Tuesday, July 17, 2007

tanks - du pont - torque - worm - falsetto - moth larvae - BFML - eugenics - bounty - taxes - dorks - google ranking

[7/16/2007 10:19:22 AM] pD says: howdy AE

[7/16/2007 10:19:25 AM] pD says: is nsy in LA?

[7/16/2007 10:20:30 AM] AE shrugs

[7/16/2007 10:20:39 AM] AE says: no idea. She's apparently not here.

[7/16/2007 10:20:50 AM] AE is master of the obvious

[7/16/2007 10:20:51 AM] pD says: you are a very shrewd observer

[7/16/2007 10:31:06 AM] AE says: http://www.youtube.com/watch?v=0AcVSEY2DP0&mode=related&search=

[7/16/2007 10:35:13 AM] AE says: here's the story on the recent one: http://news.bbc.co.uk/2/hi/asia-pacific/6898667.stm

[7/16/2007 10:36:26 AM] AE says: and the back story on the San Diego incedent:http://en.wikipedia.org/wiki/Shawn_Nelson

[7/16/2007 10:36:30 AM] AE has changed the chat topic to "Tanked"

[7/16/2007 10:36:45 AM] AE has changed the chat topic to "Tanks a Lot"

[7/16/2007 10:37:11 AM] pD says: John E. Du Pont is the name of the du pont guy

[7/16/2007 10:37:26 AM] pD says: and, i am afraid that i may have mixed up the san diego tank story with the du pont story

[7/16/2007 10:37:41 AM] pD says: he (du pont) was not killed - he was just known to drive his tank on his estate

[7/16/2007 10:37:55 AM] pD says: he is, however, in prison for a murder conviction

[7/16/2007 10:37:56 AM] AE says: which is actually pretty fun!

[7/16/2007 10:38:02 AM] AE says: oh.. that's not fun.

[7/16/2007 10:38:12 AM] AE says: ever driven a tank/tracked vehicle?

[7/16/2007 10:38:49 AM] AE says: they turn instantly. you can out accelerate most anything (up to about 25 MPH).

[7/16/2007 10:38:53 AM] pD says: never driven one - seems like an interesting experience

[7/16/2007 10:39:10 AM] AE says: very loud. very noisy. the old ones vibrate a lot too.

[7/16/2007 10:39:13 AM] AE says: but way fun.

[7/16/2007 10:40:08 AM] AE says: our boy scout troop got to ride in a M113 once. That was a kick for a bunch of kids!

[7/16/2007 10:40:30 AM] pD says: that is interesting - about acceleration - why would it be faster?

[7/16/2007 10:40:57 AM] AE says: you can lock both treads and rev the engine up. Then, all the torque is released at once.

[7/16/2007 10:41:20 AM] AE says: you can do the same thing in a car (called 'break barring"), but a tank has better traction.

[7/16/2007 10:41:41 AM] AE says: so it can apply all that torque at once, lurching the tank to it's maximum speed in seconds.

[7/16/2007 10:41:59 AM] AE says: of course... maximum speeds usually are not that impressive...

[7/16/2007 10:43:05 AM] pD says: that makes sense - ability to release the torque all at once

[7/16/2007 10:43:19 AM] pD says: i wonder how it has been used in combat situation - if any

[7/16/2007 10:43:42 AM] AE says: good question. I imagine it's pretty hard on the transmission...

[7/16/2007 3:11:32 PM] pD says: howdy!

[7/16/2007 3:11:37 PM] pD says: monday is always busy

[7/16/2007 7:25:20 PM] AE says: sorry... yes... very busy.

[10:15:15 AM] pD has changed the chat topic to "still tanking"

[10:16:07 AM] pD says: but, i think it begs the question of why/how does AE know so much about tank/tracked vehicle

[10:37:38 AM] pD says: okay, i have a worm on my desk

[10:37:41 AM] pD says: who wants to see

[10:37:49 AM] pD says: and, equally important, what do i do with it?

[10:37:59 AM] AE says: run your anti-virus scanner.

[10:38:04 AM] AE says: should take care of worms too.

[10:38:13 AM] pD says: it is onto my phone now

[10:38:26 AM] AE says: your phone has a worm?

[10:38:29 AM] AE says: that's a new one!

[10:38:30 AM] pD says: question: when do i pull up my pants and scream bloody murder?

[10:38:51 AM] pD says: a physical worm - brown/red-ish in color

[10:39:55 AM] AE says: scream now. We're on a conference call; it's boring and could use a little spicing up!

[10:40:39 AM] pD preparing for falsetto voice

[10:40:45 AM] pD says: aaaaahhhhhhhhhhhh

[10:40:53 AM] pD says: yiiiiiiiiiiiiiiiiiiiiiiiiiiii

[10:40:58 AM] pD says: uhhhhhhhhhhhhhhhhh

[10:41:21 AM] pD says: give me a few seconds to center myself

[10:41:38 AM] AE says: :D

[10:41:56 AM] pD says: (music)

[10:42:06 AM] AE says: (dance)

[10:42:09 AM] pD says: hummmmmmm (music)

[10:42:31 AM] pD says: Ooooooooooooooooooh my goooooooooooooood!!

