James A. Long THE LOW-INCOME HOUSING TAX CREDIT IN NEW JERSEY: NEW OPPORTUNITIES TO DECONCENTRATE POVERTY THROUGH THE DUTY TO AFFIRMATIVELY FURTHER FAIR HOUSING 66 New York University Annual Survey of American Law 75 (2010) The federal Low Income Housing Tax Credit (LIHTC) program has produced over one million rental housing units from 1995 to 2005, most of which are affordable to low-income tenants. Developers of low-income rental housing apply for federal income-tax credits to subsidize their affordable housing units through a competitive process administered by the... 2010
John D. Colombo THE NCAA, TAX EXEMPTION, AND COLLEGE ATHLETICS 2010 University of Illinois Law Review 109 (2010) This Article discusses the contentious topic of the National Collegiate Athletic Association's (NCAA) status as a tax-exempt organization. In late 2006, Congress asked the NCAA to justify its exempt status, and since that time many have called for a change in that status. Calls for reform cite reasons such as the amount of money paid to Division I... 2010
Shi-Ling Hsu THE POLITICS AND PSYCHOLOGY OF GASOLINE TAXES: AN EMPIRICAL STUDY 15 Widener Law Review 363 (2010) Economists are beginning to form a consensus that a carbon tax is the most effective and cost-effective way to reduce global greenhouse gas emissions. The insight of economists and other policy analysts is that, in the greenhouse gas context, the design of cap-and-trade programs creates so many opportunities for rent-seeking that they may not be... 2010
Nikki Usher, Michelle D. Layser THE QUEST TO SAVE JOURNALISM: A LEGAL ANALYSIS OF NEW MODELS FOR NEWSPAPERS FROM NONPROFIT TAX-EXEMPT ORGANIZATIONS TO L3CS 2010 Utah Law Review 1315 (2010) The proliferation of online news sources masks a deepening crisis in American journalism. Newspapers, which continue to be the linchpin of original news reporting, are facing unprecedented economic pressures--largely due to the rise of new media--that have forced nearly all major newspapers to lay off large numbers of journalists, reduce the scope... 2010
John Jacobsen THE REASONABLE PROFESSIONAL IN BANKRUPTCY 31 California Bankruptcy Journal 549 (2010) Sections 328 and 330 of the Bankruptcy Code provide, respectively, for ex-ante and ex-post review of the employment terms and conditions for professionals retained in bankruptcy. While both sections provide guidelines for approving the employment of professionals in Chapter 11 bankruptcy, significant judicial discretion remains a defining feature.... 2010
David Fautsch THE TAX INJUNCTION ACT AND FEDERAL JURISDICTION: REASONING FROM THE UNDERLYING GOALS OF FEDERALISM AND COMITY 108 Michigan Law Review 795 (March, 2010) States routinely contest federal jurisdiction when a state tax is challenged in federal district court on federal constitutional grounds. States argue that the Tax Injunction Act, 28 U.S.C. § 1341 (2006), bars jurisdiction and, even if the Tax Injunction Act does not apply, the principals of federalism and comity require abstention. The United... 2010
Richard D. Pomp THE UNFULFILLED PROMISE OF THE INDIAN COMMERCE CLAUSE AND STATE TAXATION 63 Tax Lawyer 897 (Summer, 2010) I. Introduction 902 II. The Early Days 912 A. Colonial America and the Crown 912 B. The Revolutionary War and the Confederation 922 1. The Revolutionary War 922 2. Articles of Confederation 925 3. Article IX of the Articles of Confederation 927 C. Post-Revolutionary War 929 III. Birth of the Indian Commerce Clause 932 A. The Constitutional... 2010
Miranda Perry Fleischer THEORIZING THE CHARITABLE TAX SUBSIDIES: THE ROLE OF DISTRIBUTIVE JUSTICE 87 Washington University Law Review 505 (2010) Distributive justice plays a starring role in many fundamental tax policy debates, from the marginal rate structure to the choice of base to the propriety of wealth transfer taxes. In contrast, current tax scholarship on the charitable tax subsidies generally either ignores or explicitly disavows distributive justice concerns. Instead, it focuses... 2010
