Bridget J. Crawford PINK TAX AND OTHER TROPES 34 Yale Journal of Law & Feminism 88 (2023) Abstract: Law reform advocates should be strategic in deploying tax tropes. This Article examines five common tax phrases--the nanny tax, death tax, soda tax, Black tax, and pink tax--and demonstrates that tax rhetoric is more likely to influence law when used to describe specific economic injustices resulting from actual government... 2023
Brakeyshia R. Samms POWER TO THE PEOPLE: HOW WORKERS CAN FIGHT TAX INEQUITY 49 Human Rights 38 (October, 2023) One of the most glaring problems facing workers today is tax inequity. The preferential treatment of capital gains (income from wealth) over wage income in both federal and state tax codes is a prime example. The wealthy's income has vastly risen over the past few decades, while workers have fared much worse by comparison. While tax policy alone... 2023
Amy Deen Westbrook , David A. Westbrook PROGRESSIVE CORPORATE GOVERNANCE UNDER SOCIAL CAPITALISM: DO THE RIGHT THING OR SHARE THE WEALTH? 17 Virginia Law & Business Review 145 (Spring, 2023) This Article expands the idea of progressive corporate governance beyond the limitations entailed in the traditional debate over corporate purpose: should firms be operated for Shareholder Wealth Maximization (SWM) or for broader goods, today called Environmental, Social, and Governance (ESG) goals? In one form or another, shareholder... 2023
Makenzie Stuard PROPERTY TAXIDERMY: HOW PROPERTY TAX LENDERS DO FALL UNDER THE TRUTH IN LENDING ACT (TILA), AND HOW, TO HOLD OTHERWISE ALLOWS THE INDUSTRY TO PREY ON AND MAINTAIN COMMUNITIES OF COLOR 29 Texas Hispanic Journal of Law and Policy 1 (Spring, 2023) Apex predators shape and influence the ecosystem in which they live. They are built to serve their own interests. As observers, we study their habitats and lifestyles with wonder, but in that observation, we also see the destruction they can wreak havoc when unrestrained. In the natural environment, apex predators are incentivized to hunt animals... 2023
Sheldon A. Evans PUNISHMENT EXTERNALITIES AND THE PRISON TAX 111 California Law Review 683 (June, 2023) Punishment as a social institution has failed to live up to the quixotic ideals of theory and has descended into the practice of mass incarceration, which is one of the defining failures of modern times. Scholars have traditionally studied punishment and incarceration as parts of a social transaction between the criminal offender, whose crime... 2023
Islame Hosny QUALIFIED OPPORTUNITY ZONES: A CRITICAL TAX ANALYSIS OF THE CAPITAL GAIN REQUIREMENT 18 Rutgers Business Law Review 84 (Spring, 2023) In December 2017, the Tax Cuts and Jobs Act established the Qualified Opportunity Zones (QOZ) tax incentive program, an economic development tool that allows people to invest in distressed areas. As a student at Columbia University, which has its main campus in the affluent Morningside Heights neighborhood in New York City, I sometimes pass... 2023
John Byrnes RACIAL DISCRIMINATION, HOME APPRAISALS, AND THE FAIR HOUSING ACT: REGULATING PRIVATE APPRAISERS TO REDUCE THE RACIAL WEALTH GAP 20 Rutgers Journal of Law & Public Policy 45 (Spring, 2023) This paper highlights the prevalence of racial discrimination in the home appraisal market through critical race theory (CRT) techniques and theory. When a home's value can be reduced by almost twenty-five percent simply because of the perceived race of its owners or of the neighborhood, Black families find themselves at a disadvantage as they try... 2023
Sydney Calas RECONCEPTUALIZING BANKRUPTCY EDUCATION REQUIREMENTS FOR INCARCERATED DEBTORS 39 Emory Bankruptcy Developments Journal 329 (2023) In the eighteen years since Congress enacted the Bankruptcy Abuse Prevention and Consumer Protection Act (BAPCPA), bankruptcy scholars and professionals have launched countless critiques against two of the Act's more drastic amendments: (1) mandatory pre-filing credit counseling and (2) a mandatory post-filing financial management course. Without... 2023