(music)

[10:50:07 AM] pD says: actually, this reminds me of the book "confederacy of dunces"

[10:50:24 AM] pD says: the main character says "oh, my god" quite often

[10:50:34 AM] pD says: nsy

[10:50:45 AM] pD waving to get nsy's attention

[10:50:57 AM] AE says: we're both in a meeting right now.

[10:51:01 AM] AE says: so she may not be looking.

[10:51:14 AM] pD says: oh, she is just ignoring me, i know that

[10:51:35 AM] AE plays world smallest fiddle.

[11:33:22 AM] pD says: nsy

[11:33:31 AM] pD says: if you are okay with the idea

[11:33:36 AM] pD says: can you take a pix of the worm?

[11:33:55 AM] pD says: and, we probably need to give it a name too

[11:33:59 AM] pD says: but, i think a pix would help

[12:09:01 PM] pD says: i have set the worm free

[12:09:28 PM] pD says: the office environment is just no place for a self-respecting worm

[12:15:54 PM] AE says: really, this is not a law firm!

[12:19:24 PM] pD says: i thought they are sharks

[1:43:56 PM] nsy is done ignoring pD

[1:44:15 PM] nsy says: so, did you get a picture with my silly phone? is the worm free?

[1:44:28 PM] pD says: worm has been freed

[1:44:48 PM] pD says: well, i sent him flying through the 2nd floor window

[1:44:59 PM] pD says: hmm... that did not come out sounding right

[1:45:03 PM] pD says: anyway, he is on his own

[1:45:12 PM] pD says: as for photo, the memory card was full

[1:45:14 PM] pD says: so, no photo

[1:46:04 PM] pD says: but, nsy did have a look

[1:46:12 PM] pD says: so, is it more of a slug or a worm?

[1:47:35 PM] nsy says: there are windows that open?

[1:47:39 PM] nsy says: definitely a worm

[1:48:11 PM] pD says: in the small conference room that is the only one that opens - that i know of

[1:48:32 PM] pD says: say, can you find an image similar to the worm so AE can share the joy?

[1:49:31 PM] nsy says: trying- going to have daymares on these images - ugh

[1:50:22 PM] pD says: you too can pull up your pants and scream bloody murder

[1:54:15 PM] nsy says: bloody murder!

[1:54:38 PM] nsy says: i definitely thing its some sort of moth larvae.

[1:55:00 PM] pD says: no vocal warm up, just straight into it. good stuff.

[1:55:51 PM] pD says: http://crawford.tardigrade.net/bugs/figures/codapple.jpg

[1:55:57 PM] nsy says: just be glad it wasn't a pussworm http://rxwildlife.org.uk/images/Puss%20Moth.jpg

[1:56:22 PM] pD says: this is kind of close: http://www.yates.com.au/images/problemsolver/large/Codlingmoth.jpg

[1:56:30 PM] pD says: more red/brown in color though

[1:57:51 PM] pD says: unrelated, but this is a giant BFML: http://schmidling.com/impcat.jpg

[1:58:04 PM] pD says: imperial moth: http://images.google.com/imgres?imgurl=http://schmidling.com/impcat.jpg&imgrefurl=http://schmidling.com/impmoth.htm&h=368&w=400&sz=17&hl=en&start=109&um=1&tbnid=q27VFMzCpFkV4M:&tbnh=114&tbnw=124&prev=/images%3Fq%3Dmoth%2Blarvae%2Bpictures%26start%3D100%26ndsp%3D20%26svnum%3D10%26um%3D1%26hl%3Den%26rlz%3D1T4GGIH_enUS211US211%26sa%3DN

[1:58:21 PM] pD says: i will stop now

[1:58:40 PM] pD says: i have nothing against moth nor larvae, but it does make me feel a bit queasy

[1:58:54 PM] pD loves his artificial environment

[1:59:00 PM] nsy says: ooh - here are some good ones: http://www.mark-ju.net/wildlife/larvae.htm

[2:00:11 PM] nsy says: yeesh- that imperial larvae is freaky huge

[2:00:38 PM] pD says: (puke)

[2:00:57 PM] pD says: :O

[2:01:12 PM] pD says: as i said, i have nothing against them, but...

[2:01:58 PM] pD says: maybe this is how eugenics got its start. people wanting to have better looking larvae

[2:16:32 PM] nsy says: fascinating Eugenics archive: http://www.eugenicsarchive.org/eugenics/

[2:53:04 PM] pD has changed the chat topic to "bounty"

[2:53:26 PM] pD says: so, i heard that the bounty for bin laden has been upped to $50mm

[2:53:40 PM] pD says: but, a check on the FBI site shows that he is only worth 25mm

[2:53:45 PM] pD says: what gives! http://www.fbi.gov/wanted/topten/fugitives/laden.htm

[2:54:02 PM] pD says: btw, why is his name Usama on the FBI site instead of Osama?

