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Thursday, September 3, 2020
Gray Wolves in Yellowstone essays
Dim Wolves in Yellowstone papers The reintroduction of Gray Wolves into Yellowstone has had numerous positive influences, for example, controlling the populaces of enormous game and taking out the little week idiotic ones. A few ranchers whine about them slaughtering cows yet who cares what they think. The dark wolf, additionally called the prairie wolf, is the biggest of around 41 wild species inside the pooch family, Canidae, of the request Carnivora. Every living wolf are viewed as a solitary animal categories, Canis lupus. There are 32 perceived subspecies of the dim wolf. Wolf size shifts. Grown-ups extend from around five to six and a half feet from nose to tip of tail, from 26 to 36 inches high at the shoulders, and weigh from 40 to 175 pounds. Dark wolves arent essentially dim however grizzled dim is the most well-known shading they can likewise be white, dark or red. Wolves are recognized from hounds by qualities of the skull. At one time the wolf lived all through the vast majority of the Northern Hemisphere. Most wolf populaces are in Canada and Alaska, where they are moderately steady. Of the lower 48 just Minnesota has a wolf populace sufficiently huge to look after itself. The Forestry Service reintroduced dim wolves toward the northern Rocky Mountains just as Yellowstone National Park trying to restore the species after a nonappearance of over 60 years. Dark wolves were annihilated from the region by the late 1920s. They are assigned as jeopardized under the Endangered Species Act in a large portion of the lower 48 states. The reintroduction program is an agreeable exertion with the National Park Service and USDA Forest Service. Toward the end of last century, we understood that something wasn't right with the biological system in Yellowstone National Park. Without the wolves Yellowstone neglects to keep up its characteristic state. It was clarified that the biological system in Yellowstone could never work appropriately until they were back. They concluded that the wolf ought to be reintroduced into the biological system at Y ... <!
Saturday, August 22, 2020
Research Sites For College Papers - How To Use Them
Research Sites For College Papers - How To Use ThemWith all the ease and convenience of finding and checking out various research sites, college students now have the option to use these to check up on college papers before the due date arrives. It has been found that many students skip going through this step simply because they do not know that this is a good option available. This article discusses the various options available for college papers to check up.One easy option is by making use of online research sites. The main reason for this is that many students do not like having to go through the hassle of physically going through papers. The use of research sites for college papers is very common among students since it does not take a long time at all.There are several advantages in this online option. Since you only need to log in once and then save the paper, you get to see and save each and every one of the papers that you are dealing with. This will help you check if the p aper is okay or not.However, the main disadvantage of this online option is that there will be a time lag. It will not always be available for you to check up on papers that you are working on. If the paper you want to check up is one that you are working on then it will be a pain for you to check it up just before the due date arrives.Also, there is a chance that the paper that you are saving could have already been checked by someone else. This means that the paper may have already been dealt with so it would be good to check up on it prior to the due date. This is the main disadvantage of the online option.Another way of checking up on papers is by using libraries. This is a great option, since you can easily check up on papers as and when you want. However, the disadvantage of this option is that there are many copies of the same papers that you will need to check up on.In order to overcome this problem, you can simply check up on papers from different libraries at once. This wi ll allow you to check up on different papers at the same time without wasting time. This way, you can check up on multiple papers at the same time and at the same place.Online research sites for college papers are very helpful. However, it will always be better to have all the information up front so that you will not be left guessing what the papers are about. Hence, if you are planning to check up on college papers then you should have all the information first so that you can not lose your time.