Erez Aloni RICH DAD, GAY DAD: THE WEALTH TRAPS OF GAY FATHERHOOD 101 North Carolina Law Review 1381 (June, 2023) While legal and societal progress has enabled gay fathers to form families, there remains a critical blind spot in our understanding of their financial well-being. Specifically, there are indications that a wealth gap may exist among gay father households. This Article introduces a novel taxonomy of the mechanisms that likely contribute to a wealth... 2023
B. Summer Chandler SALES FREE AND CLEAR OF AN INTELLECTUAL PROPERTY LICENSEE'S INTERESTS IN BANKRUPTCY--LOOKING TO IN RE TEMPNOLOGY FOR GUIDANCE 15 Drexel Law Review 271 (2023) Uncertainty surrounds many issues that exist at the intersection of bankruptcy law and intellectual property law. Section 363(f) of the Bankruptcy Code permits the debtor to sell assets free of a third party's interest in such assets, provided one or more preconditions is satisfied. When a debtor rejects a license agreement pertaining to the... 2023
Armen H. Merjian SECOND-GENERATION SOURCE OF INCOME HOUSING DISCRIMINATION 2023 Utah Law Review 963 (2023) [S]econd-generation barriers . have emerged in the covered jurisdictions as attempted substitutes for the first-generation barriers that originally triggered preclearance in those jurisdictions. Justice Ruth Bader Ginsburg As source of income protections increase, landlords are more likely to rely on other measures such as credit scores to... 2023
Brian Galle , David Gamage , Darien Shanske SOLVING THE VALUATION CHALLENGE: THE ULTRA METHOD FOR TAXING EXTREME WEALTH 72 Duke Law Journal 1257 (March, 2023) Recent reporting based on leaked tax returns of the ultrarich confirms what experts have long suspected: for the wealthiest Americans, paying taxes is mostly optional. Some of the country's richest have reported annual taxable incomes that would be modest for a schoolteacher, even as the share of wealth held by the top .1 percent is at its highest... 2023
Alex Sernyak STOP SUBSIDIZING THE SUBURBS: PROPERTY TAX REFORM AND ENDING EXCLUSIONARY ZONING 31 New York University Environmental Law Journal 243 (2023) Current residential land use in the United States has been disastrous for the environment. Land use is largely regulated by local zoning laws, and in many states, property taxes are set at a local level as well. The relationship between the two is complex, but put simply, having both policy tools in the hands of local governments creates... 2023
Linda Sugin TAX BENEFITS AND FAIRNESS IN K-12 EDUCATION 111 Georgetown Law Journal Online 140 (2023) This Article examines the tax law's subsidies for inequality and segregation in primary and secondary education, analyzing the federal charitable deduction and education savings plans, and state tax credits for education. It argues that the tax system diverts funds from traditional public education into private education, fostering economic,... 2023
Jackson Hughes TAXATION AND TELEHEALTH: WOULD A TELEHEALTH EXCLUSIVE FACILITY OWNED BY A NONPROFIT HOSPITAL BE EXEMPT FROM PROPERTY TAX IN INDIANA? 20 Indiana Health Law Review 385 (2023) Taxation exemption in the United States traces its roots to before the formation of our republic. Organizations which provide charitable relief, such as hospitals, fire departments, and orphanages, were established to address a lack of direct governmental involvement in the societal issues faced by colonists. These organizations were designed to... 2023
Hilary G. Escajeda TECHNOLOGY JUSTICE: TAXATION OF OUR COLLECTIVE AND CUMULATIVE COGNITIVE INHERITANCE 56 Loyola of Los Angeles Law Review 1073 (Fall, 2023) As artificial intelligence and robotic technologies accelerate economic transformation, outdated property and tax laws will increasingly fail American workers with ordinary skills that perform routine job functions. Because technology may render millions of workers redundant, U.S. policymakers must make significant social, economic, and legal... 2023
Vijay Raghavan THE CASE AGAINST THE DEBT TAX 91 Fordham Law Review 1849 (April, 2023) Americans are increasingly agitating for debt relief. In the last decade, there have been national campaigns to cancel student debt, credit card debt, and mortgage debt. These national campaigns have paralleled local efforts to cancel taxi medallion debt, carceral debt, and lunch debt. But as the public increasingly pursues broad-scale debt relief... 2023
