The Descent of the Dove
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“Tipping” to Private Foundation Status
EOTJ-18-05-cover.qxp_Layout 1 8/14/18 9:14 AM Page 1 September/October 2018 “Tipping” to Private Foundation Status Constitutionality of Religion Code Sections Impermissible Private Benefit EOTJcoverads.qxp_Journal covers 8/16/18 11:48 AM Page 2 EOTJ-18-09-01-TOC.qxp_PTS-06-06-000-MH&TOC 8/16/18 11:51 AM Page 1 September/October 2018 Volume 30, No. 2 ARTICLES FROM PUBLIC CHARITY TO PRIVATE FOUNDATION: HOW TO HANDLE THE “TIPPING” PROBLEM 3 CHRISTOPHER M. HAMMOND RELIGIOUS ORGANIZATIONS— CONSTITUTIONALITY OF CODE PROVISIONS 17 BRUCE R. HOPKINS IDENTIFYING AND NAVIGATING IMPERMISSIBLE PRIVATE BENEFIT IN PRACTICE 26 JOHN TYLER, EDWARD DIENER, AND HILLARY BOUNDS TENANT IMPROVEMENT ALLOWANCES PAID TO EXEMPT ORGANIZATIONS 33 RICHARD A. NEWMAN THE DISAPPEARING 60% DEDUCTION— NEW CHARITABLE GIVING LIMITS ARE NOT AS GENEROUS AS THEY APPEAR 36 BRAD BEDINGFIELD AND NANCY DEMPZE THE “SIMPLE” PRIVATE FOUNDATION— CHANGING ONE LIFE AT A TIME 42 JOHN DEDON EOTJ-18-09-01-TOC.qxp_PTS-06-06-000-MH&TOC 8/16/18 11:51 AM Page 2 Editors-in-Chief Editorial Staff Joseph E. Lundy Sharon W. Nokes Managing Editor Schnader Harrison Segal & Lewis The Pew Charitable Trusts Daniel E. Feld, J.D. Philadelphia, PA Washington, DC [email protected] Director, International Board of Advisors Tax & Journals Robert Gallagher, J.D., CPA Ronald Aucutt Barbara L. Kirschten McGuire Woods, LLP Wilmer, Cutler & Pickering Desktop Artist McLean, VA Washington, DC Anthony Kibort Wendell R. Bird James J. Knicely Cover Design Bird & Loechl Knicely & Associates Christiane Bezerra Atlanta, GA Williamsburg, VA VP, Editorial, Milton Cerny Michael S. -
Colour, Screen, Read Only (Unsuitable for Print) (CS, Colour, Screen Compiled 7
DDEETTOOXX Colour, Screen, read only (unsuitable for print) (CS, Colour, Screen Compiled 7. September 2018 DETOX II 07.09.18 a) Table of Contents, in Checksheet order: 1. 68-08-28 DRUGS..........................................................................................................................................1 2. 68-08-29 DRUG DATA..................................................................................................................................3 3. 69-10-17 DRUGS, ASPIRIN AND TRANQUILIZERS....................................................................................5 4. 80-10-11 DRUGS AND THEIR EFFECTS ON AUDITING GAINS................................................................9 5. 78-02-06 THE PURIFICATION RUNDOWN REPLACES THE SWEAT PROGRAM ..................................19 6. 78-02-06 THE PURIFICATION RUNDOWN – ERRATA AND ADDITIONS ...............................................41 7. 80-05-21 PURIFICATION RUNDOWN CASE DATA ..................................................................................45 8. 80-01-03 PURIFICATION RUNDOWN AND ATOMIC WAR.......................................................................65 DETOX III 07.09.18 DETOX IV 07.09.18 b) Table of Contents, in chronological order: 1. 68-08-28 DRUGS..........................................................................................................................................1 2. 68-08-29 DRUG DATA..................................................................................................................................3 -
Theories of Truth. Bibliography on Primary Medieval Authors
