technology. The Tesla Coil is a resonant, high-frequency step-up transformer used to produce extremely high voltages. One of Teslas dreams was to employ his coil technology to distribute electric power without the need for wires, simply broadcasting it in the form of radio waves which could be received and conducted to loads by means of antennas. The basic schematic for a Tesla Coil is shown in Figure below. Fig.20: Tesla coil Tesla Coil: A few heavy primary turns, many secondary turns. The capacitor, in conjunction with the transformers primary winding, forms a tank circuit. The secondary winding is wound in close proximity to the primary, usually around the same nonmagnetic form. Several options exist for exciting the primary circuit, the simplest being a high-voltage, low-frequency AC source and spark gap: (Figure below) System level diagram of Tesla coil with spark gap drive. The purpose of the high-voltage, low-frequency AC power source is to charge the primary tank circuit. When the spark gap fires, its low impedance acts to complete the capacitor/primary coil tank circuit, allowing it to oscillate at its resonant frequency. The RFC inductors are Radio Frequency Chokes, which act as high impedances to prevent the AC source from interfering with the oscillating tank circuit. The secondary side of the Tesla coil transformer is also a tank circuit, relying on the parasitic (stray) capacitance existing between the discharge terminal and earth ground to complement the secondary windings inductance. For optimum operation, this secondary tank circuit is tuned to the same resonant frequency as the primary circuit, with energy exchanged not only between capacitors and inductors during resonant oscillation, but also back-and-forth between primary and secondary windings. Tesla Coils find application primaril y as novelty devices, showing up in high school science fairs, basement workshops, and the occasional low budget science-fiction movie. It should be noted that Tesla coils can be extremely dangerous devices. Burns caused by radio-frequency (RF) current, like all electrical burns, can be very deep, unlike skin burns caused by contact with hot objects or flames. Although the high-frequency discharge of a Tesla coil has the curious property of being beyond the shock perception frequency of the human nervous system, this does not mean Tesla coils cannot hurt or even kill you! I strongly advise seeking the assistance of an experienced Tesla coil experimenter if you would embark on building one yourself. 11. Linear Variable Differential Transformer: A linear variable differential transformer (LVDT) has an AC driven primary wound between two secondarys on a cylindrical air core form. A movable ferromagnetic slug converts displacement to a variable voltage by changing the coupling between the driven primary and secondary windings. The LVDT is a displacement or distance measuring transducer. Units are available for measuring displacement over a distance of a fraction of a millimeter to a half a meter. LVDTs are rugged and dirt resistant compared to linear optical encoders. Fig.21: LVDT The excitation voltage is in the range of 0.5 to 10 VAC at a frequency of 1 to 200 KHz. A ferrite core is suitable at these frequencies. It is extended outside the body by an non-magnetic rod. As the core is moved toward the top winding, the voltage across this coil increases due to increased coupling, while the voltage on the bottom coil decreases. If the core is moved toward the bottom winding, the voltage on this coil increases as the voltage decreases across the top coil. Theoretically, a centered slug yields equal voltages across both coils. In practice leakage inductance prevents the null from dropping all the way to 0 V. With a centered slug, the series-opposing wired secondarys cancel yielding V13 = 0. Moving the slug up increases V13. Note that it is in-phase with with V1, the top winding, and 180o out of phase with V3, bottom winding. Moving the slug down from the center position increases V13. However, it is 180o out of phase with with V1, the top winding, and in-phase wit h V3, bottom winding. Moving the slug from top to bottom shows a minimum at the center point, with an 180o phase reversal in passing the center. Acknowledgment