Andrew Hayashi , Justin J. Hopkins THE CHARITABLE TAX DEDUCTION AND CIVIC ENGAGEMENT 2023 University of Illinois Law Review 1179 (2023) In an era characterized by polarization, economic inequality, and the disintegration of local communities, the income tax deduction for charitable contributions appears to abet some of our worst social ills because it incentivizes the wealthy to steer public funds to their preferred charities and subsidizes their donations. We argue that tax... 2023
Danielle A. Chaim THE COMMON OWNERSHIP TAX STRATEGY 101 Washington University Law Review 501 (2023) The recent mass shift by American retail investors into index funds has given rise to a modern form of common ownership. Significant stakes in most public companies are now held by a core group of large, diversified institutional investors. In parallel, this rise in common ownership has been accompanied by unprecedented levels of corporate tax... 2023
Mahlon J. Mowrer , The Belmont Firm, Arlington, Va. THE CONSUMER BANKRUPTCY REFORM ACT: A TRANSFORMATION OF THE LAW 42-JAN American Bankruptcy Institute Journal 8 (January, 2023) The 117th Congress is in its twilight, and the 118th Congress will mire in the narrow partisan majorities splitting its chambers and the inevitable political divides leading into the 2024 election. So imminent legislative updates impacting bankruptcy seem--at best--distant. But bankruptcy bills often echo. The sleepy winter months seem to be the... 2023
Carla Spivack THE ESTATE TAX, INEQUALITY, AND THE PROBLEM OF PUBLIC CHOICE 20 Pittsburgh Tax Review 397 (Spring, 2023) I am honored by the opportunity to comment on these three fascinating papers, and I thank these scholars for their important contributions to the question of the estate tax and inequality. Each sheds light on important ways the current estate tax contributes to wealth inequality, and therefore to the political, social, educational, health, and all... 2023
Alexander Ezenagu, Ilias Bantekas THE EXCLUSIONARY EFFECT OF MULTILATERAL GLOBAL TAX REFORMS AND THE PLIGHT OF DEVELOPING STATES 38 Connecticut Journal of International Law 63 (Spring, 2023) Countries have come to accept the wide application of international tax rules in both their domestic and international tax affairs. However, where international tax rules fall short of the legitimate expectations of states and fail to provide necessary guidance, impacted states may be compelled to seek other sources of guidance. In this paper, we... 2023
Kendall B. Bargeman THE HEIRS' PROPERTY DILEMMA: HOW STRONGER FEDERAL POLICIES CAN HELP NARROW THE RACIAL WEALTH GAP 27 North Carolina Banking Institute 320 (March, 2023) Without the proper knowledge and preparation, a family that owns heirs' property could lose all of the resources they have invested for generations in their home. Heirs' property ownership is a complex social justice issue and financial burden for Black communities that inhibits homeowners from receiving assistance after their homes and land have... 2023
Jacob Hartzler THE REVIVAL OF THE CORPORATE ALTERNATIVE MINIMUM TAX: SOUND POLICY IN THE GLOBAL EFFORT TO COMBAT BASE EROSION AND PROFIT SHIFTING? 24 Journal of High Technology Law 749 (2023) Intellectual property (IP), including patents, copyrights, trademarks, and trade secrets, are vital assets for corporations and countries alike. In the digital age, IP rights have enabled multinational corporations to reduce or outright avoid paying income tax in jurisdictions where they generate substantial revenue. For years, multinational... 2023
Joshua D. Blank , Ari Glogower THE TAX INFORMATION GAP AT THE TOP 108 Iowa Law Review 1597 (May, 2023) ABSTRACT: Tax information reporting is an essential element of tax administration and compliance in the United States. When individuals earn wages, accrue interest, or receive Social Security benefits, the Internal Revenue Service almost always knows. In these situations, a third party, such as an employer or a bank, files an information return... 2023