Theories of Truth. Bibliography on Primary Medieval Authors https://www.ontology.co/biblio/truth-medieval-authors.htm Theory and History of Ontology by Raul Corazzon | e-mail: [email protected] History of Truth. Selected Bibliography on Medieval Primary Authors The Authors to which I will devote an entire page are marked with an asterisk (*). Hilary of Poitiers Augustine of Hippo (*) Boethius (*) Isidore of Seville John Scottus Eriugena (*) Isaac Israeli Avicenna (*) Anselm of Canterbury (*) Peter Abelard (*) Philip the Chancellor Robert Grosseteste William of Auvergne Albert the Great Bonaventure Thomas Aquinas (*) Henry of Ghent Siger of Brabant John Duns Scotus (*) Hervaeus Natalis Giles of Rome Durandus of St. Pourçain Peter Auriol Walter Burley William of Ockham (*) Robert Holkot John Buridan (*) 1 di 14 22/09/2016 09:25 Theories of Truth. Bibliography on Primary Medieval Authors https://www.ontology.co/biblio/truth-medieval-authors.htm Gregory of Rimini William of Heytesbury Peter of Mantua Paul of Venice Hilary of Poitiers (ca. 300 - 368) Texts 1. Meijering, E.P. 1982. Hilary of Poitiers on the Trinity. De Trinitate 1, 1-19, 2, 3. Leiden: Brill. In close cooperation with J. C. M: van Winden. On truth see I, 1-14. Studies Augustine of Hippo ( 354 - 430) Texts Studies 1. Boyer, Charles. 1921. L'idée De Vérité Dans La Philosophie De Saint Augustin. Paris: Gabriel Beauchesne. 2. Kuntz, Paul G. 1982. "St. Augustine's Quest for Truth: The Adequacy of a Christian Philosophy." Augustinian Studies no. 13:1-21. 3. Vilalobos, José. 1982. Ser Y Verdad En Agustín De Hipona. Sevilla: Publicaciones de la Universidad de Sevilla. -
Edge 2012 Believer
RADAR Oxford Brookes University – Research Archive and Digital Asset Repository (RADAR) Edge, P Believer beware: the challenges of commercial religion Edge, P (2012) Believer beware: the challenges of commercial religion. Legal Studies, 2012 doi: 10.1111/j.1748-121X.2012.00252.x This version is available: https://radar.brookes.ac.uk/radar/items/6590f97d-7ced-17b3-ffd0-9b2596d14303/1/ Available in the RADAR: October 2012 Copyright © and Moral Rights are retained by the author(s) and/ or other copyright owners. A copy can be downloaded for personal non-commercial research or study, without prior permission or charge. This item cannot be reproduced or quoted extensively from without first obtaining permission in writing from the copyright holder(s). The content must not be changed in any way or sold commercially in any format or medium without the formal permission of the copyright holders. This document is the preprint version of the journal article. Some differences between the published version and this version may remain and you are advised to consult the published version if you wish to cite from it. go/radar www.brookes.ac.uk/ Directorate of Learning Resources Applied Study of Law and Religion Group . School of Law. Believer beware. The challenges of commercial religion. Professor Peter W Edge, Oxford Brookes University, [email protected] Forthcoming, Legal Studies. For further information: Email the author: [email protected] View his profile: http://www.brookes.ac.uk/profiles/staff/peter_edge Introduction. In this paper I will argue that in a wide range of circumstances religious activity and commercial activity may overlap, leading to what may fairly, albeit novelly, be categorised as commercial religion. -
THE DESCENT 2 Revisions by James Watkins
THE DESCENT 2 revisions by James Watkins 26th January 2008 Christian Colson Celador Films 39 Long Acre London WC2E 9LG Tel: +44 (0)207 8456988 EXT. APPALACHIAN MOUNTAINS - DUSK [HELICOPTER SHOTS] Storm clouds scud over a mountain range. Imposing peaks, impassable pine forest. A phone line RINGS OVER, CONNECTS to... VOICEMAIL MESSAGES. Ghost voices. SARAH CARTER (O.S.) Hi, this is Sarah Carter. I’m away for the rest of the month and won’t be picking up messages. BETH (O.S.) Hi, this is Beth. I’m in America, so please don’t leave me a message as it’s so expensive to pick them up! EXT. FOREST CLEARING - DUSK Two abandoned 4x4 jeeps. On one bumper, a ‘Rock chic’ sticker. Inside, a cellphone GLOWS on the dashboard. HOLLY (O.S.) Hey, this is Holly’s