[2:54:34 PM] pD says: i am sure that it is a gross bastardization of his name either case, so why not make it easier for the rest of us?

[2:56:06 PM] pD says: i guess it has just been approved by the US Senate (i heard it on the radio earlier today). Probably why FBI has not upped the bounty: http://english.aljazeera.net/NR/exeres/57FF48F9-D41B-41B4-8119-4615FE01F0DB.htm

[2:56:20 PM] pD says: btw, i am wonder if you have to pay tax for the bounty

[2:56:50 PM] pD says: if yes, that would significantly diminish the inventive, i would think...

[2:58:01 PM] nsy says: http://volokh.com/posts/1149797357.shtml

[2:58:40 PM] nsy says: "Bounties are subject to the income tax. It's really just compensation for services by unilateral contract. It's not different (from a tax perspective) from commissions paid to salesmen or the like. "

[3:02:44 PM] pD says: dang! i hope it is not too late to cancel my priceline flight reservation to pakistan

[3:03:14 PM] nsy says: good luck with that

[3:07:00 PM] pD says: priceline?

[3:07:21 PM] pD says: btw, more legalese on the tax treatment of the bounty. really good read too

[3:07:24 PM] pD says: Okay, here's a tax lawyer's quick take. If the recipient of a bounty like this is a U.S. citizen or permanent resident (a more common example would be a reward paid by the IRS for turning in somebody who didn't pay their taxes, which the IRS is indeed authorized to pay), then the bounty is definitely "gross income" subject to income tax. I think it is probably NOT subject to social security (FICA) tax or "self-employment tax" and NOT subject to withholding of income tax, because it is not "wages" nor is it income from the recipient's own business or professional activities. It's the kind of income that would be reported to the recipient and to the IRS on Form 1099-MISC Box 3, "Other Income." It should be reported by the recipient as income on Form 1040, line 21 ("Other income"). The IRS instructions say that is the line for reporting "prizes and awards," gambling winnings, and other miscellaneous non-business, non-wage income.

Since a bounty paid by the U.S. government is "U.S. source income," if the recipient is a foreign national, then the payment would be subject to U.S. withholding tax (not employment tax withholding, but withholding tax nonetheless) at the rate of 30% unless the rate is reduced by treaty. U.S. tax treaties with most of our trading partners would allow a reduced withholding rate. But we don't have a tax treaty with Iraq right now, so technically it's subject to 30% withholding. If the $25 million bounty is paid and the recipient is an Iraqi, I wonder if he or she will complain when the check is only $17.5 million.

[3:08:15 PM] nsy says: yep - thats good info! wow, 30% lost - where's my motivation, eh?

[3:08:40 PM] pD says: but, here is a ruling that may make it possible - if you have a non-US passport

[3:08:41 PM] pD says: Nonresident aliens not engaged in a business within the United States are subject to U.S. federal income tax on their U.S. source fixed or determinable annual or periodical income at a flat rate of 30% (unless reduced by treaty). IRC Sec. 871. This tax is generally withheld by the payer of the income. IRC Sec. 1441. (For a discussion of withholding tax under Sec. 1441 on amounts paid to informants, see Gen. Couns. Mem. 37,198 (July 18, 1977)).

For this purpose, whether a bounty is subject to tax by the United States will largely depend on how a bounty is characterized for tax purposes, because that will dictate how the source of the bounty is determined. There is one revenue ruling from 1970 (Rev. Rul. 70-576) that characterizes a reward paid by the United States to a Canadian informant as personal service income. The source of personal service income is generally the place where the services were performed. IRC Secs. 861(a)(3) &862(a)(3). If the informing in this situation was done in Iraq, then the bounty would be foreign source income paid to a nonresident alien, which renders it generally non-taxable by the United States. (In the revenue ruling, the informing appears to have been done in the United States, which would make the reward U.S. source income; however, the IRS found that the informant was nonetheless exempt from tax under the commercial traveler exception in the U.S.-Canada income tax treaty---the US currently has no treaty with Iraq, but we do have a statutory commercial traveler exception---IRC Sec. 861(a)(3), but that exception likely would not apply here given the size of these bounties).

[3:10:50 PM] nsy says: i guess buying a forged non-US passport is a good investment if you are a bounty hunter.

[3:14:44 PM] pD says: dang! need to change my flight schedule to go to a few Caribbean countries before heading to Paki

[3:23:11 PM] pD says: i know this sounds funny, but, the life of a tax lawyer is turning out more fascinating than i have first imagined

[3:23:24 PM] pD is once again reminded that he is a dork

[4:34:29 PM] pD has changed the chat topic to "because pD is a google ranking whore"

[4:34:34 PM] pD says: nsa chatters

[4:35:09 PM] pD says: i am afraid that this would be a recurring theme

[4:35:25 PM] pD says: throwing a few random "nsa chatters" into the mix to up our ranking

[4:35:49 PM] pD says: it dropped off last week since the phrase "nsa chatters" was not used regularly

[4:35:58 PM] pD says: on a related note

[4:36:27 PM] pD says: we should get people to link to us

===
NSA Chatters crew

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