Peter S. Lehmann, Department of Criminal Justice and Criminology, Sam Houston State University THE TRIAL TAX AND THE INTERSECTION OF RACE/ETHNICITY, GENDER, AND AGE IN CRIMINAL COURT SENTENCING 47 Law and Human Behavior 201 (February, 2023) Objective: Prior research consistently demonstrates that defendants convicted at trial are sentenced more harshly than those who plead guilty. Additionally, a vast literature has shown that Black and Hispanic defendants, and especially young minority males, are particularly disadvantaged in sentencing, though these effects may be conditional on... 2023
Michelle D. Layser THE UNKNOWN CONSEQUENCES OF PLACE-BASED TAX INCENTIVES 56 Loyola of Los Angeles Law Review 1261 (Fall, 2023) Nearly thirty years have passed since Prof. Ellen Aprill warned policymakers not to rely on tax incentives to fight urban poverty. At the time, federal and state governments were just beginning to embrace so called place-based tax incentives, which are used to promote investment in low-income areas. Aprill was skeptical and expressed doubts about... 2023
Karen Lou TICKET TO DEBT: CITY OF CHICAGO v. FULTON AND THE TWO-TRACK CONSUMER BANKRUPTCY SYSTEM 123 Columbia Law Review 2371 (December, 2023) In 2021, the Supreme Court decided City of Chicago v. Fulton, a landmark bankruptcy case that addressed the issue of whether passive retention of estate property violates § 362(a)(3) of the U.S. Bankruptcy Code, commonly known as the automatic stay provision. The automatic stay, as its name suggests, is a breathing spell that prevents creditors... 2023
Danaya C. Wright TRAPPED BETWEEN THE URPTODA AND THE UPHPA: PROBATE REFORMS TO BRIDGE THE GAP AND SAVE HEIRS PROPERTY FOR MODEST-WEALTH DECEDENTS 127 Penn State Law Review 749 (Summer, 2023) The problem of heirs property is tragic and endemic, especially in minority and low-income communities where family homes and farms are lost because of fractionation through intestate inheritance and failure by heirs to timely probate the land and clear title. But reformers have worked diligently to address the problem by passing the Uniform Real... 2023
Amy Royce, Amy Matsui UNSUPPORTED: UNDERINVESTMENT IN THE CARE ECONOMY DRIVES GENDER AND RACIAL WEALTH GAPS 48 Human Rights 14 (2023) For every dollar of wealth owned by a single white man, single Black women and Latinas own roughly 9 cents. That gap is stark--and consequential. Wealth is commonly understood as people's assets minus their debts, or, in other words, their total available resources. People need wealth to cope with unexpected moments in the present, like a... 2023
Phyllis C. Taite WELFARE v. WEALTHFARE: THE ILLUSION OF EQUALITY IN TAX POLICY 20 Pittsburgh Tax Review 363 (Spring, 2023) Tax laws and policies may be perceived as race-neutral because race data is not used to determine tax liability. Similarly, the rate structure may be perceived as progressive because tax rates increase as income increases. Nonetheless, history has demonstrated that tax laws and policies are biased against race and class and the tax system is not... 2023
Hans Hodes WHAT A SAVE! HOW U.S. TAX POLICIES COULD GROW MAJOR LEAGUE SOCCER, INCREASE PLAYER TALENT, AND STRENGTHEN YOUTH DEVELOPMENT 92 UMKC Law Review 427 (Winter 2023) The United States, alongside Mexico, and Canada, will host the 2026 World Cup. Out of the sixteen host cities for the 2026 World Cup, eleven are in the United States. The tournament brings a host country celebration, excitement, and the opportunity to showcase, internationally, its culture, people, and passion for soccer. Moreover, hosting the... 2023
Connor D. Hicks WITHOUT RESERVATION: ENSURING UNIFORM TREATMENT IN BANKRUPTCY WHILE KEEPING IN MIND THE INTERESTS OF NATIVE AMERICAN INDIVIDUALS AND TRIBES 28 Fordham Journal of Corporate and Financial Law 341 (2023) The Bankruptcy Code (Code) exists as a mechanism for good faith debtors to discharge debts and seek a fresh start in life and finance. 11 U.S.C. § 106(a) ensures that not only are all debtors treated uniformly, but that all creditors, including governmental creditors which may otherwise enjoy immunity from suit, are equally subject to the... 2023