Friday, August 21, 2020
Chinese Transformation Essays - Geography Of Asia, Asia, Eurasia
Chinese Transformation Gradualism is normally the most plausible way to deal with any circumstance. Since the fall of the iron window ornament, these two Communist force houses have decided to move towards popular government. China has decided to take the regular, increasingly steady methodology to vote based system where as Russia has picked the quick paced, increasingly perilous methodology. These two countries have decided to change their economies from a collectivized order one to a market arranged one so as to expand the ezdard of living in their nations. As we have found lately, China is blasting and turning out to be increasingly fruitful, while Russia appears as though it is relapsing back to parochial ways. It is difficult to think about anything other than Russia and China's ways to deal with change, and the outcomes that acquired. The two countries have incomprehensibly various economies and to contrast one economy with another would be irrational. China and Russia's way to deal with change are inconceivably unique, practically like night also, day. China's political and financial strategy has consistently been to get things done bit by bit. Though Russia had confidence in experiencing the important changes rapidly, so the hardship would thus pass similarly as fast. In the usage of their strategies, we have seen that China's methodology has prompted a 29% of development in their modern field. Be that as it may, in correlation, Russia as it were yielded 15% with their methodology. Yet, one must remember that China has more modern parts than does Russia, so their activity in improving industry is outstandingly simpler than Russia's accomplishment in building up an industry. Strategically, the two countries have similar arrangements that they held in their economies. China puts stock in step by step letting the individuals have more access to political opportunity. Furthermore, once more, Russia's strategy has been to flood them at the same time with these new discovered opportunities. Lamentably Russia's strategy hasn't been the most normally achievable methodology once more. Their kin have been unexpectedly shelled with all of these freshly discovered opportunities they have never understanding. They resemble close to nothing kids let free in a sweets store. There are these new things accessible to them, and a large portion of the more youthful age needs also have a go at everything simultaneously. These residents trying different things with their new opportunities are making political confusion. The Russian residents don't have the opportunity to relish their new opportunities and are simply attempting to snatch them from left and right. For they are most likely apprehensive that on the off chance that they don't take their opportunities rapidly, they will leave as fast as they came. Then again, China will not permit their residents run the country. Rather they are proceeding to disregard majority rules system. They decline to have just races, expert majority rule government showings, and still control the press. They are as yet attempting to keep up that divider that isolates them from the remainder of the world. From a just perspective, China's methodology is horrifying. China is declining fundamental law based rights that the Western country residents underestimate. China is under the misguided judgment that they can give it's kin little morsels of opportunity and shield them from needing more. China's pioneers imagine that they can continue controlling that numerous individuals for an unsure measure of time, they don't understand that once the individuals think about a superior life, nothing can prevent them from seeking after that life moreover. So taking a gander at Russia and China's political strategies, it is protected to state that what is useful for the economy may not really be useful for the individuals. When taking a gander at development and physiology, one will likewise see that changes normally occur bit by bit. After some time, living life forms change and advance, yet the key fixing is time. Now and then changes occur more than a large number of a large number of years, as planned commonly. In any case, while analyzing an adjustment in nature that happened suddenly or rapidly, one will see that the change was normally an accident, or on the other hand a side-effect of the obstructions by humankind. China has taken the common way, and has progressively prevailing in the brief timeframe range that it has be on the advertise situated way. Then again, Russia, who decided to take a quick paced approach is enduring and has not prevailing with regards to evolving. By and by, I accept that the Russian individuals will attempt to return to socialism, yet will be halted, either forcibly or by will. They individuals will turn out to be so tired of the hardship they suffer and the conezt aching for when life was better under the red watchman, that they will tr to begin a revolt to return to socialism. In any case their endeavors to return will
Monday, June 15, 2020
Children at Risk - Free Essay Example
