Dorothy A. Brown THE SOUTH BRONX HAS SOMETHING TO SAY: SYMPOSIUM KEYNOTE 72 South Carolina Law Review 617 (Spring, 2021) My book, The Whiteness of Wealth, was recently published by Crown. It looks at how systemic racism and federal tax policies compound our racial wealth gap. My book is based on my research that began with an invitation in the mid-1990s from Karen Brown and Mary Louise Fellows, who were editing a book called Taxing America. My chapter, entitled The... 2021
David S. Miller THE TAX GUIDE TO OFFSHORE LENDING 74 Tax Lawyer 523 (Spring, 2021) The Article explains the various structures that permit offshore funds with U.S. managers to originate loans without the fund or its investors being subject to any meaningful amount of U.S. tax. The Article also discusses a legislative change that would render these structures moot. L1-2Table of Contents I. The Rise of Nonbank Lending. 525 II.... 2021
Alexander Gouzoules "UNDUE HARDSHIP" AND UNINSURED AMERICANS: HOW ACCESS TO HEALTHCARE SHOULD IMPACT STUDENT-LOAN DISCHARGE IN BANKRUPTCY 69 Emory Law Journal Online 2019 (2020) American student-loan debt has reached a staggering sum. Student loans rank below only housing as the second-largest form of household debt, with $1.4 trillion outstanding. From 1990 to 2016, average college tuition rose by 57% at private universities and 93% at public ones, an increase both enabled by and contributing to the growth of student... 2020
Francine J. Lipman , Nicholas A. Mirkay , Palma Joy Strand #BLACKTAXPAYERSMATTER: ANTI-RACIST RESTRUCTURING OF U.S. TAX SYSTEMS 46 Human Rights 10 (2020) The world has witnessed the brutal suffocation of George Floyd on a concrete sidewalk in Minneapolis. While this is but one more example of centuries of relentless violence against Black people, many are hoping that this tragic death will be a catalyst for meaningful change. Throughout the world, rallies, marches, and vigils have filled public... 2020
Brian Mogck A PROPOSAL FOR POLICE REFORM: REQUIRE EFFECTIVE ACCOUNTABILITY MEASURES IN POLICE UNION CONTRACTS AS A CONDITION OF TAX-EXEMPT STATUS 8/7/2020 University of Chicago Law Review Online 1 (August 7, 2020) In the wake of the May 25 police killing of George Floyd in Minneapolis, government leaders across the nation are urgently considering reforms that might prevent police brutality. Policy analysts have suggested changes to federal, state, and local laws to improve transparency for police departments and accountability for officers. Proposals have... 2020
Edward A. Zelinsky APPLYING THE FIRST AMENDMENT TO THE INTERNAL REVENUE CODE: MINNESOTA VOTERS ALLIANCE AND THE TAX LAW'S REGULATION OF NONPROFIT ORGANIZATIONS' POLITICAL SPEECH 83 Albany Law Review 1 (2019-2020) In Minnesota Voters Alliance v. Mansky, the U.S. Supreme Court struck on First Amendment grounds Minnesota's political apparel ban. This law prohibits individuals from wearing political badges, political buttons, or other political insignia . at or about [any] polling place. The Minnesota statute, the Court held, unreasonably restricts... 2020
John Patrick Hunt BANKRUPTCY AS CONSUMER PROTECTION: THE CASE OF STUDENT LOANS 52 Arizona State Law Journal 1167 (Winter 2020) Over 300,000 student loan borrowers have applied to the Department of Education for administrative relief from federal student loans on the ground that they were deceived or otherwise victimized by their schools. The Department adopted relatively borrower-friendly rules for this process in 2016. But under Secretary DeVos, the Department changed... 2020
Samir D. Parikh BANKRUPTCY TOURISM AND THE EUROPEAN UNION'S CORPORATE RESTRUCTURING QUANDARY: THE CATHEDRAL IN ANOTHER LIGHT 42 University of Pennsylvania Journal of International Law 205 (Fall, 2020) For the last decade, the European Union (EU) has been reconceptualizing its corporate restructuring framework with the hope of bolstering capital markets and improving cross-border lending. Unfortunately, the system remains plagued by two intractable problems: divergent substantive law at the Member State level and jurists unaccustomed to guiding... 2020
