Comparing Modern Leadership And Leadership - 1322 Words

Analyzing Modern Leadership Leadership studies and practices have expanded to meet the changing demands for organizations. A comprehensive understanding of modern leadership will further the knowledge and use of various leadership tools, abilities, and limitations within these styles. Modern leadership theories are relevant and practical for the requirements placed on today’s leaders. Developing leadership skills allow leaders to think strategically and navigate the unknown effectively. New Genre Leadership Traditionally, leadership studies have focused on the attributes and qualities of the leader. The approach was to further define and improve the skill sets of leaders. However, in recent years under modern leadership studies, other theories have emerged. Leadership has been defined in a more holistic way to include stakeholders and followers as part of the construct. It shows the integral relationship between leadership and followership. This shift in the leadership outlook has let to the New Genre Leadership Theory, which investigates leadership as a process in a socio-psychological context (Springer, 2015). Several New Genre models have emerged and are documented as being successful within organizations. Transformational leadership unites and brings about positive changes. Authentic leadership encourages transparency and connection through honesty and values. Collaborative leadership embraces different views and encourages teamwork to fulfill a common Show MoreRelatedThe Importance Of Management At A Great Manager1080 Words   |  5 Pagesconsideration the most important topics of management as well, some of which include leadership, personality, motivation, decision-making, and communication. Being a great leader does not happen overnight. Leadership Leadership as defined by businessdictionary.com is â€Å"the activity of leading a group of people or an organization or the ability to do this†. Buisnessdictionary.com goes on the state that leadership involves establishing a clear vision or goal, be able to communicate that goal withRead MoreEssay on Law Enforcement and Leadership1449 Words   |  6 PagesIntroduction Police leadership uses standardization and procedure as a way to create consistency and predict ¬ability in law enforcement operations (Batts, Smoot, Scrivner, 2012). The San Diego Police Department, like nearly all law enforcement agencies uses leadership models mimicking the United States military. Paramilitary organizations use highly structured framing to conduct business operations. The structural frame creates compartmentalized specialization, and predictable, uniform task performanceRead MoreDeveloping a Motivational Plan Essay1324 Words   |  6 PagesDeveloping a Motivational Plan Essay Victoria Webb Grand Canyon University Educational Leadership in a Changing World - EDA 575 February 12, 2011 Developing a Motivational Plan Essay Motivation is the key to the success to any organization. â€Å"Human relation thinkers see the terms motivation and behavior as closely related because human behavior occurs as a result of motivation† (Razik Swanson, 2010, p. 108). Motivating people to work harder, give of themselves 100%, encouraging the employeesRead MoreThe Post Bureaucratic Era Of The Columbian And The Challenger Accident Incurred By Nasa1520 Words   |  7 Pagespost-bureaucratic era has seen the augmentation of leadership practices cultivating business sustainability from a pecuniary model to an ecological modernised ideology. Although, such dynamic contribution to business dogma has transformed neo-classical principles. Thus, exemplifying it as a â€Å"hybrid† form of economic â€Å"bureaucratic† growth and â€Å"Weberian† social and environmental rational (Clegg and Courpasson 2004: pg; 527). In this essay, I argue that post-bureaucratic leadership practices contribute to man aging sustainabilityRead MoreLeadership Styles From The Television1395 Words   |  6 Pagesbook, will be identified. Leadership theories will be used to evaluate my selected leader to determine what characteristics and leadership abilities helped this leader become successful. I will also include an evaluation of my own leadership style and identify what my individual leadership characteristics are. The plan will be developed to improve my leadership style based upon the findings of my chosen leader’s leadership style compared to my own. Leadership Style Leadership influences a group ofRead MoreThe Leader as Mentor: Jesus Christ Essay1366 Words   |  6 Pages and commissioned (Willson, 1990). His methods were unconventional and revolutionary for that time. Training was extensively and exclusively provided by Jesus while living with Him for three years prior to His ascension. He taught about servant leadership and its meaning for both the leader and follower (Matt. 20:25-28). An examination of His actions in the Gospels showed that Jesus left behind the transferable patterns to be replicated. His methods included the incorporation of three different levelsRead MoreModern Management752 Words   |  3 PagesModern Management Management Peter Spurgeon and Robert Cragg (2007) contend the current attention paid to the importance of leadership has diminished the value and contribution of management. The discussion concerning leadership and management, at the most extreme, is inclined to portray leadership as good and management as bad. These constraints are rooted in the proposition that people do not want to be managed, with its connotations of bureaucracy and control, but are happy to followRead MoreFollowership For A Group Of International Visitors From Saudi Arabia1003 Words   |  5 Pagesidea how it harmonious with leadership. The main point of my speech is â€Å"The followership is also important element like leadership in group†. The structure of my presentation is like below. Overview 1. Hook Question to the audience. â€Å"Leading and Following which do you think more important?† The concept of followership has a very important part to play in the success of any group task. However, this is often forgotten. This reflects modern culture’s emphasis on leadership and its tendency to overlookRead MoreCustomer Service And Employee Satisfaction1604 Words   |  7 PagesGood leadership is a key characteristic associated with business in today’s society. It can be said that good leadership directly relates to the quality of business. Meaning that the better the leadership, the better the business. Quality leadership one of the major keys of developing good customer service and employee satisfaction. Considering obedience defines whether we obey or disobey the authority, many individuals today have no choice but to obey. Leaders of businesses are far along being autocraticRead MoreCharacteristics Of Leadership And Group Essay974 Words   |  4 PagesObjectives of the study To find out the characteristics of leadership and group them in IT and Non-IT organizations. Significance of the Study This study aims at identifying and comparing the leadership characteristics of managers working in IT and Non-IT organizations. It also tries to examine the influence of leadership characteristics of managers on organizational superiority mediated through the intervening variables like organizational transformation and organizational culture, together described