Michael R. Gordon UP THE AMAZON WITHOUT A PADDLE: EXAMINING SALES TAXES, ENTITY ISOLATION, AND THE "AFFILIATE TAX" 11 North Carolina Journal of Law & Technology 299 (Spring 2010) As a result of the Supreme Court's decision in Quill v. North Dakota, unless a retailer has a physical presence in a state, it is not obliged to collect sales taxes in that state. In order to avoid collecting sales taxes, many companies like have set up subsidiary companies in many states to ship, but not sell, goods to customers. This... 2010
Beverly Moran WEALTH REDISTRIBUTION AND THE INCOME TAX 53 Howard Law Journal 319 (Winter 2010) This section of the Howard Law Journal is devoted to the question of wealth redistribution. The section on wealth redistribution contains five views of the United States tax system. This article asks how the tax system can stand against increasing income and wealth inequality. Part I of this article presents evidence of the increasing trend towards... 2010
Diane Ring WHO IS MAKING INTERNATIONAL TAX POLICY?: INTERNATIONAL ORGANIZATIONS AS POWER PLAYERS IN A HIGH STAKES WORLD 33 Fordham International Law Journal 649 (February, 2010) In a world in which international tax policy is no longer predominantly within the purview of the individual state, and the number of important international tax questions has grown dramatically, where is the locus of power? If there are many questions regarding international tax policy, and if they must be evaluated beyond the level of the... 2010
Clayton P. Gillette WHO SHOULD AUTHORIZE A COMMUTER TAX? 77 University of Chicago Law Review 223 (Winter, 2010) The decision to impose a commuter taxa tax on income earned within the city by nonresidentsis typically made at the state level. There are both doctrinal and economic reasons for this allocation of authority. Cities are creatures of the states of which they are political subdivisions, and legal doctrine requires that they receive either state... 2010
Adam H. Rosenzweig WHY ARE THERE TAX HAVENS? 52 William and Mary Law Review 923 (December, 2010) Recently, the issue of tax havens has risen to the fore of the fiscal policy debate, with tax havens being singled out as the root cause of many of the fiscal shortfalls plaguing the governments of the world. Surprisingly, however, although there has been a fair amount of literature on why tax havens are harmful to the modern international tax... 2010
Marcia Johnson WILL THE CURRENT ECONOMIC CRISIS FUEL A RETURN TO RACIAL POLICIES THAT DENY HOMEOWNERSHIP OPPORTUNITY AND WEALTH? 6 Modern American 25 (Spring, 2010) Property ownership in America has traditionally been linked to power and wealth. French political historian Alexis de Tocqueville observed, [T]he love of property is keener in the United States than it is anywhere else, and Americans therefore display less inclination toward doctrines that threaten, in any way, the way property is owned.... 2010
Rafael Efrat WOMEN ENTREPRENEURS IN BANKRUPTCY 45 Tulsa Law Review 527 (Spring 2010) Women are a significant and an emerging part of the American small business community. Some have described this development as one of the most striking trends in the U.S. labor market. Female-owned businesses generate almost a trillion dollars in revenues every year and employ more than seven million workers. Women represent one of the fastest... 2010
Ajay K. Mehrotra "RENDER UNTO CAESAR . . .": RELIGION/ETHICS, EXPERTISE, AND THE HISTORICAL UNDERPINNINGS OF THE MODERN AMERICAN TAX SYSTEM 40 Loyola University Chicago Law Journal 321 (Winter 2009) A variety of scholars and commentators have been recently exploring the relationship between religion and current U.S. tax policy. Whereas some legal scholars have evoked biblical pronouncements to evaluate present tax laws and policies, others have revisited classic hermeneutical practices to decipher modern lessons from ancient Judeo-Christian... 2009
Ming-Sung Kuo (DIS)EMBODIMENTS OF CONSTITUTIONAL AUTHORSHIP: GLOBAL TAX COMPETITION AND THE CRISIS OF CONSTITUTIONAL DEMOCRACY 41 George Washington International Law Review 181 (2009) The initial onset of globalization generated optimism regarding the possible creation of a global legal universe capable of transcending the borders of demos-centered constitutional states. This optimism, however, remains unfulfilled. Constitutional democracy, meanwhile, as currently understood, is undergoing an institutional self-transformation.... 2009