Jonathan Barry Forman , Roberta F. Mann BORROWING FROM MILLENNIALS TO PAY BOOMERS: CAN TAX POLICY CREATE SUSTAINABLE INTERGENERATIONAL EQUITY? 36 Georgia State University Law Review 799 (Spring, 2020) C1-3Table of Contents L1-2Introduction . L3801 I. Sustainable Intergenerational Justice and Tax Policy. 803 A. What Is Sustainable Intergenerational Justice?. 803 B. How Can Tax Policy Influence Sustainable Intergenerational Justice?. 806 1. The Resources of U.S. Households. 806 2. Taxes Can Influence the Level of Resources that Are Available to... 2020
Nathalie Martin BRINGING RELEVANCE BACK TO CONSUMER BANKRUPTCY 36 Emory Bankruptcy Developments Journal 581 (2020) This Paper was presented at the Seventeenth Annual Emory Bankruptcy Developments Journal Symposium in February of 2020. Less than a month later, all or most travel had ceased and many of us began the process of social distancing and restructuring our lives in the face of the coronavirus. No one could have predicted this event and its effects on the... 2020
Martin G. Vallespinos CAN THE WTO STOP THE RACE TO THE BOTTOM? TAX COMPETITION AND THE WTO 40 Virginia Tax Review 93 (Fall, 2020) In this article, I analyze the interaction between income tax competition and the multilateral trade regime. I argue that several forms of tax competition such as special tax zones (STZs), export tax incentives, participation exception, profit shifting toleration, and tax havens are distortive to international trade and therefore should be policed... 2020
Anthony J. Casey CHAPTER 11'S RENEGOTIATION FRAMEWORK AND THE PURPOSE OF CORPORATE BANKRUPTCY 120 Columbia Law Review 1709 (November, 2020) A fundamental question for corporate bankruptcy law is why it exists in the first place. Why are there special rules that apply only in financial distress? The conventional law-and-economics answer--known as the Creditors' Bargain Theory--identifies two core purposes of bankruptcy law: recreating a hypothetical ex ante bargain and respecting... 2020
Blaine G. Saito COLLABORATIVE GOVERNANCE AND THE LOW-INCOME HOUSING TAX CREDIT 39 Virginia Tax Review 451 (Spring, 2020) The Low-Income Housing Tax Credit (LIHTC) is the largest federal program focused on increasing the supply of affordable housing. The credit is designed as a collaboration among the federal government, states, localities, developers, and investors. But it is not meeting its goals. Budget hawks have noted that costs have increased while units have... 2020
Carlo Garbarino COSMOPOLITAN RIGHTS, GLOBAL TAX JUSTICE, AND THE MORALITY OF COOPERATION 23 Florida Tax Review 743 (Spring, 2020) This Article addresses two related first-order questions about morality that enable us to discern solutions that address second-order questions in the specific policy context of regulation of tax competition and BEPS: (1) what kind of justice conception has sufficient normative support to undergird regulation attempts of this global phenomenon to... 2020
Johnny Rex Buckles CURBING (OR NOT) FOREIGN INFLUENCE ON U.S. POLITICS AND POLICIES THROUGH THE FEDERAL TAXATION OF CHARITIES 79 Maryland Law Review 590 (2020) The 2016 presidential election spawned journalistic accounts igniting great concern across the political spectrum that foreign actors had been interfering with America's democracy. Foreign engagement with politically active nonprofit organizations has contributed to the perceived problem. Although tax-exempt charitable organizations described in... 2020
Simon de Carvalho DOES THE TAX CODE BELIEVE WOMEN?: REEXAMINING 26 USC § 104(A)(2) IN THE #METOO ERA 87 University of Chicago Law Review 1345 (July, 2020) Since 1918, the tax code has included 26 USC § 104(a)(2), an exclusion from gross income for civil lawsuit damages for personal injuries or sickness. In 1996, by adding one word--physical--to the provision (twice), Congress narrowed the exclusion's scope dramatically. Now, damages compensating for a broken arm (a personal physical injury) are... 2020