William Shakespeare s Romeo And Juliet - 1197 Words

Hayley Beckmann Beckmann 1 May 8, 2016 ENGL 1312 70 Mr. Oliver The Love that Changed Everything Two families at war, a love so forbidding it’s deadly, referring of course to the classic William Shakespeare play of â€Å"Romeo and Juliet†, set in Verona, Italy. The play examines two families, the Montauges and the Capulets caught in an ongoing battle of hate, however two of the children manage to find love. All is not fair in love and war, and this play examines some examples of how love and hate correlate to each other in this captivating tale of â€Å"Romeo and Juliet†. It’s a feud so deep and long lasting it seems that nothing can keep these families from fighting. The play opens up with a scene where two servants of the house of Capulet run into some servants of the house of Montauge on the street. Sampson one of the Capulet servants states â€Å"Nay, as they dare I will bite my thumb at them, which is a disgrace to them if they bear it† (Shakespeare 7). We see early on that the feud isn’t just family fighting, but also the se rvants. Tybalt one of Juliet’s cousins known to be hot headed when it comes to the Montagues, he walks up to the servants and states with his sword drawn â€Å"what, drawn , and talk of peace? I hate the word As I hate hell, all Montagues, and thee,† (Shakespeare 8) from early on Shakespeare wants the reader to Beckmann 2 understand just how much the two families hate each other and how they canShow MoreRelatedWilliam Shakespeare s Romeo And Juliet1287 Words   |  6 PagesLizzy Baginski English Composition 2 Mr. Spera March 10, 2015 Romeo and Juliet Research Paper The movie Romeo and Juliet is a modern classic film that took place in 1996. Overall this is a timeless story that everyone should go and watch. This movie has an intriguing plot line that tells the story of two feuding families, The Montagues and The Capulets, and how the children of these two different families fall in love. The two children overcome various obstacles such as hiding their chemistry fromRead MoreWilliam Shakespeare s Romeo And Juliet 966 Words   |  4 Pages Beauty Over Gold â€Å"Beauty provoketh thieves sooner than gold.--William Shakespeare, 1623. In his book As You Like It, William Shakespeare pointed out the supremacy of love rather than the want of gold and wealth. Truly, beauty is more important to thieves than wealth. Many of the thieves in this world would rather have an elegant woman than to obtain precious rubies. After all, what good is a prosperous man if he doesn’t have a charming woman? Two famous men grab my attention who didn’t fear forRead MoreWilliam Shakespeare s Romeo And Juliet Essay1024 Words   |  5 PagesRomeo and Juliet is a tragedy written by William Shakespeare early in his career about two young star-crossed lovers whose deaths ultimately reconcile their feuding families. It was among Shakespeare s most popular plays during his lifetime and, along with Hamlet, is one of his most frequently performed plays. Today, the title characters are regarded as archetypal young lovers. Romeo and Juliet belongs to a tradition of tragic romances stretching back to antiquity. The plot is based on an ItalianRead MoreWilliam Shakespeare s Romeo And Juliet1124 Words   |  5 PagesThe play Romeo and Juliet is a tragedy written by William Shakespeare early in his career about two young star-crossed lovers whose deaths ultimately reconcile their feuding families. It was among Shakespeare s most popular plays during his lifetime and, along with Hamlet, is one of his most frequently performed plays. Today, the title characters are regarded as archetypal young lovers. Romeo and Juliet belongs to a tradition of tragic romances stretching back to antiquity. Its plot is based onRead MoreWilliam Shakespeare s Romeo And Juliet861 Words   |  4 Pagesgreatly shown in the play Romeo and Juliet by William Shakespeare. It was love at first sight with Romeo Montague and Juliet Capulet. Meeting at a party and falling in love to get married without even spending quality time with each other. Romeo and Juliet couldn t tell there parents because the Capulets and Montagues are long term rivals. Both Romeo and Juliet had to find different ways and excuses to make this marriage work. A big problem was developed. Romeo kills Juliet s cousin and is banishedRead MoreWilliam Shakespeare s Romeo And Juliet1770 Words   |  8 Pagesof Romeo and Juliet. The story of two destined lovers who were killed by their own doing. But what if they weren t two destined lovers who got unlucky, but doomed partners that were never going to have a good-life to begin with.William Sha kespeare gives us a view of early signs of gang conflict in the early age of Verona, Italy. He gives us a perspective of the norms and customs of Italy during the Setting of William Shakespeare s most famous story. Romeo and Juliet, by William Shakespeare, givesRead MoreWilliam Shakespeare s Romeo And Juliet1616 Words   |  7 Pageslove can also cause some of life s most controversial battles. These battles could stem from lack of patience, disagreement of moral values, and in some cases, an absence of attraction overall. In Romeo and Juliet by William Shakespeare, the issues that drive Romeo Montague and Juliet Capulet s to each of their dreadful misfortunes are inevitable. When it comes to many of Shakespeare s plays, Aristotle s theory is used to describe them as tragedies. Romeo and Juliet is known by many as a tragedyRead MoreWilliam Shakespeare s Romeo And Juliet1264 Words   |  6 Pagestheater-going public the most important dramatist in English literature, Shakespeare oc cupies a well-known position in the world of talented authors. His canon contains thirty-seven plays, written in the late sixteenth and early seventeenth centuries. Additionally, throughout the years, they continue to sustain critical attention, with the majority of his works circling tragedies, one being Romeo and Juliet. William Shakespeare s Romeo and Juliet speaks to the timeless appeal of star-crossed lovers. Their loveRead MoreWilliam Shakespeare s Romeo And Juliet924 Words   |  4 PagesWilliam Shakespeare’s Romeo and Juliet is a tragedy that follows the so-called love of two teenagers. The two fall in love at a masked ball and have a secret marriage. Throughout the play, their actions show how ridiculous love is, and how it is a danger to anyone who become twisted in its choking grasp. However, in the death of the youth and survival of the elders, an alternative explanation for the tragic events may be found. Although Shakespeare seems to be mocking love throughout the play, itRead MoreWilliam Shakespeare s Romeo And Juliet1279 Words   |  6 Pagesour lives. The great, classic writers teach timeless, valuable life skills. Shakespeare was the greatest writer of all time. His writings mainly consisted of dramas and sonnets. Romeo and Juliet, as well as, A MIdsummer Night’s Dream were written about the same time period. He was able to inter relate everything that wrote. For example, the tale of Pyramus and Thisbe could possibly be an advertisement for Romeo and Juliet. The basic structure of the two dramas is the same; two forbidden lovers meet