phone. No shit! Leave a fuckin’ message. Unless you’re Bobby Flynn- Bobby piss off you stalker creep. EXT. LOG CABIN - NIGHT A backwoods cabin. Dark forest encroaching all around. REBECCA (O.S.) Hi, this is Rebecca Van Ney. I’m out of the office until the 13th. In emergencies, you can reach me via Juno Kaplan on- INT. LOG CABIN - DUSK [STEADICAM] Eerily empty ROOMS, CORRIDORS. Party leftovers. The girls’ suitcases, clothes, cosmetics, photo albums, medication... A cellphone VIBRATES... JUNO KAPLAN (O.S.) This is Juno. I can’t make the phone right now. Please leave a short message and I’ll get back to you when I can. A long message BEEP. 2. INT. BOREHAM CAVERNS - DARKNESS Black screen. A MAN’S VOICE- MOUNTAIN RESCUE RANGER (O.S.) This is Pulaskie Mountain Rescue. -
A BRIEF HISTORY of the PAPACY by John Judy (Written Mid-April
A BRIEF HISTORY OF THE PAPACY By John Judy (Written mid-April 2005 for “Big News.”) MICHAEL Any day now the College of Cardinals will be choosing a new Pope. White smoke will billow out into Saint Peter's Square signaling that the Holy Mother Church has discovered fire. I'm kidding. The Catholic Church has long since acknowledged the existence of fire and has used it on more than a few occasions. If you don't believe me, ask a heretic. If you can find one! (Did I mention John Paul II once issued a formal apology to Prometheus? True story...) In any case, we Big News Catholics don't want the rest of you sinners to spend the next week in complete ignorance of our glorious heritage and the intricate, infallible goings- on of our higher-ups. With that in mind we now present a brief history of the papacy, or, as we call it: "The Vatican Highlight Reel!" MATT There have been 265 Popes since Jesus chose Saint Peter to be the rock on which he founded his church in 32 A.D. SAINT PETER Numero Uno, baby! Pearly gates in the house! MATT According to Catholic tradition, Peter brought Christianity to Rome although it was there well before Peter arrived. SAINT PETER We were in previews out of town, man. MATT And once he was in Rome, Peter didn't serve as any kind of bishop or leader. SAINT PETER It was casual. Why you doggin' me, Boo? MATT Saint Sixtus, the seventh Pope, was the first Pope known to be the son of a Priest. -
Popes in History
popes in history medals by Ľudmila Cvengrošová text by Mons . Viliam Judák Dear friends, Despite of having long-term experience in publishing in other areas, through the AXIS MEDIA company I have for the first time entered the environment of medal production. There have been several reasons for this decision. The topic going beyond the borders of not only Slovakia but the ones of Europe as well. The genuine work of the academic sculptress Ľudmila Cvengrošová, an admirable and nice artist. The fine text by the Bishop Viliam Judák. The “Popes in history” edition in this range is a unique work in the world. It proves our potential to offer a work eliminating borders through its mission. Literally and metaphorically, too. The fabulous processing of noble metals and miniatures produced with the smallest details possible will for sure attract the interest of antiquarians but also of those interested in this topic. Although this is a limited edition I am convinced that it will be provided to everybody who wants to commemorate significant part of the historical continuity and Christian civilization. I am pleased to have become part of this unique project, and I believe that whether the medals or this lovely book will present a good message on us in the world and on the world in us. Ján KOVÁČIK AXIS MEDIA 11 Celebrities grown in the artist’s hands There is one thing we always know for sure – that by having set a target for himself/herself an artist actually opens a wonderful world of invention and creativity. In the recent years the academic sculptress and medal maker Ľudmila Cvengrošová has devoted herself to marvellous group projects including a precious cycle of male and female monarchs of the House of Habsburg crowned at the St. -