Caroline Bruckner DOUBLING DOWN ON A BILLION DOLLAR BLIND SPOT: WOMEN BUSINESS OWNERS AND TAX REFORM 9 American University Business Law Review 1 (2020) I. Introduction. 1 II. Women Business Owners as an Economic Force. 8 A. Most Women-Owned Firms Are Small Business Service Firms. 9 B. Women-Owned Firms Still Encounter Growth and Access to Capital Challenges. 13 III. Data on Women Testifying Before the Tax-Writing Committees. 16 IV. TCJA & Small Business Tax Expenditures. 21 A. Section... 2020
Pamela Foohey , Robert M. Lawless , Deborah Thorne DRIVEN TO BANKRUPTCY 55 Wake Forest Law Review 287 (2020) Over the last ten years, 15.1 million people owning 16.4 million cars filed for bankruptcy. These cars provided access to work, education, medical care, childcare, food, and other life necessities. They were also major household investments, the most expensive asset most bankruptcy filers owned other than a house. Using original data from the... 2020
Reuven Avi-Yonah, Orli Avi-Yonah, Nir Fishbien, Haiyan Xu FEDERALIZING TAX JUSTICE 53 Indiana Law Review 461 (2020) The United States is the only large federal country that does not have an explicit way to reduce the economic disparities among more and less developed regions. In Germany, for example, federal revenues are distributed by a formula that takes into account the relative level of wealth of each state (the so-called Finanzausgleich, or fiscal... 2020
Rafael I. Pardo FINANCIAL FREEDOM SUITS: BANKRUPTCY, RACE, AND CITIZENSHIP IN ANTEBELLUM AMERICA 62 Arizona Law Review 125 (Spring, 2020) This Article presents a new frame of reference for thinking about how the federal government facilitated citizenship claims by free people of color in the antebellum United States. While scholars have accounted for various ways in which free black litigants may have made such claims, they have not considered how the Bankruptcy Act of 1841 enabled... 2020
Pamela Foohey FINES, FEES, AND FILING BANKRUPTCY 98 North Carolina Law Review 419 (January, 2020) When faced with mounting civil or criminal court fines, fees, and interest-- court debt, as broadly defined--people may consider turning to the bankruptcy system to deal with that debt. Every year, about a million people file bankruptcy, seeking to discharge most of their debts. Although most court debt is categorically nondischargeable,... 2020
Neil L. Sobol GRIFFIN v. ILLINOIS: JUSTICE INDEPENDENT OF WEALTH? 49 Stetson Law Review 399 (Spring, 2020) There can be no equal justice where the kind of trial a man gets depends on the amount of money he has. --Justice Hugo Black (1956) My work with the poor and the incarcerated has persuaded me that the opposite of poverty is not wealth; the opposite of poverty is justice. --Bryan Stevenson (2014) Justice Hugo Black's frequently quoted comment... 2020
Cyril A.L. Heron HOW TO SUE AN ASUE? CLOSING THE RACIAL WEALTH GAP THROUGH THE TRANSPLANTATION OF A CULTURAL INSTITUTION 26 Michigan Journal of Race and Law 171 (Fall, 2020) Asues, academically known as Rotating Savings and Credit Associations (or ROSCAs for short), are informal cultural institutions that are prominent in developing countries across the globe. Their utilization in those countries provide rural and ostracized communities with a means to save money and invest in the community simultaneously. Adoption of... 2020
Julie Roin JUDGE WOOD MEETS INTERNATIONAL TAX 87 University of Chicago Law Review 2453 (December, 2020) There is always a danger in having courts of general jurisdiction rule on issues involving the application of technical pieces of specialized legislation. Judges in these courts generally lack the background necessary to understand the interactions between the particular issue(s) under scrutiny and the larger legislative or regulatory picture. And... 2020
Phyllis C. Taite MAKING TAX POLICY GREAT AGAIN: AMERICA, YOU'VE BEEN TRUMPED 24 Florida Tax Review 240 (Fall, 2020) Tax policy plays a role in shaping the economy. Scholars have long asserted that tax policy should be used to make positive impacts on economic activity by adjusting and creating policies that benefit most of the population rather than the elite few. Scholars advocate for implementing policies to address wealth and income inequality while... 2020