Stephanie Hunter McMahon A LAW WITH A LIFE OF ITS OWN: THE DEVELOPMENT OF THE FEDERAL INCOME TAX STATUTES THROUGH WORLD WAR I 7 Pittsburgh Tax Review 1 (Fall, 2009) In a debate over the income tax in 1864, Justin Morrill (R-Vt.) protested that the tax's graduated rate structure made it no less than a confiscation of property. Three years earlier, however, he had been one of the staunchest congressional supporters of the first federal income tax, a flat-rate tax enacted as part of the Revenue Act of 1861.... 2009
Sagit Leviner A NEW ERA OF TAX ENFORCEMENT: FROM 'BIG STICK' TO RESPONSIVE REGULATION 42 University of Michigan Journal of Law Reform 381 (Winter 2009) This Article explores the economics of crime and compliance as the dominant approach to U.S. tax enforcement of the past three and a half decades. It evaluates the key advantages and disadvantages of the economic model as well as its application to tax. The Article then addresses the multiplicity of taxpayer behavior and the need and prospect of... 2009
Catherine A. Clancy A ROLE FOR TAX ATTORNEYS IN ANTITRUST LAW?: VARIABLE-COST TAX SAVINGS AS A MERGER EFFICIENCY DEFENSE 62 Tax Lawyer 475 (Winter, 2009) A merger efficiency defense should be permitted for variable-cost tax savings under United States, European Union, and Canadian antitrust law. Mergers in the United States, the European Union, and Canada must be approved, based on a showing that the efficiencies from the merger outweigh potential anticompetitive effects in the relevant market. No... 2009
Timothy R. Tarvin, Assistant Professor A STEP-BY-STEP GUIDE TO CHAPTER 7 CONSUMER BANKRUPTCY IN ARKANSAS FROM THE DEBTOR'S PERSPECTIVE 2009 Arkansas Law Notes 183 (2009) Anyone who watches television or reads the newspaper is aware that the country is in a severe economic downturn. Not surprisingly, bankruptcy filings are clearly on the rise. The predictions of an increase in bankruptcy filings for this year are now coming true. The surge in filings is not surprising. The three most common causes of consumer... 2009
Rory Van Loo A TALE OF TWO DEBTORS: BANKRUPTCY DISPARITIES BY RACE 72 Albany Law Review 231 (2009) Legal policy has long struggled with the issue of official neutrality in the face of racially disparate results. While the days of laws explicitly discriminating against people of color may be gone, the legal system as a whole has not attained perfect race neutrality. Scholars have offered evidence of this tension in disparate spheres such as... 2009
Nevin M. Gewertz ACT OR ASSET? MULTIPLICITOUS INDICTMENTS UNDER THE BANKRUPTCY FRAUD STATUTE, 18 USC § 152 76 University of Chicago Law Review 909 (Spring, 2009) Dishonest participation in the civil bankruptcy system undermines its central aimsdebtor relief and equitable redistribution. The bankruptcy fraud statute, 18 USC § 152, protects against this form of behavior. Unlike other criminal statutes, however, its importance lies less with deterring the acts that it proscribes and more with enforcing civil... 2009
Jack F. Williams, Deborah L. Thorne, Ronald J. Silverman, Ben Pickering AMERICAN BANKRUPTCY INSTITUTE MEDIA TELECONFERENCE TO EXAMINE THE FUTURE OF AUTOMOTIVE SECTOR DISTRESS 17 American Bankruptcy Institute Law Review 105 (Spring, 2009) Jack F. Williams The coming demise of the Detroit Three has captured the attention of the country and has catapulted bankruptcy practitioners to rock star status. Well, maybe not rock star status, but ordinary folks have developed a keener appreciation of what we do. And so has Congress. In the Winter of 2008, Congress held hearings on whether to... 2009
Adam J. Levitin BANKRUPTCY MARKETS: MAKING SENSE OF CLAIMS TRADING 4 Brooklyn Journal of Corporate, Financial & Commercial Law 67 (Fall, 2009) The creation of a market in bankruptcy claims is the single most important development in the bankruptcy world since the Bankruptcy Code's enactment in 1978. Claims trading has revolutionized bankruptcy by making it a much more market-driven process. The limited scholarly literature on claims trading, however, while recognizing its radical impact,... 2009