Background Obesity has become a nationwide epidemic that affects a vast amount of our population. According to Reingold and Jordan, obesity is considered a widespread and all-inclusive health problem in the United States that affects over 72 million Americans (2013). There is a distinct difference between being classified obese versus being classified overweight. The Centers for Disease Control uses the tool of body mass index, or BMI, to determine an individuals weight status (Centers for Disease Control [CDC], 2016). A BMI that defines overweight is considered to be 25.0- 29.9, whereas a BMI classified as obese would be 30.0 or greater (Reingold Jordan, 2013). The statistics have shown to trend upward for every population, but some groups are more susceptible to the detrimental health factor. Obesity tends to affect a certain faction of the population, including those that are considered lower socioeconomic class, certain minority groups including the Hispanic population and African American population, as well as those with physical disabilities. The aforementioned factors appear to almost double the chances of being considered obese (Bazyk Winne, 2013). Unfortunately, the total number of pediatric obesity cases are steadily rising. The national percentage of youth considered obese is seventeen (Kugel, Dysinger, Hewitt, 2017). Due to the enhanced importance of early development, children are at a greater disadvantage to face comorbidities such as poor physical, social, and mental health. Children at Risk The youth of today faces many novel struggles that have previously been unexperienced by older generations, as we are now living in a dynamically changing society, (Kugel et al., 2017). With the ever-growing field of technology, kids are becoming more sedentary and less likely to seek healthy food options due to inexpensive and convenient of fast food chains (Reingold Jordan, 2013). Studies have shown vast correlation between obesity and other chronic diseases such as sleep apnea, diabetes, hypertension, cancer, cerebrovascular accidents, infertility (Reingold Jordan, 2013). Not only is physical health impacted greatly, psychological health stands to be affected too. Issues such as anxiety, suicidal ideations, and depression are common among obese children (Bazyk Winne, 2013). Social health is also negatively influenced by obese children. The inability to engage in activities of daily living, such as play, due to obesity has shown a correlation to rates of self-reported weight-based bullying, social exclusion, and social withdrawal (Kugel et al., 2017). This dangerous trifecta of negatively impacted physical, social, and psychological health is alarming and stands to be a task for occupational therapy to face head-on. Impact on Occupational Therapy The heart of occupational therapy lies within our ability to provide meaningful and effective interventions to assist clients in their return to participation of daily functions and activities (Reingold Jordan, 2013). But occupational therapy professionals must realize the important role that prevention holds regarding childhood obesity. As mentioned earlier, obesity tends to confound with numerous other comorbidities, all of which can negatively impact activities of daily living. It is important to be able to recognize factors that signal the possibility of obesitys chronic progression (Kugel et al., 2017). Occupational therapy plants its roots in advocacy, therefore all occupational therapists should advocate for their clients physical, social, and psychological health. Impact on Pediatric Intervention During any pediatric client encounter, an occupational therapist can incorporate numerous healthy habits into their practices and interventions, such as proper nourishment training, physical activity, and positive social interactions (Lau et al., 2013; Reingold Jordan, 2013). Occupational therapists can perform early health interventions in a variety of settings such as school systems, home health, and community-based groups (WILL SPACK!!!!!!)
Wednesday, May 6, 2020
Children with Learning Disabilities Essay - 2139 Words
Children with Learning Disabilities Do you know anyone who suffers from a learning disability? There are several disabilities out there, so chances are you must know someone who battles with the day-to-day hassles. But, are learning disabilities really a hassle? More often than not, this can be considered a misconception. Learning disabilities (LD) affect the way a person ââ¬Å"of at least average intelligence receives, stores, and processes informationâ⬠(NCLD 2001). This neurological disorder prevents children especially from being able to perform well academically. Therefore more time and special programs are fostered to them. Once one is educated about what the disability means, the causes of LD, what programs are available toâ⬠¦show more contentâ⬠¦Understanding a foreign language is also not one of their strong points. A child with a learning disability does not perform well on tests, especially when they are timed, often refuses to do written work, and has trouble decoding words. This usuall y means that they have trouble hearing and understanding a personââ¬â¢s directions since they cannot decode the message properly. (Silverman) Of the three previously mentioned diseases, Dyslexia impairs a personââ¬â¢s ability to read, write, and spell (NINDS 2003). Although they are of normal intelligence, their reading level is below average. They will usually have ââ¬Å"trouble with phonological processing (the manipulation of sounds) and/or rapid visual-verbal responding.