Bridget J. Crawford, W. Edward Afield YESTERDAY'S PROTESTER MAY BE TOMORROW'S SAINT: REIMAGINING THE TAX SYSTEM THROUGH THE WORK OF DOROTHY DAY 76 Tax Law Review 217 (Spring, 2023) Even would-be saints don't always pay their tax bills. Dorothy Day, who lived from 1897 to 1980, was a legendary U.S. activist and cofounder of the Catholic Worker movement. Day worked most of her adult life among the poor; she was a lifelong advocate for workers' rights and social justice. The Catholic Church named Day a Servant of God... 2023
William Organek "A BITTER RESULT": PURDUE PHARMA, A SACKLER BANKRUPTCY FILING, AND IMPROVING MONETARY AND NONMONETARY RECOVERIES IN MASS TORT BANKRUPTCIES 96 American Bankruptcy Law Journal 361 (Spring, 2022) Purdue Pharma, the maker of OxyContin®, filed for bankruptcy in 2019 to resolve thousands of opioid-related lawsuits. The settlement reached in the case would release the controlling Sackler family from all opioid-related liability in exchange for a Sackler financial contribution--without requiring the Sacklers to file for bankruptcy. Critics... 2022
Samuel Ackerman "STAMPING" OUT THE POSTAGE POLL TAX 55 Columbia Journal of Law and Social Problems 331 (Winter, 2022) In the 1966 case of Harper v. Virginia Board of Elections, the Supreme Court abolished the last vestiges of the Jim Crow-Era poll tax in one fell swoop under the Equal Protection Clause. The opinion emphasized that paying a tax or fee is irrelevant to one's qualifications for voting and invidiously discriminates against the poor. Litigants have... 2022
Reece Barker A MEMORIAL AND REMONSTRANCE AGAINST TAXATION OF CHURCHES 47 Brigham Young University Law Review 1001 (2022) C1-2Contents Introduction. 1001 I. Memorial and Remonstrance Against Taxation of Churches. 1004 A. The Church Is Not Within Cognizance of the State's Taxation Power. 1006 B. The Dangers of Taxing Religious Organizations. 1008 C. Counterarguments. 1013 II. The Historical Practice of Exempting Churches from Income and Property Taxation. 1015 A. Case... 2022
Helen Sprainer AIR QUALITY EQUITY: WHY THE CLEAN AIR ACT FAILED TO PROTECT LOW-INCOME COMMUNITIES AND COMMUNITIES OF COLOR FROM COVID-19 30 New York University Environmental Law Journal 123 (2022) The effects of the COVID-19 pandemic highlight the many ways in which low-income communities and communities of color suffer disproportionate harms during a disaster. This pandemic is an environmental injustice because the inequitable development and enforcement of our environmental laws has left some communities more at risk for serious infection... 2022
Alex Zhang ANTIDISCRIMINATION AND TAX EXEMPTION 107 Cornell Law Review 1381 (July, 2022) The Supreme Court held, in Bob Jones University v. United States, that violations of fundamental public policy--including race discrimination in education--disqualify an entity for tax exemption. The holding of the case was broad, and its results cohered with the ideals of progressive society: the government ought not to subsidize discrimination,... 2022
Taylor C. Holley AUDITING SCIENTOLOGY: REEXAMINING THE CHURCH'S 501(C)(3) TAX EXEMPTION ELIGIBILITY 54 Texas Tech Law Review 345 (Winter, 2022) I. Introduction. 346 II. Church and Legislative History. 347 A. The Origins of Scientology. 347 1. L. Ron Hubbard and Dianetics. 348 2. A Religion Is Born from the Principles of Dianetics. 349 B. Criteria for Obtaining and Requirements for Maintaining § 501(c)(3) Status. 353 1. Statutory Criteria. 353 2. The Common Law Requirement. 355 C.... 2022
Courtney Kobren BANKRUPTCY BASICS: WHAT THE U.S. CAN LEARN FROM THE U.K. FILING PROCESSES 32 Duke Journal of Comparative & International Law 441 (Spring, 2022) Although filing for bankruptcy is the primary form of economic relief for U.S. consumers in financial distress, pro se debtors lack access to the consumer bankruptcy system. An individual debtor faces many challenges when filing for bankruptcy without an attorney, since the debtor must rely on free access to the information provided by the U.S.... 2022
Daryl J. Smith , Office of the Chapter 13, Standing Trustee, Memphis, Tenn. BANKRUPTCY CAN BE A MEANS TO ECONOMIC JUSTICE AND EQUALITY 41-NOV American Bankruptcy Institute Journal 36 (November, 2022) Cancer does not discriminate; it can touch anyone at any time. Similarly, debt does not discriminate. Like cancer, debt can be a disease impacting a person's life. Also like cancer, debt affects all ethnicities, the young, the old, the rich, the poor, the uneducated and the educated. Along the lines of a harsh disease, debt can eat away at a... 2022