Grace Stephenson Nielsen NETFLIX AND (TAX) BILL: RETAIL SALES TAXATION OF SERVICES 46 Brigham Young University Law Review 249 (2020) C1-2Contents I. Political and Policy Implications of Service Taxes. 255 A. Advantages of an RST on Services. 256 1. Base erosion: More money, more problems consistency. 256 2. Correcting economic distortions. 261 B. Design Concerns. 261 1. Tax cascading: Exempting business-to-business services. 262 2. Vertical equity concerns. 264 3. Essential... 2020
  NYC PROPERTY TAX SYSTEM UPHELD 26 CITYLAW 12 (2020) An Organization challenged New York City's property tax system as unfair, unconstitutional and discriminatory. Tax Equity Now NY LLC, an association of property owners and renters, filed a lawsuit challenging the New York City property tax system. The owners and renters alleged that the City's property tax system was unfair and results in racial... 2020
Dr. Charles J. Reid, Jr. PANDEMIC OF INEQUALITY: AN INTRODUCTION TO INEQUALITY OF RACE, WEALTH, AND CLASS, EQUALITY OF OPPORTUNITY 14 University of St. Thomas Journal of Law & Public Policy 1 (December, 2020) This Symposium was proposed and planned months before COVID-19 emerged as a public health emergency. Still, it can safely be said that the COVID pandemic that ravaged the United States in the summer and fall of 2020--a pandemic, furthermore, that poses an even greater threat in the upcoming winter--has revealed in vivid detail the inequalities at... 2020
Blake N. Humphrey PILOT AGREEMENTS IN WEST VIRGINIA: A TALE OF TURBULENT TAXATION 123 West Virginia Law Review 335 (Fall, 2020) I. Introduction. 336 II. Historical Perspective and Background. 340 A. History of PILOT Agreements in the United States. 340 1. Nonprofit PILOT Agreements. 341 2. Private Sector PILOT Agreements. 343 B. History of PILOT Agreements in West Virginia: A Push to Facilitate Economic Development and Stability. 345 1. Statutory Authorization for PILOT... 2020
Luke Scheuer POT, THE FIRST AMENDMENT, AND TAXES: THE IRS'S DENIAL OF 501(C)(6) TAX-EXEMPT STATUS TO MARIJUANA ADVOCACY GROUPS 26 Widener Law Review 101 (2020) Federal law prohibits the sale, possession, and use of marijuana under the Controlled Substances Act. Nevertheless, many states have legalized marijuana for medical or recreational uses and have licensed businesses for the purpose of selling marijuana to the public. As a result, a burgeoning marijuana industry has cropped up, and its participants... 2020
Connor Blancato QAP OUT: WHY THE FEDERAL GOVERNMENT SHOULD REQUIRE MORE FROM HOW STATES ALLOCATE LOW-INCOME HOUSING TAX CREDITS 28 Journal of Law & Policy 639 (2020) Prohibitively high land acquisition and construction costs block affordable housing developers from using the Low-Income Housing Tax Credit program in high opportunity areas. Policymakers must study the history of housing policy in the United States and realize that the LIHTC program works because it suitably balances previously problematic... 2020
Edward R. Morrison, Belisa Pang, Antoine Uettwiller, Columbia University, Yale University, Imperial College London RACE AND BANKRUPTCY: EXPLAINING RACIAL DISPARITIES IN CONSUMER BANKRUPTCY 63 Journal of Law & Economics 269 (May, 2020) African American bankruptcy filers select Chapter 13 far more often than other debtors, who opt instead for Chapter 7, which has higher success rates and lower attorneys' fees. Prior scholarship blames racial discrimination by attorneys. We propose an alternative explanation: Chapter 13 offers benefits, including retention of cars and driver's... 2020
Palma Joy Strand, Nicholas A. Mirkay RACIALIZED TAX INEQUITY: WEALTH, RACISM, AND THE U.S. SYSTEM OF TAXATION 15 Northwestern Journal of Law & Social Policy 265 (Spring, 2020) This Article describes the connection between wealth inequality and the increasing structural racism in the U.S. tax system since the 1980s. A long-term sociological view (the why) reveals the historical racialization of wealth and a shift in the tax system overall beginning around 1980 to protect and exacerbate wealth inequality, which has been... 2020
