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Fashion designer Libby Griffin has had the week from hell--terminated from her job and heart-wrenching news from the doctor. Hoping for time alone to regroup, Libby rents a cabin on Grand Lake St. Mary's for five months. Right away she meets the most irritating man on the planet, who also happens to be drop-dead delicious. Recently divorced author Maxwell August has a book due, and his muse has gone into hiding. With a chip on his shoulder, his writing in stuck-mode, he heads to the lake only to encounter a monumental distraction with blonde hair and hazel eyes. Will these two right-brainers allow the off-the-charts attraction brewing between them to grow? Or deny it to focus on the things they think are more important and miss a chance at forever?
Hector thought he'd escaped his past and had nothing to fear by posing for a charity calendar, but he was wrong. Hector Torres is a self-made man. He came from the wrong side of the tracks and had a difficult childhood. Violence and crime flourished around him, but one particular event sent him running, and he's been looking back over his shoulder for a long time. He thought he'd changed enough to take a chance and do something good, especially in light of his closest friend's daughter being diagnosed with cancer. But Hector is wrong, and the man who suddenly appears in his life might be his savior—or his executioner.
#1 NEW YORK TIMES BESTSELLER • Millions of people have fallen in love with Auggie Pullman, an ordinary boy with an extraordinary face—who shows us that kindness brings us together no matter how far apart we are. Read the book that inspired the Choose Kind movement, a major motion picture, and the critically acclaimed graphic novel White Bird. And don't miss R.J. Palacio's highly anticipated new novel, Pony, available now! I won't describe what I look like. Whatever you're thinking, it's probably worse. August Pullman was born with a facial difference that, up until now, has prevented him from going to a mainstream school. Starting 5th grade at Beecher Prep, he wants nothing more than to be treated as an ordinary kid—but his new classmates can’t get past Auggie’s extraordinary face. Beginning from Auggie’s point of view and expanding to include his classmates, his sister, her boyfriend, and others, the perspectives converge to form a portrait of one community’s struggle with empathy, compassion, and acceptance. In a world where bullying among young people is an epidemic, this is a refreshing new narrative full of heart and hope. R.J. Palacio has called her debut novel “a meditation on kindness” —indeed, every reader will come away with a greater appreciation for the simple courage of friendship. Auggie is a hero to root for, a diamond in the rough who proves that you can’t blend in when you were born to stand out.
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Liam Conrad. University lecturer. Sexy as hell. ... And considering risking his career. Perry Jenkins. University student. Natural beauty. ... And crushing on her teacher. From the moment Liam and Perry lock eyes, sparks fly. Liam never expected a woman to make him look twice, let alone one that would turn up in the front row of his class. Perry's focus has always been to graduate with top marks, but she's finding herself distracted by her sexy, off limits professor. Liam is scared to share his past. Perry is struggling to hide her feelings. Both start to fall hard, but is their student/teacher relationship the only reason that Liam wants to keep Perry as his dirty little secret?
Volume of the United States Tax Court Reports containing case abstracts and opinions of the court regarding cases between July 1, 2013 December 31, 2013. Cases in each volume are listed in the prefatory table. The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to "constitute Tribunals inferior to the Supreme Court. “The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule”).” Contents 8 Findings of Fact 8 Background 8 John Hancock’s History9 Investment Process and Review10 Leasing10 LILO and SILO Transactions 10 Basic Structure 15 History 17 Due Diligence 18 The Hoosier Transaction 19 The LILO Test Transactions 20 OBB LILO20 Lease and Sublease23 End of Sublease Term25 SNCB 2 and SNCB 5 Lot 1 LILO Transactions25 Lease and Sublease28 End of Sublease Term 28 The SILO Test Transactions 29 TIWAG29 Lease and Sublease33 End of Sublease Term35 Two Dortmund Transactions35 Lease and Sublease38 End of Sublease39 SNCB SILO39 Grant and Subgrant42 End of Subgrant Term 43 Tax Returns, Notices of Deficiency, and Trial 43 Procedural History48 Trial 53 Opinion 53 Burden of Proof53 Principal Place of Business54 Leveraged Lease Transactions54 Frank Lyon58 LILO and SILO Litigation 77 The Test Transactions 78 Economic Substance79 Objective Inquiry88 Subjective Inquiry89 Substance Over Form91 OBB and SNCB LILO Transactions110 SILO Test Transactions 145 Interest Deductions 147 Original Issue Discount 149 Transaction Expenses 149 Conclusion NOTE: NO FURTHER DISCOUNTS FOR ALREADY REDUCED SALE ITEMS. Keywords: tax court reports, reports of the united states tax court, u.s. tax court reports, united states tax court reports, united states tax court, u.s. tax court, tax court