â⬠(NINDS 2003). Children with dyslexia complain they cannot read their textbooks, do not have enough time to finish tests, cannot take notes, and are unable to read their own handwriting (GVSU 2000). Dyslexia does not affect every person the same way, and signs of the disorder may not be prevalent until later, when grammar and more in-depth writing skills are introduced. Dyslexia can also create a difficulty in processing vocabulary and thoughts correctly when speaking, and understanding what one says when they are spoken to. Dysgraphia is another neurological disorder that focuses on writing. When a child with this disorder is first in troduced to writing, they will make unnecessary spaces between their letters, and some letters will beShow MoreRelatedLearning Disabilities in Children1603 Words à |à 7 PagesLearning Disabilities 1 Children and Learning Disabilities Child/Adolescent Development PSY3520 South University Online Scott Walker Learning Disabilities 2 Children that are dealing with learning disabilities have a difficult road ahead of them. If the disability is neglected or overlooked for too long, the probability of the child falling behind in school as well as social aspects in their life is very high. HoweverRead MoreEducating Children With Learning Disabilities1612 Words à |à 7 PagesEducating Children with Learning Disabilities Research Compiled for Termpapermasters.com, Inc. by M. Hall 8/2009 Introduction Educators and parents sometimes have very different views on the education of their children and the best approaches to classroom process. Educational initiatives since the implementation of the No Child Left Behind Act (NCLB) has led to increasing focus on providing parents with adequate data for decision-making and promoting positive parent/teacher interactions. ForRead MoreLesson for Children with Learning Disabilities1468 Words à |à 6 PagesIntroduction Learning disability is a term misused severally. In essence, it applies to students who have different learning challenges. Most people associate learning disability to the development of a child, thus assuming that it is a short-term condition and disappears as the person matures. The accepted definition, provided by the National Adult Literacy and Learning Disability Center states that; learning disability is generic and refers to a composite group of disorders that become evidentRead MoreChildren With Learning Disabilities And Adhd768 Words à |à 4 PagesIdentifying information. Inna Doe is a 16-year-old from Chicago, Illinois who currently attends Eagle Hill School in Hardwick, Massachusetts, a boarding school for students with learning disabilities and ADHD, since September 2015. Inna is a female who is white and is of Eastern European decent. Inna did not identify her sexuality or religious preferences. Inna began living in a Russian orphanage at 2 years old and was adopted f rom the orphanage at 3.5 years of age by her parents John and Jane DoeRead MoreChildren With Learning Disabilities Are Inherently At Risk876 Words à |à 4 PagesChildren with learning disabilities are a population who are inherently at risk. They are at risk of not being able to utilize the presented curriculum, as their non-disabled peers do. They are also at risk of suffering from emotional stress and or low self-efficacy as they negotiate classrooms assignments and expectations. Our Exceptional Children text states that children with learning disabilities, ââ¬Å"â⬠¦ often struggle with reasoning, attention, memory, selecting and focusing on relevant stimuliRead MoreEducational Needs Of Children With Learning Disabilities Essay890 Words à |à 4 PagesEven after a child is diagnosed with a disability, they remain able to improve intellectually and personally. ââ¬Å"Special Education is a specialized area of education which uses unique instructional methods, materials, learning aids, and equipment to meet the educational needs of children with learning disabilities.â⬠(Specialednews, 2009). ââ¬Å"Learning disabilities do not go away ââ¬â theyââ¬â¢re with you for life. That doesnââ¬â¢t mean someone with a learning disability canââ¬â¢t achieve or even be wildly successfulRead MoreThe Differences Of Children With ADHD And Learning Disabilities1444 Words à |à 6 PagesIndividuals with ADHD, LD and RD have more learning problems than in a child with either ADHD, learning disabilities, or RD alone (Faraone, et al., 2001; Jensen, Martin, Cantwell, 1997; Smith Adams, 2006). For example, students with ADHD and learning disabilities had demonstrated poorer reading skills (Woodcock Johnson III), inferior social skills, and more behavior problems when compared to their peers with learning disability alone, and those differences persisted over time (Wei et al., 2014)Read MoreThe Role Of The Development Of Children With Learning Disabilities1109 Words à |à 5 Pagesinfluence of the development