Diane L. Fahey CAN TAX POLICY STOP HUMAN TRAFFICKING? 40 Georgetown Journal of International Law 345 (Winter, 2009) The total number of victims who are held in captivity to perform forced labor at any one time is estimated to be as high as twenty-seven million. That would be equivalent to every man, woman, and child in the states of New Hampshire, Vermont, Massachusetts, and New York being held in captivity and forced for twelve to fourteen hours each day to... 2009
Bruce Ackerman , Jennifer Nou CANONIZING THE CIVIL RIGHTS REVOLUTION: THE PEOPLE AND THE POLL TAX 103 Northwestern University Law Review 63 (Winter 2009) I. New Generation. 63 II. The Twenty-Fourth Amendment. 69 A. New Deal Roots. 71 B. Interregnum: Between the New Deal and the Civil Rights Era. 75 C. Process. 79 III. The Voting Rights Act of 1965. 87 A. The Shadow of the Twenty-Fourth. 88 B. Action and Reaction. 98 IV. Erasure by Judiciary: Harper v. Virginia Board of Elections. 111 A. The Goldberg... 2009
Margaret McFarland, Editor-in-Chief Capital Tax Harmonization and Agglomeration Economies in the European Union 38 Real Estate Review Journal 3 (Winter 2009) Pamela Hannigan is a member of the full-time faculty at New York University's Schack Institute of Real Estate where she teaches Real Estate Economics and Market Analysis. Her background in economics includes advanced degrees, research, and executive management in banking, investment banking, and public finance. She is currently involved with the... 2009
Dalton Conley COMMENTARY TAX REVOLTS, PREGNANCY ENVY, RACE, AND THE "DEATH TAX" 63 Tax Law Review 261 (Fall 2009) Many political scientists and sociologists are puzzled by the fact that the more progressive taxes are, the less they are accepted by populations. There is, for example, broad acceptance of value added taxes (VATs) or sales taxes, but more resistance to an income tax, which is, of course, generally more progressive than consumption taxes. But the... 2009
Elina Chechelnitsky D&O INSURANCE IN BANKRUPTCY: JUST ANOTHER BUSINESS CONTRACT 14 Fordham Journal of Corporate and Financial Law 825 (2009) In July 2008, bankruptcy courts across the nation prepared themselves for a busy season. As many as 5,664 companies sought to liquidate or restructure that month alone, a 57% increase from the prior year. Just two months later, the largest corporate bankruptcy yet hit the world financial markets hard and swept away the lifetime investments of... 2009
Diane Ring DEMOCRACY, SOVEREIGNTY AND TAX COMPETITION: THE ROLE OF TAX SOVEREIGNTY IN SHAPING TAX COOPERATION 9 Florida Tax Review 555 (2009) Virtually all efforts to confront and curb tax competition effectively require some measure of cooperation among nation-states. Regardless of the precise amount and type of competition deemed acceptable, the cooperation question arises. Only for those who would advocate a complete acceptance of all forms of tax competition would cooperation seem... 2009
Stephen J. Lubben DERIVATIVES AND BANKRUPTCY: THE FLAWED CASE FOR SPECIAL TREATMENT 12 University of Pennsylvania Journal of Business Law 61 (Fall 2009) The casual reader of recent scholarship on the treatment of contracts in chapter 11 could easily suppose that the Bankruptcy Code is the source of great injustices and inefficiencies. According to the standard account, chapter 11 locks third parties into inefficient contracts while allowing the debtor to cherry pick which contracts it wants to... 2009
David Schneider DIVIDING TO UNITE: HOW WE CAN REACH COMMON DEVELOPMENT GOALS WHEN DEVELOPED COUNTRIES AND DEVELOPING COUNTRIES ADOPT DIFFERENT TAX SYSTEMS 2009-SUM Federal Bar Association Section of Taxation Report 12 (Summer, 2009) Taxpayers resident in countries with a worldwide tax system have an incentive to invest in high-tax countries, whereas taxpayers resident in countries with a territorial tax system have an incentive to invest in low-tax countries. Under the global economy's ad hoc patchwork of tax systems, many developing countries are forced to engage in a tax... 2009