Corporate Sponsorship in Transactional Perspective: General Principles and Special Cases in the Law of Tax Exempt Organizations Frances R
University of Miami Law School University of Miami School of Law Institutional Repository University of Miami Entertainment & Sports Law Review 7-1-1996 Corporate Sponsorship in Transactional Perspective: General Principles and Special Cases in the Law of Tax Exempt Organizations Frances R. Hill University of Miami School of Law, [email protected] Follow this and additional works at: http://repository.law.miami.edu/umeslr Part of the Entertainment, Arts, and Sports Law Commons Recommended Citation Frances R. Hill, Corporate Sponsorship in Transactional Perspective: General Principles and Special Cases in the Law of Tax Exempt Organizations, 13 U. Miami Ent. & Sports L. Rev. 5 (1996) Available at: http://repository.law.miami.edu/umeslr/vol13/iss1/4 This Article is brought to you for free and open access by University of Miami School of Law Institutional Repository. It has been accepted for inclusion in University of Miami Entertainment & Sports Law Review by an authorized editor of University of Miami School of Law Institutional Repository. For more information, please contact [email protected]. Hill: Corporate Sponsorship in Transactional Perspective: General Princ ARTICLES CORPORATE SPONSORSHIP IN TRANSACTIONAL PERSPECTIVE: GENERAL PRINCIPLES AND SPECIAL CASES IN THE LAW OF TAX EXEMPT ORGANIZATIONS FRANCES R. HILL* Exempt organizations depend on financial support from cor- porate contributors.' Many corporations regard charitable contri- butions as an element of corporate citizenship,2 and tax law provides that corporate contributors may deduct their charitable * Associate Professor, University of Miami School of Law. The author wishes to thank Professor Elliott Manning for his helpful comments. This research was supported by a University of Miami School of Law Summer Research Grant. -
The Breeding Birds of Central Lower California (With Eleven Ills.)
20 Vol. xxx11 THE BREEDING BIRDS OF CENTRAL LOWER CALIFORNIA WITH ELEVEN ILLUSTRATIONS By GRIFFING BANCROFT A Contributionfrom the San Diego Societyof Natural History By wagon road and burro trail it is an even one hundred miles from Santa Rosalia, on the Gulf of California, to the tide line of the Pacific at San Ignacio Lagoon. The intervening country is essentially a desert. The summit, which is two thousand feet high in the passes and nearly three times that altitude in the mountains, lies within ten or twelve miles of the Gulf. The two water- sheds are thus of unequal length. They are also of quite distinct configuration. On the eastern side the descent to sea-level is abrupt and precipitous, checked by two rather extensive valleys. The long western slope, on the other hand, is broken by valleys, canons, and pretentious hills. It is marked with the weird formations which are characteristic of arid North America and which are here exaggerated. Angles and profiles of silhouetted hills and table-tops are unusually harsh and for- bidding. There is not even the softening effect of grandeur. Over the major portion of the entire region lava has flowed and mesa, valley and mountains are covered with dull brown rocks. This lava sheet, though of varying thickness, normally does not exceed three feet in depth. In overlaying the ancient sandstone it parallels the slopes of the hills and the sides of the canons, while on the mesas, and sometimes in the valleys too, it is as level as they and often stretches away as far as the eye can see. -
What Does It Mean to Be a Woman in Horror?