Portfolio Successful Completion

Questions: 1. Create a document called Successful Completion andwrite a reflective analysis that demonstrates you have satisfied all eight(8) course learning outcomes that are listed in the course profile for COIT20249 Professional Skills in ICT (they are listed below). In no more than two (2) A4 pagesjustify how the work you have completed this term has satisfiedall eight (8) course learning outcomes.Please note it is important that you JUSTIFYthat you have satisfied the course objectives do NOTjust summarise the course content and/or assessment items OR define the course learning outcomes. 2. Write two things you liked about this course and provide the reason or reasons you liked them. Also describe two suggested improvements to the course and justify why they would improve the course. Upload the Successful Completion document into Moodle. Answers: Part A Justification of fulfilling the course objectives after the proper completion of the course After the proper completion of the two courses (COIT20233 and COIT20249) I have effectively taken in the eight diverse learning results of the two courses. The written notes given in the classes and the online course substances were extremely useful to the successful achievements of the goals of these two courses. The eight distinctive learning results and the method for finishing the course substance are discussed in the underneath area: The primary goal of these courses was regarding the viable interpersonal aptitudes, dynamic listening and perusing. The learning materials supplied in the classes were truly helpful to satisfy this target. In order to complete the assignments of the courses I had to listen carefully to the teacher and from that point a great deal of viable perusing helped me to finishing my assignments. Along these lines I have taken in the fancied significance of the interpersonal abilities and the dynamic listening and perusing. The second target was to show the cooperation aptitudes. There were some assignments in the course, which need an effective team work to be completed. In order to complete these types of team work related assignments, I have learnt the way of conducting the team work and how to communicate with the team members for achieving the corporate objectives. The third target was to take in the viable verbal and composed presentation by utilizing appropriate dialect. Again the courses lecture notes and learning materials supplied in the classes helped a lot for enhancing verbal and written skills. The assignments written by us in the diverse times of the course are exhibited in a well frame utilizing suitable dialect. These types of practices helped me to enhance myself in the particular region. The fourth target was building up the oral presentation aptitudes. I have given many presentations throughout the whole course. These presentations helped me to develop my presentation and oral skills for a better professional career development. The ICT business has a few morals and codes of conduct and numerous authoritative issues in the territory of working. Understanding and utilizing these codes was the fifth objective of the course. The course content with the assistance of the morals exhibited by the Australian Computer Society helped me in this field. The practical work practices conducted in this course were related to the context of Australian environment. Through these practical work practices, I have comprehended the working pattern and the estimation of Australian working environment. In the course content, there were some errands which were included in determining a few issues of various sorts of associations with the assistance of the ICT instruments. I could resolve and exhibit the method for determining the issues of the authoritative procedures by the successful utilization of the ICT apparatuses. The method for correspondence and the communitarian works has been changed. At present, the entire world is especially subject to the rising innovation. These particular two courses are online courses and the method for contemplating and speaking with the general population helped me to comprehend the use of latest technologies in the learning through the internet technology. Part B Feedback section The internet learning gives loads of advantages to the understudies. The methodologies of these two online courses are extremely compelling to the learning and supported me such a great amount to satisfy the goal of finishing the courses. The primary themes of these two courses are the ICT innovation and Professional aptitudes. I have built up a decent technique for building up my expert aptitudes and the course made a future arrangement about how to function in the Australian working environments by keeping up the all the moral contemplations and the administrative issues. The method for learning through the present day approaches and useful application is great. The utilization of ICT apparatuses are all over the place in the current world. The courses helped me such a great amount with the rehearsing of pragmatic explain for the diverse sorts of hierarchical issues through the inventive utilization of the ICT apparatuses. The methodology of building up the reasonable thought regarding the utilization of the ICT apparatuses by the commonsense lesson is great. Everywhere throughout the arrangement of the two courses are great, however a few changes in a portion of the segments of the courses might be useful for the course. The useful practices of the employments of the ICT innovation are great yet the acts of the self-improvement and the presentation aptitudes ought to be more enhanced for better learning. Another region which may be more improved is the course content. Some instruments of the ICT are utilized for the learning reason of these two courses which are not currently using in the modern edge of technology. As the genuine situation of the ICT innovations are changing much of the time, the courses ought to embrace the state-of-the-art innovation in their course substance.

Slides Essay Example

Slides Essay Slide 2(Population).   With a little under half of the population being college youth and about a third of the population being African American, they Tallahassee still remains heavily segregated in nature.Slide3 (Complex Impression) My first impression of Tallahassee was very complex.   The town consisted mostly of young people, and daily concerns were based entirely on football game and parties, so I found it to be very fun, but then a I gradually noticed how segregated the town was.   It was commonly referred to as Southern Georgia, because a lot of visitors from out of town said they forgot they were in Florida when they were in Tallahassee.Slide4 (FSU vs FAMU) Another thing I began to notice was the major economic differences between the two Universities.   While Florida State was heavily funded,   FAMU the historically black college was struggling to stay in business. The separate campuses were completely opposite to one another.   All of FSU’s buildings are brand new and more are under construction.   Whereas FAMU’s buildings are run down and the campus is I the center of the poorest part of town.Slide5 (irony in Leaders)   John Marks to the left is the Mayor of Tallahassee, though he is black his position more for show in the fact that he has no veto power and his vote is only worth one vote in the city commission.   Bobby Bowden, on the other hand, has been Florida State’s head football coach since back when Jim Crow was still legal. He is paid more than a million dollars a year and earns three times that off the field through endorsements.   He is praised as the single most important figure in Tallahassee, and at Florida State; and with all the money he brings the school he has a higher standing than the President of the University himself.   This makes Bobby Bowden more like the actual mayor of the town considering that Florida State is the source of the Majority of Tallahassee’s income.Slide6 Martha Minow is a theorist who deals with race and sociology.   (just read the slide)Slide7 Susan Opotow is a theorist   who deals with dispute resolution. (just read slide)Slide10 My closing argument is that I think it is the responsibility of the Tallahassee government to care for the wellbeing of the FAMU students. I think that cultural diversity is a precious part of our nation, and it should be valued.   I think the United States has come a long way since 1776, and we should continue to expand our views.   We should work to nurture historically black colleges like F.A.M.U.; in the hopes that one day if they were to merge with a good old boy University like Florida State, they would accomplish something more than just the abolishment of a racial divide, but form an academic institute equally beneficial to both parties.   Neither one should be a financial burden to the other.   Each can be a scholastic super power in their own right.   If I had the power, this would be my aspiration.

Teaching the Compare and Contrast Essay

Teaching the Compare and Contrast Essay The compare/contrast essay is easy and rewarding to teach for several reasons: Its easy to convince students there is a reason for learning it.You can teach it effectively in a few steps.You can see students critical thinking skills improve as they learn to write the essay.Once mastered, students feel proud of their ability to systematically compare and contrast two subjects. Below are the steps you can use to teach the compare/contrast essay. They have been used in regular high school classes where reading levels ranged from fourth to twelfth grade. Step 1 Discuss practical reasons for comparing and contrasting.Discuss reasons for learning to write about similarities and differences. Selecting subjects that matter to students is critical for this step. For example, one might be to compare two models of cars and then write a letter to a benefactor who might buy them one. Another would be a store manager writing to a buyer about two products. Academic topics such as comparing two organisms, two wars, two approaches to solving a math problem may also be useful. Step 2 Show a model compare/contrast essay. Explain that there are two ways to write the essay but dont go into any detail on how to do it just yet. Step 3 Explain compare/contrast cue words. Explain that when comparing, students should mention differences but focus on similarities. Conversely, when contrasting they should mention similarities but focus on differences. Step 4 Teach students how to use  compare/contrast charts. You should plan to spend a few classes on this. Although it seems simple, students doing it for the first time perform better if they arent rushed through this step. Working in teams, with a partner, or in a group is helpful. Step 5 List and model the Writing Dens  cue words  to show similarities and differences. Many tenth graders have difficulty thinking of these words if this step is skipped. Provide model sentences with these words which they can use until they become comfortable with them. Step 6 Explain charts showing how to organize compare/contrast  paragraphs  and  essays. Have students write the block style first since it is easier. Students should be told that the block is better to show similarities and the feature-by-feature is better to show differences. Step 7 Provide guided practice in writing the  first draft. Guide students through their first essay providing help with an introduction and transition sentences. It is helpful to allow students to use a chart they have completed as a class or one that they have done independently and  that you have checked. Do not assume they understand the chart until they have done one correctly. Step 8 Provide in-class writing time. By giving in-class writing time, many more students will work on the assignment. Without it, students with little motivation may not write the essay. Walk around asking who needs a little help to get more participation from reluctant learners. Step 9 Review the steps in the  writing process.Review editing suggestions and give time for  revision. Explain that after writing their essay, students should edit and revise. They should continue the cycle of editing and revising until they are satisfied with the quality of their essay. Explain the advantages of revising on the computer. For  editing  tips, check  these suggestions for revising drafts  from the University of North Carolina Writing Center. Step 10 Review the  SWAPS Proofreading Guide  and give students time to proofread their essays. Step 11 Have students evaluate their peers essays using a  Compare/Contrast Rubric. Staple a rubric to each essay and have students evaluate them. Be sure to check off on a roster the names of students who turn in essays because they could be stolen during the peer evaluation activity. Consider requiring students who have not finished to submit their essay for peer evaluation after writing  Not Finished  at the top of their papers. This helps peers recognize that the essay is incomplete. More importantly, taking their paper forces them to participate in the evaluation activity rather than trying to finish the essay in class. Consider giving 25 points each for evaluating three essays and another 25 points for quiet participation. Step 12 Review the proofreading guide briefly and then devote half a period to proofread one anothers essays. Tell students to read their essay aloud or to have someone else read it to them to catch any errors. Have students proofread several essays and sign their names at the top of the paper: Proofread by ________.