of their children with learning disabilities (LD) and their families. Furthermore we learned that the culture of the school, it organizational, itââ¬â¢s overall environment can effect students with LDs either positively or negatively (Smith, 2004). Our first DQ question further explored the importance of family by asking what are some important elements in parent-child interaction that affect achievement for students with learning disabilities and why is it important to knowRead MoreEducating Children With Learning Disabilities And Needs1207 Words à |à 5 Pagesknowledge, skill, and disposition to address the needs of young children. Teachers asses children because it provides them needed information to help children with learning disabilities and needs. Assessment also gives teachers a more guided approach to teaching that is fitted to each child individually. The purpose of assessing young children is not merely to learn about children, but uncover and plan for their individual learning styles, behaviors, weaknesses, skills, and personalities. Teacherââ¬â¢sRead MoreSocial Behaviors Of Children With Learning Disabilities Essay2200 Words à |à 9 Pages Introduction Learning Disabilities is a growing sensation throughout the world.Many people pass by children with a learning disability without notice. Unlike other disabilities, a learning disability is a hidden handicap. Students with learning disabilities do everyday things like going school and living a productive life of sports and activities. Many people believe that children with learning disabilities are lazy and are not determined, this idea is not true. Many students do not know what
Clements and Taxation Taxation Law
Question: Describe about the Clements and Taxation for Taxation Law. Answer: Case study 1: Residence and source Fred does not reside or is domiciled in Australia hence for the purpose of assessment of tax his residency will be determined based on the statutory tests. Under the Australian Taxation law, an individual is determined to be a resident for the purpose of taxation as per the statutory requirements mentioned under Section 6 of ITAA (1996). Section 6 lays down the following test for the determination of resident for the purposes of taxation: Domiciled in Australia: the individuals domicile is in Australia. 183 days requirement: the individual resides in Australia for more than 6 months, either for a continuous period or intermittently period in an income year. However this condition is subject to the intention of the individual, whether he intends to reside in Australia or not and his usual place of abode is outside Australia. If either through his actions or intention he does not wish to reside in Australia or his usual place of abode is outside Australia then he is not a resident for the purposes of taxation. Superannuation Scheme: if the individual is a member of the superannuation scheme in Australia then he is a resident of Australia for tax Assessment. In the given situation Fred is a resident of Australia for taxation purposes as he falls under the second test laid down in the Income Tax Assessment Act, which is the 183 days test. Since Fred resides in Australia for a period of 11 months consecutively, he fulfils the condition of residing in Australia for more than one-half of the income year. Here the income year is not the calendar year but the year when the income is actually earned. In Clemens and Commissioner of Taxation [2015], it was stated that the assessee must be physically present in Australia for more than 183 days in an income year to be resident of Australia. Herein, Fred being a British citizen has come to Australia with the intention of residing in Australia, although the period of residence is not fixed, but his intention is apparent from the fact that he has come to Australia to set up a branch of his company (Ato.gov.au, 2015). Also he rents his family home and brings along his wife too which shows that he intends to stay for a long duration, because if that was not the case then he would have left his wife with his children. The usual place of abode is not the permanent place of residence, as was held by the administrative tribunal in Jaczenko and Commissioner of Taxation, [2015]; it is the current or the habitual place that is considered as the usual place of abode. In this case also, Freds usual place of abode is in Melbourne as he has leased a property for 12 months which shows his intention of habitual as well as current residence. Although Fred has a family home outside Australia, still his place of abode will be determined by his usual place of abode. Therefore, Fred is a resident for the purposes of tax assessment and the income he gains from renting out the family home and other interest accrued from his investments in France, he shall pay taxes in Australia for that income gained. Case study 2: Ordinary Income Californian Copper Syndicate Ltd v Harris (Surveyor of Taxes) (1904) 5 TC 159: This judgment clears the concept of assessment of tax in case of sale proceeds from a land or building. As a principle when an ordinary investment is realised the gain received from the difference in value is not considered as profit and is only an