Hon. Jason D. Woodard RACING TO RESOLUTION: A PRELIMINARY STUDY OF INDIA'S NEW BANKRUPTCY CODE 52 George Washington International Law Review 393 (2020) Motivated in part by its low rankings in the World Bank's annual Doing Business reports, India enacted a new bankruptcy code in 2016. The new law is significantly different from the United States' highly-ranked code but was likewise designed to engineer a rise in the World Bank rankings. This Article examines the dynamic from two perspectives. Part... 2020
Arvind Sabu REFRAMING BITCOIN AND TAX COMPLIANCE 64 Saint Louis University Law Journal 181 (Winter, 2020) This Article argues that, contrary to the common belief that Bitcoin enables tax evasion, the Internal Revenue Service (IRS) can increasingly police transactions in Bitcoin. First, commercial and technical intermediaries have emerged as part of Bitcoin's ecosystem. This diverse set of intermediaries can facilitate tax enforcement, as the... 2020
Sinis̆a Petrović , Tomislav Jaks̆ić REGULATION AND COMPETITION OF TAXI SERVICES 76 IUS Gentium 153 (2020) Throughout the world, the taxi market is generally considered a heavily regulated market. Such regulation refers primarily to establishing market entry restrictions, establishing taxi fares schemes, setting up of minimal passenger safety and protection standards, as well as ensuring that certain universal service requirements are adhered... 2020
Richard M. Hynes , Steven D. Walt REVITALIZING INVOLUNTARY BANKRUPTCY 105 Iowa Law Review 1127 (March, 2020) For the first centuries of bankruptcy's existence, only creditors could initiate a proceeding. Voluntary bankruptcy--initiated by the debtor rather than creditors--began in the nineteenth century, but well into the early twentieth century, involuntary bankruptcy accounted for about two-thirds of the money distributed to general... 2020
Elizabeth E. Stephens , Sullivan Hill Rez & Engel, APLC, Las Vegas SEN. WARREN PROPOSES SWEEPING REFORMS TO THE BANKRUPTCY CODE 39-MAR American Bankruptcy Institute Journal 8 (March, 2020) Editor's Note: This month's Update features a look at a proposal to revise the Bankruptcy Code and how it compares to recommendations made by the ABI Commission on Consumer Bankruptcy ( Prior to entering public office in 2013, Sen. Warren was an ABI member and even penned a column for the ABI Journal called Warren &... 2020
Caroline Enright SOMEONE TO LIEN ON: PRIVATIZATION OF DELINQUENT PROPERTY TAX LIENS AND TAX SALE SURPLUS IN MASSACHUSETTS 61 Boston College Law Review 667 (February, 2020) In Massachusetts, as well as in twenty-eight other states in the nation, municipalities can sell delinquent property tax liens to private investors. In exchange for paying for the debt, the private entity can collect interest rates of up to sixteen percent and levy additional fees on the homeowner. If the homeowner is unable to pay the... 2020
Gladriel Shobe SUBSIDIZING ECONOMIC SEGREGATION THROUGH THE STATE AND LOCAL TAX DEDUCTION 11 UC Irvine Law Review 539 (December, 2020) Economic segregation has increased over the past half-century. The trend of rich localities getting richer while poor localities get poorer is particularly concerning because it limits upward mobility and perpetuates intergenerational income inequality. This Article makes the novel argument that the state and local tax deduction subsidizes economic... 2020
Pippa Browde TAX BURDENS AND TRIBAL SOVEREIGNTY: THE PROHIBITION ON LAVISH AND EXTRAVAGANT BENEFITS UNDER THE TRIBAL GENERAL WELFARE EXCLUSION 20 Nevada Law Journal 651 (Spring, 2020) This article examines a portion of a relatively new federal tax statute, the Tribal General Welfare Exclusion (TGWE), that allows qualified individuals an exclusion from gross income for payments received from American Indian/Alaska Native tribes for any Indian general welfare benefit. Indian general welfare benefits are payments made to tribal... 2020
Ariel Jurow Kleiman TAX LIMITS AND THE FUTURE OF LOCAL DEMOCRACY 133 Harvard Law Review 1884 (April, 2020) C1-2CONTENTS Introduction. 1886 I. Understanding the Tax Reduction Goal. 1893 II. Improving Public Control. 1899 A. How Tax Limits Can Improve Public Control. 1900 B. Normative Support for Local Public Control. 1905 1. Improved Policies. 1905 2. Improved Process. 1908 C. Countervailing Interests. 1911 1. Extralocal Residents. 1911 2. Tax Limit... 2020