Johnny Rex Buckles DO LAW SCHOOLS FORFEIT FEDERAL INCOME TAX EXEMPTION WHEN THEY DENY MILITARY RECRUITERS FULL ACCESS TO CAREER SERVICES PROGRAMS?: THE HYPOTHETICAL CASE OF YALE UNIVERSITY V. COMMISSIONER 41 Arizona State Law Journal 1 (Spring 2009) The overwhelming majority of United States law schools prohibit prospective employers from utilizing the schools' official programs for student recruitment if those employers discriminate against students on any of several grounds, including sexual orientation. By virtue of these longstanding anti-discrimination policies, some law schools at times... 2009
Lars Lefgren , Frank McIntyre , Brigham Young University, Brigham Young University EXPLAINING THE PUZZLE OF CROSS-STATE DIFFERENCES IN BANKRUPTCY RATES 52 Journal of Law & Economics 367 (May, 2009) Bankruptcy rates vary tremendously across states, and it is not obvious why. The number of candidate explanations is large relative to the number of states. To overcome this problem, we use zip-code-level data to identify the importance of demographic variables using within-state variation. This preserves state-level degrees of freedom to identify... 2009
Richard Lavoie FLYING ABOVE THE LAW AND BELOW THE RADAR: INSTILLING A TAXPAYING ETHOS IN THOSE PLAYING BY THEIR OWN RULES 29 Pace Law Review 637 (Summer 2009) These days it really does seem like only the little people pay taxes. Whether they are from the world of politics, sports, or entertainment, the elites of this country are demonstrating a penchant for not paying their taxes. Nevertheless, Americans in general continue to exhibit a high degree of tax compliance. Why do most people pay their taxes?... 2009
Ann Mumford FROM DAHOMEY TO LONDON TO DC: "MARKETING" WEALTH WITH THE PROPOSAL FOR A COMPREHENSIVE INHERITANCE TAX 63 Tax Law Review 221 (Fall 2009) In Lily Batchelder's fascinating proposal to replace the estate tax with a comprehensive inheritance tax, two problems are identified with the current law, highlighting reasons why the estate tax is not necessarily in need of revival. First, when compared with other aspects of the U.S. tax system, the estate tax favors those who inherit their... 2009
Mehmet Bac , Faculty of Arts and Social Sciences, Sabanci University, Orhanli, Tuzla, Istanbul 34956, Turkey GENERALIZED TRUST AND WEALTH 29 International Review of Law & Economics 46 (March, 2009) JEL classification: Z13 D30 D82 Keywords: Trust Incomplete information Inequality Wealth Enforcement The relation between economic inequality and trust is studied in a model where the ability to elicit trustworthiness from unrelated people depends on own wealth as well as the distribution and mean of population wealth. In equilibrium, the rich... 2009
Eric M. Zolt INEQUALITY, COLLECTIVE ACTION, AND TAXING AND SPENDING PATTERNS OF STATE AND LOCAL GOVERNMENTS 62 Tax Law Review 445 (Summer 2009) Observers of colonial America noted the remarkable diversity in the new world. One important way in which regions differed was the relative inequality that existed among and within the colonies before independence and among and within the states after independence. In this Article, I examine how state and local differences in inequality may have... 2009
Richard Weiss MICHIGAN BUSINESS TAX OFFERS MANY TAX CREDIT OPPORTUNITIES 19-NOV Journal of Multistate Taxation and Incentives 10 (November/December, 2009) Although the SBT has been replaced by the MBT, the state did not change its overall philosophy of offering an extensive number of diverse tax credits. Effective in 2008, Michigan switched its corporate tax structure from the Single Business Tax (SBT) to the Michigan Business Tax (MBT). The purported rationale for this change was to provide a tax... 2009
Andrew B. Dawson OFFSHORE BANKRUPTCIES 88 Nebraska Law Review 317 (2009) I. Introduction. 317 II. Background. 321 A. International Bankruptcy Forum Shopping. 321 B. American Perspective on Forum Shopping. 324 III. The Bankruptcy Code and Cross-Border Insolvencies. 325 IV. Cases. 331 A. Tri-Continental. 331 B. SPhinX. 332 C. Bear Stearns. 334 V. Methodology. 335 VI. Findings. 336 A. Re-Incorporation as Bankruptcy... 2009
Dorothy A. Brown RACE, CLASS, AND THE OBAMA TAX PLAN 86 Denver University Law Review 575 (2009) This Essay examines three areas of federal tax policy: (i) the exclusion for employer provided pensions; (ii) the mortgage interest deduction; and (iii) the earned income tax credit for the working poor. Each of the three areas is addressed in The Obama Tax Plan. My previous research showed that in those three areas, low-income taxpayers were... 2009