ordinary income and not a capital gain. However, gains from realising securities are considered as capital gains as they are profits earned in the ordinary course of business. Lord Justice Clerk explained the scheme of capital gains, and states that there is a very slight difference between the above two situations and in each case the situation is to be determined based on the idea of whether there is an enhancement of value by mere realisation or change in investment or whether there is a gain while carrying out a profit making activity. The case discusses in general the assessing of income generated from sales proceeds of land/ building. The ratio of the judgment was that in order to assess taxability it is to be first seen whether the profit is in the nature of income falling under the category of capital income/gains. It was held that if the sale of the building/land is not for the purpose of business, i.e. the sales is not in ordinary course of business for profit making motive and is only a realisation from sales due to enhanced value meant for further investment and not for profit making then the character of the gain so received is not a capital gain or income but only an ordinary income under the Income Tax Act. Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 It was submitted by the respondent that the income that was generated from sale of land belonging to the company was an income that falls under either section 6 or Section 24, which are the incomes generated not for profit making purposes or in the ordinary course of business arising from carrying out of the business. The business of the respondent company as evident from its memorandum was of mining, the sale and other activities were only a part of the business in order to fulfil its final work of mining. The court held that, the Lambton lands were bought for the purpose of coal-mining and not for profit making by sale of the land. It was only after the purpose of coal-mining became redundant, that the respondents started to sell the land. The mere sub-division of the land before selling it and was only a method of using the land to its advantage, which is not the same as profit making in the ordinary course of business of sale of land. The construction of railway lines, parks and other amenities are only a part of the advantage that the company was trying to seek, as sub-division is not possible without that. Hence, it cannot be said that the sale of land by the respondent was for the purpose of profit making rather it was only for realisation of the land. Therefore the income generated would fall under the category of Section 6 of the ITAA as in order to fall under section 26, it falls out of the ambit of carrying on or carrying out for profit making by sale. FC of T v Whitfords Beach Pty Ltd (1982) 150 CLR This is a case that establishes the principle that not every sale wherein the magnitude of proceeds is high can be said to be as a profit assessable under section 26 of ITAA. Here, the taxpayers had bought the land for the purpose of securing entry for its shareholders to the shacks at the beachside. Later on the land was developed by the shareholders into residential areas and was developed for the same purpose and there was a residential subdivision of the said land. The sales of the same generated huge profits, but the intention of the taxpayer while buying it or while selling it was not for the purpose of profit. It was held that the degree of proceeds is not the parameter on which the assess ability shall be governed but what happens to the land in the course of conducting the business that would be the subject of assess ability. In the present case the development of the land and its sale was considered as mere realisation of the land, assessable under Section 25 of the ITAA. Statham Anor v FC of T 89 ATC 4070 In this case the court held that there was only realisation of land and the tax-payers were trying to sell of the land in the most advantageous way for them. This conclusion was derived at after thorough consideration of the facts that the tax-payers bought the land for the purpose of farming, they later tried to sell off the land in one lot but were unable to do so, they did not engage into commercial activity of selling the land by employing brokers, working, developing site office etc, they continued with their respective professional tasks, they only subdivided the land in order to make the most out of the sales. Also none of their actions were in the nature of profit making by sales nor were they professionally involved in land development in the ordinary course of business. Hence, merely shifting from farming to development of land for selling it in order to take advantage does not amount to profit making under section 26, rather in the present case it was only realisation of t he capital asset and is an income under Section 25 of the Act. Casimaty v FC of T 97 ATC 5135 In this case there were 5 applications before the court for reviewing the decision of the Commissioner of Taxation disallowing objections of the applicant to amended assessments of tax in 1987, 1988, 1989, 1990 and 1991 stating that successive subdivisions of the property Acton View occurred