Free Essays on Immigrants Or Minorities

Hispanics as a minority or as immigrants; I believe this to be an answer that is looked upon differently by different peoples opinions. In my opinion, I believe that Hispanics are as much a minority group as are African Americans. Sure, at one time I agree that they were immigrants; they did of course migrate here from Mexico and the various outlying Hispanic countries, whether legally or illegally. Hispanics have been fused so much into American culture that they are now truly a minority group that look to soon overtake the African American population. Many of their cultures have fused together with American culture. Take for example, the many Mexican restaurants in our area; this food has become a way of a lot of people’s lives in the area. Music would be another example, take Carlos Santana for instance, a Latino rock guitarist who has combined Rock & Roll with Latin music, and his music is very well received by American listeners. I myself was born and raised in Miami, which has a very dominant Cuban population, American and Hispanic cultures have intertwined so much in South Florida over the last few decades that any child born within the past 15 years or so would have a hard time distinguishing one culture from the other. Spanish is like a second language to many people and in several places you must be able to speak Spanish if you expect to get by. Cubans aren’t the only Hispanics in South Florida; there are Puerto Ricans, Central Americans, and South Americans as well. They are not as dominant as the Cuban population is but nevertheless they are indeed Hispanics as well. I think that a multi-cultural country is a good thing; it opens your eyes to new experiences and new ways of life. A person gets to see how other cultures work. But of course there are many people who would disagree. Unfortunately many Americans are still racially biased towards Hispanics as well as African Americans, these people I believe are afraid... Free Essays on Immigrants Or Minorities Free Essays on Immigrants Or Minorities Hispanics as a minority or as immigrants; I believe this to be an answer that is looked upon differently by different peoples opinions. In my opinion, I believe that Hispanics are as much a minority group as are African Americans. Sure, at one time I agree that they were immigrants; they did of course migrate here from Mexico and the various outlying Hispanic countries, whether legally or illegally. Hispanics have been fused so much into American culture that they are now truly a minority group that look to soon overtake the African American population. Many of their cultures have fused together with American culture. Take for example, the many Mexican restaurants in our area; this food has become a way of a lot of people’s lives in the area. Music would be another example, take Carlos Santana for instance, a Latino rock guitarist who has combined Rock & Roll with Latin music, and his music is very well received by American listeners. I myself was born and raised in Miami, which has a very dominant Cuban population, American and Hispanic cultures have intertwined so much in South Florida over the last few decades that any child born within the past 15 years or so would have a hard time distinguishing one culture from the other. Spanish is like a second language to many people and in several places you must be able to speak Spanish if you expect to get by. Cubans aren’t the only Hispanics in South Florida; there are Puerto Ricans, Central Americans, and South Americans as well. They are not as dominant as the Cuban population is but nevertheless they are indeed Hispanics as well. I think that a multi-cultural country is a good thing; it opens your eyes to new experiences and new ways of life. A person gets to see how other cultures work. But of course there are many people who would disagree. Unfortunately many Americans are still racially biased towards Hispanics as well as African Americans, these people I believe are afraid...

Economics-Market Power, Oligopoly, Monopoly Essay

Economics-Market Power, Oligopoly, Monopoly - Essay Example Depending on the premise and circumstances of the discussion it can be reasonable to argue that competition is socially harmful as compared to market power. However, the argument against competition is very weak since empirical evidence and data shows the competition has more economic benefits and support for the development of the market than a single firm holding and dominating market power over an industry. This is because there are several benefits which can be gained from having some competition in a market. For instance, competition may force prices to go down for the consumer if a lower cost producer competes in the market. Additionally, a better product might be entered into the market with actually superior or perceived superior quality. The combination of these two factors can create products which are innovative, desirable and can cause the emergence of brands within an industry. At the same time, competition may be unnecessary or wasteful if the product differentiation is very low. For instance, the battle between Coke and Pepsi for market share seems to be wasteful since the products they are marketing are very similar to begin with. However, advertising can be socially effective when the products are dissimilar and offer different benefits as in the case of computer operating systems like the ones created by Apple, Microsoft and Linux.

A Dialogue Over Marijuana And Its Characteristics Assignment

A Dialogue Over Marijuana And Its Characteristics - Assignment Example So I reached my classroom, drew a marijuana leaf, for class 11 students they thought in their current affairs class they would be discussing biology. However, they were soon proved wrong to their utter surprise. I stood firm to the ground and raised the following question to the students: â€Å"Who here thinks that Marijuana should be legalized in Europe and the rest of the world†? Many of them did not know what I was talking about, so I explained the herb and its characteristics. As everyone else would have thought, they came to the conclusion that this was a drug and they better stay away from it. Which was the point basically. However, quite of a few of them wanted to know about it more and wanted to try it before making any judgements about it. One kid asked the obvious question which was going to come up sooner or later. â€Å"Is it our right to smoke Marijuana?† Well, that question brought me back to the various arguments and confrontations I have had with people over the legal right to smoke Marijuana. ... I told my students that freedom always comes at a price. If you are willing to pay the price then you can go ahead and enjoy the freedom. However, it is pertinent to note that people in my class were reluctant to question the system as it stood there. Not many of them really thought that it was worth the spending time. I mean, why would anyone want to indulge in an illegal activity of smoking pot when one knows that he can be arrested for this? Not many were willing to take th steps and I don’t blame them. Introspection: The reason why I spoke about marijuana is very peculiar to what I think is the true value of freedom. In today’s world there are quite a few rebels out there. Not many peple aer ready to question he system and those who do have no understanding or aim to reach somewhere. Marijuana is long been known as a recreational drug. It is not really a drug, but a more recreational medicine which was used abundantly in medieval India. People in India like sadhus a nd saints used to smoke this leaf over and over again and derived great pleasure out of this. They were extremely intellectual and were always ahead of their times, not because they smoked pot, but because they were inherently like this and it catapulted them to smoking pot for recreational usage. The irony has become now that the USA whose ideology was founded by men who smoked pot ended up banning the same drug. They were not ready to allow its existence, mostly because at that time due to the external industrial forces smoking marijuana had already become an illegal and taboo thing to do. Reaction: As a teacher I am always on the lookout for students that have the knack to do something about their present in order to improve their future and utilize the best of every