Clinton G. Wallace TAX POLICY AND OUR DEMOCRACY 118 Michigan Law Review 1233 (April, 2020) Our Selfish Tax Laws: Toward Tax Reform that Mirrors Our Better Selves. By Anthony C. Infanti. Cambridge: The MIT Press. 2018. Pp. xi, 159. $39. Racial Taxation: Schools, Segregation, and Taxpayer Citizenship, 1869-1973. By Camille Walsh. Chapel Hill: The University of North Carolina Press. 2018. Pp. xii, 176. Cloth, $90; paper, $29.95. In her new... 2020
Karen Czapanskiy TAX POLICY, STRUCTURED SETTLEMENTS AND FACTORING: MAKING EXPLOITATION EASY AND PROFITABLE 97 University of Detroit Mercy Law Review 455 (Spring, 2020) Secondary sales of streams of income payable under structured settlements of tort claims are such a disfavored transaction that Congress imposed a punitive 40 percent excise tax on them. These factoring transactions are disfavored because it is believed that payees are likely to be exploited, to dissipate the lump sum which is paid for the stream... 2020
Adam Crepelle TAXES, THEFT, AND INDIAN TRIBES: SEEKING AN EQUITABLE SOLUTION TO STATE TAXATION OF INDIAN COUNTRY COMMERCE 122 West Virginia Law Review 999 (Spring, 2020) I. Introduction. 999 II. Tribal Sovereignty and Taxes. 1001 III. Quil Ceda Village--A New Level of Injustice. 1009 A. History of QCV. 1009 B. The Tax Showdown at QCV. 1011 IV. Problem with State Taxation of Indian Country. 1014 V. Solutions. 1021 A. State Power Stops at the Reservation's Edge. 1021 B. Tax 'Em Back. 1028 VI. Conclusion. 1032 2020
Mark J. Cowan TAXING CANNABIS ON THE RESERVATION 57 American Business Law Journal 867 (Winter 2020) American Indian tribes that enter the cannabis industry confront a multis-overeign tax system that lacks certainty and horizontal equity. The complex interaction of state legalization and taxation of cannabis, federal tax law, the status of tribes as both governments and business enterprises, and the legal and tax landscape in Indian country can... 2020
Bruce Grohsgal THE ARGUMENT FOR A FEDERAL RULE OF DECISION FOR A BANKRUPTCY COURT'S RECHARACTERIZATION OF A CLAIM AS EQUITY 94 American Bankruptcy Law Journal 681 (Winter 2020) This article considers whether a federal or state rule of decision applies to a bankruptcy court's recharacterizing a claim as equity. Though every circuit that has considered recharacterization has authorized it, the circuits are split on whether federal or state law governs. I conclude that a federal decisional rule applies for several reasons.... 2020
Danaya C. Wright THE DEMOGRAPHICS OF INTERGENERATIONAL TRANSMISSION OF WEALTH: AN EMPIRICAL STUDY OF TESTACY AND INTESTACY ON FAMILY PROPERTY 88 UMKC Law Review 665 (Spring, 2020) Everyone dies eventually, and the vast majority of us will die owning at least some property. Unless you are very adept at budgeting your every need, and give away during life whatever might be left over, you are unlikely to do as my father wants to do: spend his last five dollars on the margarita that will drop him in the grave. Thus, as we think... 2020
Yiming Sun THE GOLDEN SHARE: ATTACHING FIDUCIARY DUTIES TO BANKRUPTCY VETO RIGHTS 87 University of Chicago Law Review 1109 (June, 2020) Under bankruptcy law, a debtor cannot enter into a binding agreement with a creditor to not file for bankruptcy in the future. However, creditors can in effect prevent a corporate debtor from filing for bankruptcy by obtaining a special golden share in the debtor and exercising the right to veto its bankruptcy concomitant with such a share.... 2020
Allison Anna Tail THE LAW OF HIGH-WEALTH EXCEPTIONALISM 71 Alabama Law Review 981 (2020) Introduction. 983 I. The Inscription of Family Goverance. 987 A. Forming a Perfect Family Union. 987 1. Crafting Democratic Governance. 988 2. Identifying Fundamental Family Values. 991 3. Exceptional Entities: Family as Nation-State. 993 B. Securing the Wealth of Families.. 995 1. In Families We Trust. 995 2. Investing in Family. 999 3. Charity... 2020
1 2 3 4 5 6 7 8 9 10 11 12 13 14