in the course of carrying on a business. The issue for determination was whether the subdivision and sales were undertaken as part of conduct of business such that the profits are accessible under Section 25(1) of The Income Tax Assessment Act, 1936 or under second limb of S. 25A of the Act. The Court decided in favour of the taxpayer being influenced by factors that apart from activities necessarily undertaken to obtain approval for subdivision, he did nothing to change the purpose of Acton View and used it as residence and conducted the business of a primary producer. Also, he did not acquire any other land to add to his stock suggesting that he did not carry a business of lands. Also, though h e worked in partnership with his wife and son, he made no attempt to bring Acton View as a partnership asset, considering the fact that subdivisions were undertaken only to meet debts and problems of deteriorating health. Thus the taxpayer carried no business of land and thus the appeal was allowed that each assessment be remitted to reassessment in accordance with these reasons. Moana Sand Pty Ltd v FC of T 88 ATC 4897 In this case, the applicant (the company) appealed against the decision of the Administrative Appeals Tribunal where the Tribunal disallowed the objection of the company to the Commissioners claim of bringing to tax $ 500,000 less the cost of land and other expenses wherein the land owned by the company was resumed. Here, the tribunal decided that $ 370,000, less costs and expenses, should be bought to tax for 1980 since only the aforesaid amount was paid in this year. The principal of this company is Mr. Roche to whom the land was transferred in 1951 as nominee for a family syndicate. The land has many sandhills on it. The company, incorporated in 1955 contained in its MOA the only object to acquire lands for the purpose of carrying on business of working on/or selling the sand thereon. The tribunal came to the conclusion on the basis of the evidences before it that the company while acquiring the land had the predominant purpose of working on/selling the sand on it while secondary to it, was the purpose of selling the land for profit when the time became ripe for subdivision and thus held the income taxable under Section 25(1) according to ordinary concepts and usages and the second limb of 26(a) which says that assessable income of a taxpayer should include profit arising from the carrying on or carrying out of any profit making undertaking or scheme. Before this Court, the interpretation of the tribunals findings were disputed. The Court critically analysed the tribunals findings and concluded that the company had a twofold purpose in mind while acquiring the property and held the income taxable under S.2 5(1) and second limb of S. 26(a). Turning to 26(a), it said that it was not required that the second limb only apply when the profitable resale was the dominant purpose, it just has to be a purpose in mind. Also, it distinguished the case from the Kratzmanns case because unlike it here although due to compulsory acquisition, the ultimate purpose of the com pany in relation to the land was fulfilled. Thus, it dismissed the appeals with costs. Crow v FC of T 88 ATC 4620 In the present case the court was of the view that the activity of the tax payer of purchasing land and then sub-dividing it and selling was a continuous activity, which is considered to be as an activity for profit making by sale. The contention of the tax payer that he purchased the land for the purpose of farming and then in order to clear his indebtedness he had to sell of the land so bought by him, was not considered by the court. This is because the court stated that the land was bought although with the intention of farming, but the tax payer being a poor farmer, borrowed money in order to buy the land and then he had to mortgage further to pay off the mortgages. Therefore, the tax-payer already knew that he would have to the sub-divide the land in order to pay off the credit, specially taken from the bank. Hence, even if the initial intention of the tax payer was to use the land as a farm but his continuous actions of buying and selling and then the obvious need of development in order to pay off the debts makes the sale in the nature of profit making activity done in the course of business. Hence the ingredients of section 25 of the Income tax Act. The ratio of the judgment by Lockhar J. was that in order to determine whether the activity was in the nature of profit making or not, all the ingredients, including the intention and the circumstances needs to be taken into consideration and not an individual act. McCurry Anor v FC of T 98 ATC 4487 In this case, two brothers purchased a land which had an old house of no value on it with the intention of removing the old house and constructing three townhouses on the land. The purchase price was $ 32,000 of which they borrowed $ 15,000 from the bank. Later, they borrowed $ 80,000 from the bank for building the townhouses. They advertised the units for sale before their completion but no sale was affected. Then after completion, they, along with their family moved into two of the townhouses. After about an year of