The strategic plans of Procter and Gamble Essay Example for Free

The strategic plans of Procter and Gamble Essay INTRODUCTION   Ã‚  Ã‚  Ã‚   This study is being undertaken in order to review the strategic plans of Procter and Gamble. The Human Resource activities of the company will be identified including their estimated costs and benefits. Also, the study will identify the strategic activities and how it match the strategic goals of the company.   Ã‚  Ã‚  Ã‚   Finally, this study will formulate recommendations on how the organization might better match its human resource activities with its strategic benefits. COMPANY BACKGROUND   Ã‚  Ã‚  Ã‚   Procter and Gamble Company is a U. S. based global corporation based in Cincinnati, Ohio. It manufactures a wide range of consumer goods. The company is the 25th largest U.S. company by revenue in 2007. It is the 18th largest by profit, and 10th in Fortune’s most admired companies list as of 2007.   Ã‚  Ã‚  Ã‚   The company was founded by William Procter, a candle maker, and James Gamble, a soap maker in 1837. These two men were immigrants from England and Ireland respectively. The company grew tremendously and throughout the twentieth century, it continued to prosper. The firm expanded into other countries and introduced Tide laundry detergent in 1946 and â€Å"Prell† shampoo in 1950. In 1955, the company began selling its first toothpaste to contain fluoride which is known as â€Å"Crest† (Dyer et al., 2004).   Ã‚  Ã‚  Ã‚   Currently, the company is ranked in the top ten by the Harris Interactive/Wall Street Journal list of companies with the world’s best reputation, the number one ranking in Fortune’s U.S. Household and Personal Products most admired list. It is ranked number two on the Hay Group list of Best Companies for Leaders, and the Market Sector Leader for Household Products in the Dow Jones Sustainability Index (PG Annual Report, 2007).   Ã‚  Ã‚  Ã‚   PG ranks among the top companies for Executive Women (National Association for Female Executives), African Americans (Working Mother and Women of Color Magazines), Working Mothers (Working Mother Magazine), and Best Corporate Citizens (Business Ethics Magazine) (Ibid).   Ã‚  Ã‚  Ã‚   Supplier diversity is a fundamental business strategy of the company. In 2007, the firm spent over $1.9 billion with minority-and women-owned businesses. It is a member of the Billion Dollar Roundtable, a forum of 14 corporations that spend more than $1 billion annually with diverse suppliers (Ibid). Overview of Operations   Ã‚  Ã‚  Ã‚   The business of Procter and Gamble is focused on providing branded consumer goods. The company’s goal is to provide products of superior quality and value to improve the lives of consumers around the world. The company believes that this will result in leadership sales, profits and value creation, allowing employees, shareholders and the communities in which the company operate to prosper (Ibid).   Ã‚  Ã‚  Ã‚   The firm’s products are sold in more than 180 countries mainly through mass merchandisers, grocery stores, membership club stores and drug stores. It is continuing to expand their presence in â€Å"high frequency stores,† the neighborhood stores which serve many customers in developing markets. The firm on-the-ground operations in over 80 countries. The market is highly competitive, with global, regional and local competitors. In most markets and industry segments wherein the company is selling their products, it compete against other branded products as well as retailers’ private-label brands. In addition, many of the product segments in which it compete are differentiated by price. Essentially, Procter and Gamble compete with premium and mid-tier products and are well positioned in the industry segments and markets in which it operates. It is most often holding a leadership or significant share position (Ibid). Organizational Structure   Ã‚  Ã‚  Ã‚   Currently, the organizational structure of the company was comprised of three Global Operations Units (GBUs) and a Global Operations group. The Global Operations group includes the Market Development Organization (MDO) and Global Business Services (GBS). The heads of the three GBUs and Global Operations each would report to the Chief Executive Officer (Ibid). Global Business Units   Ã‚  Ã‚  Ã‚   During 2007, the three GBUs were Beauty and Health, Household Care and Gillette GBU. The main responsibility of the GBUs is to develop the overall strategy of the brands. They identify the common needs of the consumer, develop product innovations, marketing and sales. In the United States, the business units comprising the GBUs are integrated into seven segments: Beauty; Health Care; Fabric Care and Home Care; Snacks, Coffee, and Pet Care; Blades and Razors; and Duracell and Braun (Ibid). Growth and Strategies   Ã‚  Ã‚  Ã‚   Procter and Gamble’s sales have grown from $39 billion to $76 billion in the past seven years. The firm have more than doubled the number of brands that generate $1 billion or more in sales each year, and now have 23 of these leading billion-dollar brands in its portfolio. The company also have more than quadrupled the number of brands that generate at least $500 million in sales, and today have 18 of these brands poised to be the next billion-dollar brands. The firm have nearly doubled the number of countries in which it generates a billion dollars or more in sales each year, and now have 12 billion-dollar countries (Ibid).   Ã‚  Ã‚  Ã‚   Procter and Gamble (PG) have more than a billion dollars in sales each year with seven retail customers, up from two in 2001. PG have generated more than $43 billion in net earnings and $50 billion in free cash flow. PG’s   market capitalization has increased more than $100 billion since 2001. Currently, the company is among the ten most valuable companies in the United States (Ibid).   Ã‚  Ã‚  Ã‚   Procter and Gamble designed a diversified business portfolio to grow consistently and reliably. It designed its core strengths to win in the industry. It designed strategic, operational, and financial processes that ensure discipline to deliver. It also designed a management team and organization to lead (Ibid). 2007 Results of Activities   Ã‚  Ã‚  Ã‚   The year 2007 brought results to the company’s strategic plan for growth. It was the most demanding year that the company faced since the beginning of the decade. As energy and commodity costs continued to rise, competitive pressure also intensified. Nevertheless, the company continued to grow well and attained its target growth range. The following were the highlights of its operations: Net sales increased 12% to $76 billion. Organic sales increased 5%. Diluted net earnings per share increased 15% to $3.04. Free cash flow from operating activities was $10.5 billion, or 101% of net earnings. Fabric and Home Care grew organic sales 8%, with double-digit growth in developing markets and mid-single-digit growth in developing regions. The key growth drivers included Tide Simple Pleasures, Gain Joyful Expressions, and Febreze Noticeables. Blades and Razors organic sales grew by 8%. Beauty organic sales increased 5%, led by strong growth in feminine care, prestige fragrances, and hair care. Billion-dollar brands Always, Olay, and Head Shoulders each grew sales double-digits for the year. Health Care organic sales incremented 6% which is driven by very strong growth in oral care. In the United States, Crest extended its category market leadership to 38% behind the success of the Pro-Health line. Baby and Family Care organic sales increased 4%. This growth was due to the continuing expansion into developing markets and robust results on Pampers Baby Stages of Development and Baby Dry Caterpillar Flex products in North America.   Ã‚  Ã‚  Ã‚   Growth across geographic regions was also broad-based. This was led by mid-single-digit organic volume growth in North America and double-digit organic growth in developing markets. Also, it made excellent progress on the integration of Gillette. This was the biggest acquisition in the consumer products industry and in the history of the company (Ibid). Growth Strategies, 2001-2007   Ã‚  Ã‚  Ã‚   The basic strategy is to grow from its core competence. This is done through maximizing on its leading brands, big markets, and top customers. Specifically, this strategies are as follows (Ibid): Volume up 7% on average, for PG ‘s 23 billion dollar brands; Volume up 8% on average, for PG’s top 16 countries; Volume up 8% on average, for PG’s top 10 retail customers. Develop faster-growing, higher-margin, more-asset efficient businesses and this is done specifically through: Beauty sales doubled to $23 billion profit more than doubled to $3.5 billion; Health Care sales more than doubled to $9 billion; profit increased 6-fold to $1.5 billion; Home Care sales up nearly 85% profit more than tripled.   Ã‚   Accelerate growth in developing markets and among low-income consumers as follows: Developing market sales up 18% per year; Over one-third of total company sales growth from developing markets; Developing market profit margins comparable to developed market margins. New Strategic Design   Ã‚  Ã‚  Ã‚   The first element of the company’s strategic design is a portfolio that balances growth and consistency.   Ã‚  Ã‚  Ã‚   In the 1990’s, two businesses accounted for 85% of all the value created by the firm through the decade. Today, the firm have a much stronger and more robust business portfolio. It is competing in 22 categories that include a balanced mix of faster growing, higher-margin asset-efficient businesses, such as beauty or home care, and large, foundation categories such as laundry, or baby care. PG also have an attractive geographic mix, with about half coming from the rest of the world. The firm is focusing on achieving disproportionate growth in fast-growing developing markets. These markets have contributed more than a third of the company’s top-line growth over the past five years, and their contribution has been accelerating. Nearly 40% of PG sales growth came from developing markets this past fiscal year, and it is expected that the contribution would be even greater in the year ahead. The company’s diversified portfolio reduces exposure to single and competitive events, and maximizes future growth opportunities. Traditional businesses, like fabric care and baby care, are strong and growing in their own right, and they create scale that makes PG’s beauty and health care businesses more competitive (Ibid).   