Elizabeth K. Julian RECENT ADVOCACY RELATED TO THE LOW INCOME HOUSING TAX CREDIT AND FAIR HOUSING 18-WTR Journal of Affordable Housing & Community Development Law 185 (Winter, 2009) We have long recognized that government can and should act to ensure that all people have a decent place to live. And we know that place means not only the housing structure but where it is located. The Low Income Housing Tax Credit (LIHTC) program is the latest in a line of programs through which we have chosen to address this worthy goal.... 2009
Adam J. Levitin RESOLVING THE FORECLOSURE CRISIS: MODIFICATION OF MORTGAGES IN BANKRUPTCY 2009 Wisconsin Law Review 565 (2009) This Article empirically tests the economic assumption underlying the policy against bankruptcy modification of home-mortgage debt--that protecting lenders from losses in bankruptcy encourages them to lend more and at lower rates, and thus encourages homeownership. The data show that the assumption is mistaken; permitting modification would have... 2009
Darryll K. Jones SOPHISTRY, SITUATIONAL ETHICS, AND THE TAXATION OF THE CARRIED INTEREST 29 Northwestern Journal of International Law and Business 675 (Summer 2009) This Article is, in essence, a strident expression of indignation about what a majority of tax scholars and, indeed, legislators consider a glaring yet persistent inequity in the tax code. In short, sometimes extraordinarily well-paid fund managers receive compensation taxed at capital gains rates. All other, usually very much lower-compensated,... 2009
Allison Christians SOVEREIGNTY, TAXATION AND SOCIAL CONTRACT 18 Minnesota Journal of International Law 99 (Winter 2009) Tax policy creates and reflects relationships between the market, the citizen, and the state. As a result, traditional tax policy discourse centers around the premise that decisions about taxation should be made exclusively within nations, independent of outside concern and interference. But this view of sovereign autonomy over taxation is... 2009
William A. Drennan STRICT LIABILITY AND TAX PENALTIES 62 Oklahoma Law Review 1 (Fall, 2009) Tax evaders [are] stealing from their fellow citizens. The more successfully they escape what they owe, the more the rest of us have to pay. Taxpayers who fail to pay their fair share cause each honest taxpayer to pay on average over $2000 extra in federal income taxes every year. This extra burden falls primarily on the working class and the poor,... 2009
Joni Larson TAX EVIDENCE III: A PRIMER ON THE FEDERAL RULES OF EVIDENCE AS APPLIED BY THE TAX COURT 62 Tax Lawyer 555 (Spring, 2009) I. Introduction. 557 II. General Provisions. 558 Rule 101. Scope. 558 Rule 102. Purpose and Construction. 558 Rule 103. Rulings on Evidence. 559 Rule 104. Preliminary Questions. 561 Rule 105. Limited Admissibility. 562 Rule 106. Remainder of or Related Writings or Recorded Statements. 563 III. Judicial Notice. 566 Rule 201. Judicial Notice. 566 IV.... 2009
Atiba R. Ellis THE COST OF THE VOTE: POLL TAXES, VOTER IDENTIFICATION LAWS, AND THE PRICE OF DEMOCRACY 86 Denver University Law Review 1023 (2009) The election of Barack Obama as the forty-fourth President of the United States represents both the completion of a historical campaign season and a triumph of the Civil Rights revolution of the twentieth century. President Obama's 2008 campaign, along with the campaigns of Senators Hillary Rodham Clinton and John McCain, was remarkable in both the... 2009
Richard T. Page THE INTERNATIONAL AND COMPARATIVE TAX WAR: A STRATEGIC TAX CUT RECOMMENDATION FOR THE OBAMA ADMINISTRATION 18 Tulane Journal of International and Comparative Law 287 (Winter 2009) I. Introduction. 287 A. Purpose Statement. 287 B. Summary of Conclusion. 288 II. Analysis. 288 A. Overview. 288 B. Foreign Tax Rate Trends: A State of Gradual Decline. 289 1. Foreign Corporate Tax Rates Are Decreasing. 289 2. Foreign Personal Income Tax Rates Are Decreasing. 292 3. Diminishing and Nonexistent Estate Taxes Around the World. 293 C.... 2009
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