this, they sold the townhouses resulting in a net profit of about $ 150,000. For some time thereafter, they lived in two of the townhouses as tenants. Also, they undertook a similar development in the area and sold those units. The Commissioner of Taxation alleges that the sums were assessable to tax under Section 25(1) of The Income Tax Assessment Act, 1936 the purpose of purchase being to make profits by sale of the townhouses which the taxpayers reject by saying that the townhouses were sold because of financial difficulties and that the purpose in mind while buying the property was to derive regular income by renting them. The Court, not convinced by their arguments came to the conclusion that the taxpayers had the purpose of realising profits by the sale of the property based on the fact that that the money for purchasing the land and building townhouses was obtained by loan. Moreover, the fact that they gave advertisement for the sale of townhouses before their completion is suggestive of their motive and no attempt was ever made to let out the townhouses. Also, the taxpayers claim that if they had undertook a profit making venture they would not have abandoned it by occupying it for a year was reject ed by the Court which said that though it was used for some other purpose as per their convenience, the motive of realising profits out of it remained the same and thus the court dismissed the application with costs. References: Case study 1: Clemens and Commissioner of Taxation [2015]AATA (Administrative Appeals Tribunal of Australia), p.124. Jaczenko and Commissioner of Taxation [2015]AATA (Administrative Appeals Tribunal of Australia), p.125. Ato.gov.au. (2015). Residency tests | Australian Taxation Office. [online] Available at: https://www.ato.gov.au/Individuals/International-tax-for-individuals/Work-out-your-tax-residency/Residency-tests/ [Accessed 17 Aug. 2016]. Income Tax Assessment Act, 1996 Case study 2: Californian Copper Syndicate Ltd v Harris (Surveyor of Taxes) [1904] 5 (TC), p.159. Scottish Australian Mining Co Ltd v FC of T [1950] 81 CLR, p.188. FC of T v Whitfords Beach Pty Ltd [1982] CLR, p.150. Statham Anor v FC of T [1989] ATC, p.4070. Casimaty v FC of T [1997] ATC, p.5135. Moana Sand Pty Ltd v FC of T [1988] ATC, p.4897. Crow v FC of T [1988] ATC, p.4620. McCurry Anor v FC of T [1998] ATC, p.4487.
Monday, April 13, 2020
Topics For Critical Thinking Essay
Topics For Critical Thinking EssayWhen writing a college essay, there are many topics for critical thinking. Critical thinking is not something that is learned in school, but it is a process that are hardwired into our mind that requires no instruction from the brain. When writing a critical thinking essay, the key is to make sure that the thoughts and information are real and based on facts.A lot of college essays are written by students who are anxious to get into the college or university. The majority of these essays will be written during the first or second year. In many cases, students do not know how to write a great essay. This can be because they do not have time to practice writing a well-researched essay, or they do not have the correct writing skills.There are many topics for critical thinking that can be used when writing an essay. The first topic is the topic of religion. In order to start the topic of religion, students must research the topic of religion in the area of their religion. For example, if the student is a Mormon, they will need to research topics of what being Mormon means and how they relate to the other religions.After researching the topic of religion, students will want to create positive mental images for themselves and write a description of what they believe and what their faith teaches them. The student will then create a logical argument to support what they are saying.When writing the essay, students will want to take the time to discuss the topic of religion. After they have discussed the concept, they will want to explain how religion ties into the thesis statement of the essay. The student will then explain how they believe the concepts they have researched are true and how they relate to the topic of religion.Another topic for a good essay is one that is based on a personal experience. This could be a story about an issue that they personally dealt with such as bullying or getting picked on in school. The student will want to make sure that the story they use is based on fact and not on a biased story.Finally, the student will want to show their writing skills and explain how they will be able to use their writing skills to craft a quality essay. After explaining their skills, the student will want to make sure that they are able to come up with ideas and ways to support their argument. Once they have all of their arguments ready, they will then find a trusted friend to help them proofread their essay before submitting it to the editor.With so many topics for critical thinking essay available to students, it is easy to come up with creative ways to present information. Students should make sure that they take time to research the topic before beginning the process of writing an essay.
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