Ã‚  Ã‚  Ã‚   Geographically, the firm’s North America home base is rock solid, with dependable growth that allows them to invest in developing markets. Also, the breadth and diversity of the firm’s businesses and the breadth and diversity of the technological expertise that supports these businesses enable the company to transfer technologies from one business to another. For example, Crest Whitestrips was created by combining bleach stabilization technology from laundry care with film technology from corporate Research and Development (RD) to provide in-home teeth whitening. The Swifter Wet Jet pad combines absorbent cores from feminine care with flexible surface lawyers from baby care. Olay Daily Facials combines structured paper from family care with skin conditioning and mild cleansing from beauty to provide a mini-facial in the home. The company’s ability to combine technologies from so many diverse businesses cannot be rivaled in the industry because no other consumer products company has the scope of science and technology found at PG. The firm’s business portfolio is not static. It uses the operating total shareholder return (TSR) delivered by each business to continuously ensure its portfolio is maximizing shareholder value. TSR is a cash flow return on investment (CFROI) model that measures sales growth, earnings growth and cash flow to determine the rate of return that each business earns (Ibid).   Ã‚  Ã‚  Ã‚   The firm’s researchers and entrepreneurs around the world working in areas that are relevant to their business. They are establishing the company as the preferred commercialization partner for these external innovators, and it is making a huge impact. The firm’s ability to innovate is most evident in the net present value of its innovation pipeline and the organic incremental sales growth generated by innovation. Innovation-driven value creation for shareholders and incremental sales growth from innovation have nearly doubled in this same time period (Ibid).   Ã‚  Ã‚  Ã‚   These are just two examples of how the company designed an institutional capability to grow. The firm’s core strengths create sustainable competitive advantages, and it is continuing to get stronger in every area.   Ã‚  Ã‚  Ã‚   The third element of the company’s design for growth is the disciplined way it managed its business. Discipline is part of the company’s culture and it is applied to every aspect of the business: strategic, operational, and financial. The company set and stick with clear strategies. It does its homework before going to market with new products and ideas (Ibid).   Ã‚  Ã‚  Ã‚   The second element of the firm’s design for growth is its combination of core strengths. Early in the decade, the firm determined that it did not have sufficient competitive advantage in the five areas that are critical to winning in consumer products: consumer understanding, brand building, innovation, go-to-market capability, and scale. It invested substantially in every area and it is paying off. For example, the company invested more than a billion dollars in consumer understanding since 2001. It transformed one of the industry’s more traditional market research organizations into a consumer understanding powerhouse. Its external benchmarking indicates that the company has the industry’s strongest suite of proprietary consumer research tools and methodologies. These tools make the firm learn faster and more effectively, and it helps discover the often unarticulated needs and aspirations that lead to breakthrough innovation (Ibid).   Ã‚  Ã‚  Ã‚   Innovation has always been the firm’s lifeblood, and it created significant advantage in this area. It has the best-in-class expertise in about a dozen technology areas that are the foundation for innovation in the industry, including enzymes, perfumes, and flavors, polymers, structured substrates, and surfactants. The firm multiplied this internal capability through an effort we call â€Å"connect + develop,† which is proving to be an enormous source of innovation and competitive advantage. It has about 8,500 researchers within the company and another 1.5 million outside the company (Ibid). Strategic Focus   Ã‚  Ã‚  Ã‚   The growth strategy of the company will exploit opportunities focusing on these areas: PG’s Core. The firm is widening its share advantages versus competition. For example, in fabric care, it is the number two player worldwide in the early 1990s. Today, the firm has a 34% share of the global fabric care market, almost double the next competitor, and its share has grown for six consecutive years. There are plenty of opportunities to keep growing all of the company’s billion dollar brands. It is proving in category after category that a leading share, even a relatively high share, is not a barrier to growth. The company aims to continue leverage its brand line-up and category-leading innovation to keep core businesses healthy and growing. Faster-Growing. Higher-Margin Businesses. The company has even greater upside in businesses such as beauty and health care. The beauty and health categories in which PG competes are   a combined $360 billion market today, and are projected to grow 3% to 4% a year for the balance of the decade. The firm has almost doubled its share of beauty and health over the past decade although the firm’s share of this combined market is only about 10% globally. Developing Markets and Lower-Income Consumers. The firm can still grow significantly in developing markets by increasing household penetration and consumer usage frequency, and by entering categories   where it has not yet competed. For example, the average U.S. householder buys five to ten times as much PG product per year as the average household in developing markets. In addition, there is a large number of households in developing regions that do not yet purchase any PG product. Closing this gap, the company is confident that it can do it over time. It will continue to drive strong growth for years to come. There are significant bottom-line growth opportunities as well. The firm will continue to leverage its economies of scale. It will reduce overhead costs by simplifying work and eliminating duplication between global business units and market development organizations. It will be more effective and efficient in how it will manage smaller country organizations and brands. It will continue to increase productivity in all of its businesses. It will continue to improve gross margins. The company’s current margin is about 52% (Ibid). Human Resource Management   Ã‚  Ã‚  Ã‚   Procter and Gamble have the most diverse and broadly experienced leadership team in its history. The top 45 leaders came from a dozen countries, and most of them have experience leading businesses in both developed and developing markets (PG Annual Report, 2007).   Ã‚  Ã‚  Ã‚   The firm is proud that they have recognized as one of the world’s best leadership development companies. PG have been ranked as one of the three best companies for leaders. Human Resources Executive magazine ranked PG as the best company among the Fortune Most Admired for â€Å"management quality†(Ibid).   Ã‚  Ã‚  Ã‚   The Human Resource department of PG have developed advanced leadership training or senior managers. The new General Manager College is targeted to the 135 general managers who run PG businesses globally. GM College focuses on Purpose and Value, leadership strategy, capabilities, systems, and culture. They have also designed a sequel to GM College which is called the Executive Leadership Program. This program is targeted to the most-senior managers in the company and focuses on agility and flexibility, embracing leading change, and sustaining growth (Ibid).   Ã‚  Ã‚  Ã‚   The firm is concerned with getting the right people into the right jobs at the right time is always a primary responsibility of management. Also, equally important and more difficult is the need to anticipate leadership capabilities that will be required in the future, and ensuring that managers get the experiences and coaching they need to be ready (Ibid).   Ã‚  Ã‚  Ã‚   One of the most visible example of the company’s ability to develop strong leaders is the number of former PG employees who are now CEOs of major companies. The president of PG himself is personally involved in succession planning for every organization in the company. They review succession plans and the progress of key leaders with the Board once a year, and with the senior management team three times a year (Ibid).   Ã‚  Ã‚  Ã‚   The human resource management values and culture of PG is reflected in their principles as follows (www.pg.com): We show respect for all individuals. We believe that all individuals can and want to contribute to their fullest potential. We value differences. We inspire and enable people to achieve high expectations, standards and challenging goals. We are honest with people about their performance.   Ã‚  Ã‚   The interests of the Company and the Individual are inseparable. We believe that doing what is right for the business with integrity will lead to mutual success for both the Company and the individual. Our quest for mutual success ties us together. We encourage stock ownership and ownership behavior.   Ã‚  Ã‚  Ã‚   We are Strategically Focused on Our Work. We operate against clearly articulated and aligned objectives and strategies. We only do work and only ask for work that adds value to the business. We simplify, standardize and streamline our current work whenever possible.   Ã‚  Ã‚  Ã‚   Innovation is the Cornerstone of Our Success. We place great value on big, new consumer innovations. We challenge convention and reinvent the way we do business to better win in the marketplace.   Ã‚  Ã‚   We are Externally Focused. We develop superior understanding of consumers and their needs. We create and deliver products, packaging and concepts that build winning brand equities. We develop close, mutually productive relationship with our customers and our suppliers. We are good corporate citizens. We incorporate sustainability into our products, packaging and operations.   Ã‚  Ã‚  Ã‚   We Value Personal Mastery. We believe it is the responsibility of all individuals to continually develop themselves and others. We encourage and expect outstanding technical mastery and executional excellence.   