What Does it Mean to be a Woman in Horror? Presentation by Maya Hendl CONTENT WARNING This presentation contains descriptions of violence, torture, kidnapping, and murder. There are no explicit images of these acts taking place, but these acts are mentioned and (briefly) described. Table of Contents 1 2 Final Girls Female Antagonists Exploring examples of female villains, why they are Exploring what they & so scary, and their ability to are, why they exist, justify their motivations in and the contexts in comparison to male which they exist antagonists 1 Final Girls Exploring what they are, why they exist, and the contexts in which they exist What Does it Mean to be a “Final Girl”? The term “final girl” was coined by Carol J. Clover in her 1993 book Men, Women and Chain Saws: Gender in the Modern Horror Film. The “final girl” is the last woman or girl left alive in a horror movie, most often within the slasher genre, that must confront the killer. Clover describes final girls as typically being sexually unavailable at the start of the film, as having sex in a horror movie is a common trope that will most likely get you killed (Alternative Press Magazine). Clover goes on to describe how, once the final girl survives, she “is ‘purged’...of undesirable characteristics, such as pursuit of pleasure in her own right. An interesting feature of the genre is the ‘punishment’ of beauty and sexual availability” (Horror Fandom Wiki). Why Do Final Girls Exist? In horror films, women are more often than not left to fight the big bad all on their own. -
Natural Theology and the Christian Contribution to Metaphysics: on Thomas Joseph White’S Wisdom in the Face of Modernity
Nova et Vetera, English Edition, Vol. 10, No. 2 (2012): 539 –62 539 Natural Theology and the Christian Contribution to Metaphysics: On Thomas Joseph White’s Wisdom in the Face of Modernity NICHOLAS J. H EALY , J R. John Paul II Institute Washington, DC From the very heart of Christian faith and, at the same time, the heart of Greek thought now joined to faith, Manuel II was able to say: Not to act “with logos” is contrary to God’s nature. [T]he faith of the Church has always insisted that between God and us, between his eternal Creator Spirit and our created reason there exists a real analogy, in which unlike - ness remains infinitely greater than likeness, yet not to the point of abol - ishing analogy and its language (cf. Lateran IV). God does not become more divine when we push him away from us in a sheer, impenetrable voluntarism; rather, the truly divine God is the God who has revealed himself as logos and, as logos, has acted and continues to act lovingly on our behalf. This inner rapprochement between biblical faith and Greek philosophical inquiry was an event of decisive importance not only from the standpoint of the history of religions, but also from that of world history—it is an event which concerns us even today. 1 It is my view that the neoscholastic rationalism that was trying to reconstruct the praeambula fidei, the approach to faith, with pure rational certainty, by means of rational argument that was strictly inde - pendent of any faith, has failed; and it cannot be otherwise for any such attempts to do that kind of thing. -
Suggestions for Further Reading
MP_D01.qxd 11/23/06 2:43 AM Page 382 Suggestions for Further Reading GENERAL SURVEYS OF MEDIEVAL PHILOSOPHY Armstrong, A. H., ed. 1970. The Cambridge History of Later Greek and Early Medieval Philosophy. Cambridge: Cambridge University Press. Copleston, Frederick. 1950. A History of Philosophy, vol. 2: Medieval Philosophy: From Augustine to Duns Scotus. Westminster, MD: The Newman Press (many subsequent reprintings by various presses). Copleston, Frederick. 1953. A History of Philosophy, vol. 2: Late Medieval and Renaissance Philosophy. Westminster, MD: The Newman Press (many subsequent reprintings by various presses). Gilson, Étienne. 1955. History of Christian Philosophy in the Middle Ages. New York: Random House. Gracia, Jorge J. E., and Timothy B. Noone, eds. 2003. A Companion to Philosophy in the Middle Ages. Blackwell Companions to Philosophy. Oxford: Blackwell. Kenny, A. 2005. A New History of Western Philosophy, vol. 2: Medieval Philosophy. Oxford: Clarendon Press. Kretzmann, Norman, et al., eds. 1982. The Cambridge History of Later Medieval Philosophy: From the Rediscovery of Aristotle to the Disintegration of Scholasticism, 1100–1600. Cambridge: Cambridge University Press. Luscombe, David E. 1997. History of Western Philosophy, vol. 2: Medieval Thought. Oxford: Oxford University Press. Marenbon, John. 1981. From the Circle of Alcuin to the School of Auxerre: Logic, Theology and Philosophy in the Early Middle Ages. Cambridge: Cambridge University Press. Marenbon, John. 1983. Early Medieval Philosophy (480–1150): An Introduction. London: Routledge & Kegan Paul. Marenbon, John. 1991. Later Medieval Philosophy (1150–1350): An Introduction. London: Routledge. Marenbon, John, ed. 1998. The Routledge History of Philosophy, vol. 3: The Middle Ages. London: Routledge. McGrade, A.