Telecommunications and Networking Report :: Telecommunications Technology Essays

Telecommunications and Networking Report 1.â€Å"Free Web Services Challenge AOL’s Dominance† - Internet business analysts generally are not yet convinced of the viability of the free web service business model for bring profitable. None-the-less, most agree that the free access will probably take a significant chunk of AOL’s market share before running out of investor’s money. 2.â€Å"Visitalk.com Builds White Pages for Web Phone Calls† - Visitalk.com has unveiled plans to simplify the routing of phone calls over the Internet. They will provide a directory service which will provide subscribers with a unique 12 digit Internet phone number. The directory will capture user’s current IP address and update their database, serving as a switchboard for Internet phone calls which are routed over IP. This solves a major problem with the fact that IP addresses change for users as they move from computer to computer. 3.â€Å"Cisco to But Software Maker for $325 Million† – Cisco Systems agreed to acquire WebLine Communications, a software maker producing e-mail routing and collaborating software. WebLine is to be assimilated into Cisco’s Applications Technology Group. This was Cisco’s 12th acquisition this year. 4.â€Å"Firm Agrees to Purchase Cable-Modem Technology† – Intel agreed to purchase the cable modem technology of Stanford Telecommunications, Inc. The deal puts Intel face to face in the marketplace with Broadcom Corp., which currently holds the majority market share for cable modem chips. 5.â€Å"Qualcomm Pact Targets Wireless Network Products† – Lucent Technologies signed a development agreement with Qualcomm to product wireless networking equipment. Qualcomm will give its CDMA technology, including chips and software to Lucent. Lucent plans to have trial systems utilizing the technology in place next year. 6.â€Å"MCI Worldcom, Sprint Ponder Merger† – The world’s second and third largest long-distance carriers are in talks are in talks over a possible merger. The deal would give MCI it’s only nationwide wireless network. An obvious stumbling block over such a large telcom merger would be close scrutiny by regulators. It is also expected that regional Bell companies may soon have permission to compete in the long distance market as well. 7.â€Å"Earthlink and MindSpring to Merge, Forming No. 2 Internet Access Firm† – This deal makes the new Internet Provider second only to AOL. The combined company will have 3 million subscribers, still a far cry from AOL’s 18 million, but none-the-less a viable competitor. 8. â€Å"Teledesic ‘Sky Internet’ May Start Sooner† – Teledesic chief Craig McCaw is attempting to raise funds for his planned ‘Sky Internet.

The First Outbreak of the Illness :: Medicine Medical Influenza Essays

The First Outbreak of the Illness It was a quietly dull afternoon when they brought the first victim into the Emergency Room. He was a boyish 15 year-old, an adolescent sheep herder who appeared to be suffering from an unusually high fever accompanied by delirium. His uncle, the only relative to accompany the boy, said that his nephew was in good spirits until a few days prior when his health quickly deteriorated. [I was] a visiting doctor from Peru [and] the boy reminded me of home, where a majority of my childhood neighbors raised sheep upon the Altiplano. The hospital in which the boy was received was King Fahad Central Hospital in the town of Jazan, a small city in southwest Saudi Arabia near the Yemen border. It was early August 2000, and I was in Jazan as a participating physician in the first physician exchange program between the Saudi and Peruvian governments. My admission into this program was due to my youth, my specialization in pediatrics, and my familiarity with livestock culture. Though this are a of Saudi Arabia was similar to home in climate, it didn't help ... that the language of these indigenous people was so difficult to interpret. Thank Allah that I was surrounded by a sympathetic hospital staff. After administering fluids to relieve his dehydration, I had the boy x-rayed to see if I could find anything beyond the surface of his quickly-failing, physical condition. Upon review of the patient's cranial x-rays, it was found that there was swelling of the brain (encephalitis) along with kidney damage. Sadly, the boy was pronounced dead two days later, and with my inability to find a cure for him, the hospital was suddenly facing an exponential amount of patients suffering from the same condition. Desperate to find a clue, my fellow doctors and I spent whatever time available studying the cause for this mysterious illness. The most common factors between these patients were that all of them were herdsmen who happened to graze their sheep near a wadi (seasonal watercourse) a few miles north of Jazan. Instantly we assumed that this was a new, aggressive form of malaria with the vector being a mosquito. However, another colleague, Dr. Muhammad Almaradni, concluded another diag nosis--Rift Valley Fever. According to the World Health Organization, Rift Valley Fever (RVF) was isolated in 1930 during an