Ã‚  Ã‚  Ã‚   We Seek to be the Best. We strive to be the best in all areas of strategic importance to the Company. We benchmark our performance rigorously versus the very best internally and externally. We learn from both our successes and our failures.   Ã‚  Ã‚  Ã‚   Mutual Interdependency is a Way of Life. We work together with confidence and trust across business units, functions, categories and geographies. We take pride in results from reapplying others’ ideas. We build superior relationships with all the parties who contribute to fulfilling our Corporate Purpose, including our customers, suppliers, universities and governments.   Ã‚  Ã‚  Ã‚   As such, it is very clear in â€Å"Our Principles† of PG that they really value their human resources and that they value the individual, the team and their development to become leaders and their corresponding search towards excellence (www.pg.com). Employee Benefits   Ã‚  Ã‚   The company sponsor several post-employment benefits throughout the world. These include pension plans, both defined contribution plans and defined benefit plans, and other post-employment benefit (OPEB) plans, which is comprised mainly of health care and life insurance for retirees (PG Annual Report, 2007). Stock-Based Compensation   Ã‚  Ã‚  Ã‚   The company have a primary stock-based compensation plan under which stock options are granted every year to key managers and directors with exercise prices equal to market price of the underlying shares on the date of grant. A total of 229 million shares of common stock were authorized for issuance under plans approved by shareholders in 2001 and 2003, of which 73 million remain available for grant. An extra 20 million shares of common stock were authorized for issuance under a plan approved by Gillette shareowners in 2004 and assumed by the firm in conjunction with the acquisition of the Gillette Company in October 2005. A total of 14 million of the shares remain available for grant under this plan. There are also five million shares available for grant under this plan. There are also five million shares available for grant under Future Shares Plan approved by the Board of Directors in 1997. This plan will terminate in October 2007. Grants issued under the firm’s shareholder approved plans since September 2002 are vested after three years and have a 10-year life. Grants issued under these plans from July 1998 through August 2002 are vested after three years and have a 15-year life, while grants issued prior to July 1998 are vested after one year and have a 10-year life. In addition to the key manager and director grants, the company makes other minor stock option grants to employees for which vesting terms and options lives are not substantially different (Ibid).   Ã‚  Ã‚  Ã‚   Total stock-based compensation expense for stock option grants was $612 million, $526 million, and $459 million for 2007, 2006 and 2005, respectively. The total income tax benefit recognized in the income statement for these stock-based compensation arrangements was $163 million, $140 million and $125 million for 2007, 2006 and 2005, respectively. The company also makes minor grants of restricted stock, restricted stock units and other stock-based grants which are generally expensed at grant date was $56 million, $59 million and $65 million in 2007, 2006, and 2005 respectively (Ibid). Defined Contribution Retirement Plans   Ã‚  Ã‚  Ã‚   Procter and Gamble have defined contribution plans which cover the   majority of U.S. employees as well as employees in other countries. These plans are fully funded. The firm generally make contributions to participants’ accounts based on individual base salaries and years of service. The main U.S. defined contribution plan comprises the majority of the balances and expense for the firm’s defined contribution plans. The contribution rate is set annually. Total contributions for this plan approximated 15% of total participants’ annual wages and salaries in 2007, 2006 and 2005. Procter and Gamble maintains the Profit Sharing Trust and Employee Stock Ownership Plan (ESOP) to provide a portion of the funding for the D.C. plan in the United States as well as other retiree benefits. Total defined contribution expense was $273, $249 and $215 in 2007, 2006, and 2005, respectively. The accumulated benefit obligation for all defined benefit retirement pension plans was $ 8.6 billion and $8 billion at June 30, 2007, and June 20, 2006, respectively (Ibid). MATCHING OF HUMAN RESOURCES WITH STRATEGY   Ã‚  Ã‚  Ã‚   The development of key managers through the General Managers’ College of PG matched its strategy of growth and diversification as discussed above. The continuous growth of the company requires a constant supply of managerial talents. The employee benefits also matched the strategic goals of the company since these benefits are the motivators that will make the employees and managers work hard since the company spends a lot of money for their insurance, health care, pension plan, and stock-based compensation wherein the company spends billions of dollars.   Ã‚  Ã‚  Ã‚   Also, the â€Å" Our Principles† of the company as discussed above is also supportive of the strategy of the company wherein these principles promote a culture of independence and at the same time work as a team. It also encourages hard work and excellence for employees in their jobs. RECOMMENDATIONS   Ã‚  Ã‚   PG is an excellent company. Most of its strategic management practices are state of the art as well as its HRM practices. However, in order to match the strategic goals of the company, the human resources function should do the following: Conduct intensive training to all of its employees and not only their candidates for senior managers. These trainings should be in line with their respective functions of the employees in their respective divisions, and In order to motivate employees, the stock compensation option should be offered to everyone and not only for key managers.   PG’s infrastructure requirements consist of those functions and activities necessary for the effective management of a companys human resources. The major purposes of these activities traditionally have been to attract, retain, and motivate employees. We refer to them as human resource management (HRM) practices (Schuler, 1984), and the key HRM practices include: Human resource planning Staffing, including recruitment, selection, and socialization Appraising Compensation Training and development Union-management relationships   Ã‚  Ã‚   The result of effectively managing human resources is an enhanced ability to attract and retain qualified employees who are motivated to perform, and the results of having the right employees motivated to perform are numerous. They include greater profitability, low employee turnover, high product quality, lower production costs, and more rapid acceptance and implementation of corporate strategy. These results, particularly if coupled with competitors who do not have the right people motivated to perform, can create a number of competitive advantages through human resource management practices. CONCLUSION   Ã‚  Ã‚  Ã‚   Although there are many ways by which companies can gain a competitive advantage, as MacMillan (1983) has suggested, one way often overlooked is through their human resource management practices. HRM practices enable companies to gain a competitive advantage in two major ways: One is by helping themselves and the other is by helping others. So there appears to be a significant benefit from having HRM considerations represented in the strategy formulation stage rather than only in the implementation stage. Once the strategy is formulated and the appropriate HRM thrust identified, specific HRM practices need to be developed. These practices, such as staffing and compensation, are the ones that actually create the competitive advantage for the company. In addition, selection of the most appropriate practices should be appropriate to the strategy and lead to behaviors that are supportive of the strategy; for example, if cooperative behaviors are needed among employees, then group or organizational level compensation incentives should be provided rather than an individual-level incentive system. If product quality is critical, quality circles and union-management cooperation should be developed.   Ã‚  Ã‚  Ã‚   Once the strategy is formulated, the determination of the needed behaviors comes from job analysis. The HRM practices that stimulate those behaviors must be identified. They must be implemented so as to ensure consistency across HRM practices. It is this hard-won consistency which will help ensure that a competitive advantage through HRM practices is gained and sustained because of the barriers we have just discussed.   Ã‚  Ã‚  Ã‚   In addition to using their HRM practices on themselves, companies can also gain a competitive advantage through using their HRM practices on others. Specifically, companies can gain a competitive advantage by helping their suppliers, customers, or servicers/distributors with their practices     Ã‚      REFERENCES    ^ a b http://www.pginvestor.com/phoenix.zhtml?c=104574p=irol-fundSnapshot ^ CNN Fortune ranking ^ http://money.cnn.com/magazines/fortune/mostadmired/2007/top20/index.html ^ Dyer, Davis; Frederick Dalzell, Rowena Olegario (2004). Rising Tide: Lessons from 165 Years of Brand Building at Procter Gamble. Harvard Business School Press. ISBN 1591391474. ^ Wherrity, Constance. Dial Agrees to Buy PG Deodorant Brands, Pierce Mattie Public Relations New York blog, 2006-02-21. Retrieved on 2006-09-06. ^ John G. Smale: He rebuilt PG and city, too, The Cincinnati Post, 11 October 2005. ^ 2007 Annual report, pg 71 ^ Reasons for Selection, 2007 Canadas Top 100 Employers. ^ Trademark of the Beast by David Emery, June 10, 1998 ^ Trademark of the Devil by Barbara Mikkelson, snopes ^ Mikkel MacMillan, I. C. Seizing Competitive Initiative. The Journal of Business Strategy, 1983, pp. 43-57. Peters, T. J., and Waterman, R. H. Jr. In Search of Excellence. New York: Warner Books, 1982. Schuler, R. S. Personnel and Human Resource Management (2nd ed.). St. Paul, MN: West Publishing, 1984. Skinner, W. Big Hat, No Cattle: Managing Human Resources. Harvard Business Review, September-October 1981, pp. 107-118. Schulerson, Barbara and David. 2005 December 31