Samuel D. Brunson BARGAIN BASEMENT PROGRESSIVITY? CONSTITUTIONAL FLAT TAXES, DEMOGRANTS, AND PROGRESSIVE INCOME TAXATION 53 Loyola University Chicago Law Journal 683 (Summer, 2022) State and local governments raise revenue in three primary ways: property, sales, and income taxes. Property and sales taxes tend to impose a higher burden on low-income households. To ensure the fairness and progressivity of their overall revenue system, states need their income tax to be sufficiently progressive. Four states face an apparently... 2022
Goldburn P. Maynard Jr. BIDEN'S GAMBIT: ADVANCING RACIAL EQUITY WHILE RELYING ON A RACE-NEUTRAL TAX CODE 131 Yale Law Journal Forum 656 (January 9, 2022) The American Rescue Plan Act was both a major infusion of economic aid to low-income and middle-class Americans and an opportunity for the Biden Administration to keep its promise to promote racial equity. This Essay analyzes ARPA's major provisions to determine their potential impact on racial equity. It argues that the Biden... 2022
Goldburn P. Maynard Jr. BIDEN'S GAMBIT: ADVANCING RACIAL EQUITY WHILE RELYING ON A RACE-NEUTRAL TAX CODE 131 Yale Law Journal Forum 656 (1/9/2022) abstract. The American Rescue Plan Act was both a major infusion of economic aid to low-income and middle-class Americans and an opportunity for the Biden Administration to keep its promise to promote racial equity. This Essay analyzes ARPA's major provisions to determine their potential impact on racial equity. It argues that the Biden... 2022
Ishaq Kundawala BITING THE BULLET: A BIPARTISAN SOLUTION TO INCREASE DEBTORS' ACCESS TO CHAPTER 7 RELIEF WHILE EXEMPTING FIREARMS IN A BANKRUPTCY CASE 56 Indiana Law Review 33 (2022) Introduction I. A Brief History of the Current Practices Regarding Debtors' Payment of Bankruptcy Attorneys' Fees in Chapter 7 Cases II. Understanding the Disparate Social Impact of the Current Payment Practices on Debtors' Bankruptcy Chapter Choices and Eventual Case Outcomes III. Examining the Two-Contract Approach to the Payment of Chapter 7... 2022
Melody R. Webb, Esq. BUILDING A GUARANTEED INCOME TO END THE "CHILD WELFARE" SYSTEM 12 Columbia Journal of Race and Law 1 (July, 2022) I. Disparities in the Child Welfare System. 3 A. The Child Welfare System is Racialized. 3 B. Current Child Welfare Policies Reflect Historically Racialized Approaches to Child Welfare and Cash Assistance Programs.. 4 C. Anti-Black Racist Policies Demobilize Black American Parents. 7 II. Confronting the Risk Factor for Neglect. 8 A. American... 2022
Jeremy Bearer-Friend COLORBLIND TAX ENFORCEMENT 97 New York University Law Review 1 (April, 2022) The United States Internal Revenue Service (IRS) has repeatedly taken the position that because the IRS does not ask taxpayers to identify their race or ethnicity on submitted tax returns, IRS enforcement actions are not affected by taxpayers' race or ethnicity. This claim, which I call colorblind tax enforcement, has been made by multiple IRS... 2022
Anthony Rychkov CRITICAL TAX THEORY: COMBATTING RACIAL AND INCOME INEQUALITY IN AMERICA 21 Seattle Journal for Social Justice 87 (Fall, 2022) Critical race theory holds that racism is not merely the product of individual bias and prejudices but also something embedded in legal systems and policies. This article will particularly discuss critical race theory and its effects on U.S. tax policies, something I would like to call critical tax theory. As Benjamin Franklin famously noted,... 2022
Allison Tait DEBT GOVERNANCE, WEALTH MANAGEMENT, AND THE UNEVEN BURDENS OF CHILD SUPPORT 117 Northwestern University Law Review 305 (2022) Abstract--Child support is a ubiquitous kind of debt, common to all income and wealth levels, with data showing that approximately 30% of the U.S. adult population has either been subject to paying child support or has received it. Across this field of child support debt, however, unpaid obligations look different for everyone, and in particular... 2022
1 2 3 4 5 6 7 8 9 10 11