The Nurse and Friar Laurence are responsible for Romeo and Juliets deat

  Ã‚  Ã‚  Ã‚  Ã‚  In Shakespeare’s play Romeo and Juliet the characters Nurse and Friar Laurence are to blame for Romeo and Juliet’s Problems.   Ã‚  Ã‚  Ã‚  Ã‚  The way Friar Laurence encouraged Romeo and Juliet to get Married, The way the Nurse is contradictory in her views of Romeo and Paris, When Friar Laurence secretly married them, the way the Nurse is secretive about the affair and does not tell the Capulet’s or the Montague’s, when Laurence gave Juliet the sleeping potion, the way Laurence believed he was doing the right thing without thinking of the consequences, and the way Laurence leaves Juliet’s Tomb when he hears the watch coming, all combine to result in the lovers death.   Ã‚  Ã‚  Ã‚  Ã‚  In act II scene III, Romeo goes to see Friar Laurence to tell him that he no longer loves Rosaline, but has fell in love with Juliet. This amazes Friar Laurence, but he promises to marry them,   Ã‚  Ã‚  Ã‚  Ã‚  Ã¢â‚¬Å"O, she knew well   Ã‚  Ã‚  Ã‚  Ã‚  Thy love did read by rote, that could not spell.   Ã‚  Ã‚  Ã‚  Ã‚  But come, young waverer, come, go with me.   Ã‚  Ã‚  Ã‚  Ã‚  In one respect I’ll assistant be.   Ã‚  Ã‚  Ã‚  Ã‚  For this alliance may so happy prove   Ã‚  Ã‚  Ã‚  Ã‚  To turn your household’s rancour to pure love.† (Friar Laurence, Act II Scene III, sentence 87-92)   Ã‚  Ã‚  Ã‚  Ã‚  By doing this, Friar Laurence has gone behind Capulet and Montague’s back, and started the momentum behind the lover’s tragedy.   Ã‚  Ã‚  Ã‚  Ã‚  In a few parts of the play, the Nurse speaks of Romeo and Paris with Juliet, each time she has a different view on who Juliet should be with,   Ã‚  Ã‚  Ã‚  Ã‚  LADY CAPULET   Ã‚  Ã‚  Ã‚  Ã‚  Ã¢â‚¬Å"Marry, that ‘marry’ is the very theme   Ã‚  Ã‚  Ã‚  Ã‚  I came to talk of. Tell me daughter Juliet,   Ã‚  Ã‚  Ã‚  Ã‚  How stands your dispositions to be married?†   Ã‚  Ã‚  Ã‚  Ã‚     Ã‚  Ã‚  Ã‚  Ã‚  JULIET   Ã‚  Ã‚  Ã‚  Ã‚  Ã¢â‚¬Å"It is an honour that I dream not of†   Ã‚  Ã‚  Ã‚  Ã‚  NURSE   Ã‚  Ã‚  Ã‚  Ã‚  Ã¢â‚¬Å"An honour! Were not I thine only nurse,   Ã‚  Ã‚  Ã‚  Ã‚  I would say thou hadst sucked wisdom from thy   Ã‚  Ã‚  Ã‚  Ã‚  Teat.†   Ã‚  Ã‚  Ã‚  Ã‚  LADY CAPULET... ...p;  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Exit Friar What’s here? A cup, closed in my true loves hand? Poison, I see, hath been his timeless end. O churl! Drunk all, and left no friendly drop To help me after? I will kiss thy lips. Haply some poison yet doth hang on them To make me die with a restorative. She kisses him Thy lips are warm!† WATCHMAN ‘within’ â€Å"Lead, boy. Which way? JULIET â€Å"Yea, noise? Then I’ll be brief. O happy dagger! She snatches Romeos dagger This is thy sheath, there rust, and let me die   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  She stabs herself and falls† (Act V Scene III, sentence 144-176)   Ã‚  Ã‚  Ã‚  Ã‚  In this act, Rome and Juliet die. This is brought about by the Friars plan to help Romeo and Juliet escape to Mantua, which failed.   Ã‚  Ã‚  Ã‚  Ã‚  Without the meddling from the Nurse and Friar Laurence, Romeo and Juliet might not have died. Friar Laurence and the Nurse are responsible for Romeo and Juliet’s death. Bibliography William Shakespeare - Romeo And Juliet - Complete Edition

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