robert e. lee Essay -- essays research papers

Robert E. Lee, who was considered to be the greatest soldier fighting for the Confederate States of America, descended from a long line of famous heroes. Many of Lee's ancestors played important roles in America's history. His father was a Revolutionary War hero and a friend of George Washington. He was often referred to as Light Horse Harry Lee. Lee was born on January 19, 1807 in Stratford, Virginia. Lee always admired Washington, and was his hero as a youngster. Young Lee decided to become a soldier, partly because of the military tradition of his family. Lee enrolled in West Point Military Academy and graduated 2nd in his class in 1829. Lee majored in military engineering and supervised several army projects, he was named Second Lieutenant in the Corp engineers. His devotion and hard work in supervising harbor improvements in Saint Louis got him promoted to Captain in 1838. As a captain, his first experience in actual battle was in the Mexican War. He served under General Winfield Scott, and was the best engineer in General Scott's campaign. Lee's actions at the battles of Cerro Gordo, Churubusco, and Chapultepec received many high praises and earned him a reputation. General Scott claimed that the success of the war was due to Lee's bravery and skills, Lee was appointed the rank of Colonel. In 1582 he was appointed superintendent of West Point Military Academy. Under his service, James B. McPherson, Phillip Sheridan, and John Bell Hood would graduate from the academy, soon to be famous. Lee finished his duty as the superintendent in 1855, and served as a Lieutenant Colonel in the Second Cavalry, stationed in Texas. In 1859, while serving in Texas, Lee was sent to command a group of Marines to suppress John Brown's uprising. John Brown was a northern abolitionist would believed a rebellion in the south would lead to abolition. He was taken down by Lee's forces. After suppressing the uprising, Lee was called to Washington is 1861. The succession movement had begun. Some southern states had left, but Lee's own Virginia was still uncertain. As much as Lee had supported the Union, he couldn't bear the sight of union soldiers invading and destroying his hometown. Lee had thought over this matter for days, and finally decided to resign from the union forces and offer his help to the confederacy. When Lee reached Richmond, Virginia had succeeded and they had a... ...hrew strong attacks at the union forces, but was repulsed with heavy losses. The battle of Gettysburg was the largest battle ever fought in North America. He was criticized for attempting an impossible battle, the union forces had and advantageous position and more men. After Gettysburg, Lee retreated back to Virginia for the rest of the war. With the loss of more and more soldiers, Lee had no choice but to start taking a defensive position. In the spring of 1864, General Ulysses Grant got control of the union forces and decided to bring Lee into northern Virginia and crush the confederate forces there. Grant rushed to Petersburg, hoping to seize the railroad the was supplying Lee with supplies. Lee had arrived first and Grant started a siege. In 1865, Grant finally seized control of the railroads and lee retreated to the west. Lee, realizing his loss of men, met Grant at Appomattox and surrendered the Army of Northern Virginia. After the war, Lee was considered a hero of the south, with dignity he accepted his defeat and preached to his people the necessity of peace and national unity. He later became the principal of Washington college at Lexington. He died on October 12, 1870.

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