Tours Travel

5 Outdoor Event Spaces to Host Your Summer Birthday

Summer is always a good time to host a birthday party. There are many options available in New York City for all budgets. They can range from free to as expensive as a person can afford. There are numerous outdoor venues and activities for birthday parties. Today, hosting birthday parties in outdoor venues is preferred as there is no clutter in the home and everything is well organized in these event spaces in New York City. Parties at these outdoor venues can be a lot of fun.

Some of the most popular event spaces for celebrating summer birthdays in New York City include: Bryant Park – balcony, Eden (@china club), 230 5th Ave., Ono (garden), and A60 (Thompson hotel)

Bryant Park is located between 5th and 6th Avenues and 40th and 42nd Streets, behind the New York Public Library in Manhattan. It offers one of the best locations to hold an event in New York. Several events have been held at Bryant Park in recent years.

Eden (@china club) has a spectacular rooftop lounge. Both the outdoor and indoor bar areas are nestled among giant trees. There are artificial plants that adorn the interior space and create an Olive Garden effect. It offers a great location for birthday parties and the service is excellent.

230 5th Ave opened in 2006 and has been a regular venue for events ever since. The decoration of palm trees, wooden benches and stuffed animals make it a great attraction for people. It has the biggest rooftop drink in New York City. The cuisine is great with superb service.

The Ono Garden is open from May to November and is used to host many events. It has a sophisticated open-air lounge and attracts 20-somethings. The food is delicious and it offers a great outdoor space to celebrate summer birthdays.

A60 (Thompson hotel) offers a beautiful space for hosting events. Staff and food is great. Located at the top of the Thomson hotel, it offers great views. Although the space is a bit small, it is nevertheless a great place to be.

Organizing a summer birthday is quite fun. A lot of planning is required to make it a success and choosing the right venue is of paramount importance.

Arts Entertainments

Learning languages ​​for desperately busy people

When you were younger, life was about school and the associated student responsibilities. There weren’t many limitations to deal with, like a job, children, home maintenance, and other adult obligations. As an adult, you still have goals and interests, and speaking a foreign language could be one of them. It takes about 1000 hours of study to be considered fluent in most languages, so with all the time required, how can you realistically speak a new language when your schedule is already full?

A productive way to learn a language and strengthen skills when time is limited is make use of idle times, idle time, travel time, and wait time. While you’re traveling or going to work, use those minutes to listen to podcasts or music in the language you’re studying. If you have an advanced level, listen to an audiobook in that language. Even if you passively listen to music in another language, you are learning new vocabulary, and music is a wonderful memory aid. While waiting for an appointment or standing in line, use a language learning app on your smartphone or tablet to pass the time. Brief periods of study are small boosters that greatly enhance your memory.

Read 15 minutes each day. If there is a book you like in English, try reading it in your foreign language. You don’t need to read it word for word; understanding the basic plot and becoming familiar with sentence structures and new vocabulary will make an impact. Also, you will have great satisfaction and confidence after achieving such an impressive goal. Of course, reading a novel is a suggestion. The important thing is to read something, anything that interests you: magazines, comics, romance novels, whatever motivates you to read every day. In fact, reading 15 minutes each day exposes you to more than 1,000,000 words each year.

If rereading a book doesn’t interest you, watch a favorite movie in the language you are studying. You will already know the plot so this time you will be able to follow the dialogue with a better understanding. Use subtitles if you wish. Games and puzzles They are also a productive use of time, and there are unlimited options available on the web. How about participating in a chat room in a foreign language? Not only do they provide a practical conversation experience, but they are also a wonderful source for potential foreign friends.

have you ever tried incorporating the five senses in your language learning? This can be done wherever you are. Every time you taste, smell, touch, hear or see something new or interesting, think about these sensations in your new language. By interacting with your senses, you will train yourself to think more in the new language, not your dominant language. This is why so many language students make rapid progress when traveling to foreign countries. They begin to hear and see more foreign words than words in their own language. Eventually their brains stop translating into their own language and start thinking in the new language. When you brush your teeth, for example, talk to yourself (quietly or out loud) about the mint flavor of your toothpaste, how fresh your mouth feels, the color of your toothbrush, how you feel the bristles on your gums, how soft your teeth feel, how foamy the toothpaste gets, the water, and the sound of brushing. Engage your senses in simple tasks while thinking in the language you are learning. Don’t worry about making mistakes. Think of words and sentences and let your mind be free.

To supplement language learning throughout your busy day, practice these achievable approaches that will keep you on the path to fluency. You can do it! Having an interest in foreign languages ​​is rewarding and opens your world to new possibilities, so don’t let time constraints limit your potential to speak a new language.


6 incredible benefits of cryptocurrency

In recent years, people have been talking a lot about cryptocurrencies. At first, this business sounded scary, but people began to trust him. You may have heard of Ether and Bitcoin. Both are crypto currencies and use Blockchain technology for the highest possible security. Today, these coins are available in various types. Let’s know more about it.

How can cryptocurrencies help you?

As far as fraud is concerned, this type of currency cannot be counterfeited as it is in digital form and cannot be reversed or counterfeited unlike credit cards.

immediate liquidation

The purchase of real estate involves third parties, such as lawyers and notaries. Therefore, delays may occur and additional costs may be incurred. On the other hand, Bitcoin contracts are designed and enforced to include or exclude third parties. Transactions are fast and settlements can be done instantly.

lower rates

There is usually no transaction fee if you want to exchange Bitcoin or any other currency. For verifying a transaction, there are minors who are paid by the network. Although the transaction fee is zero, most buyers or sellers contract the services of a third party, such as Coinbase, for the creation and maintenance of their wallets. If you don’t know, these services work like Paypal which offers a web-based exchange system.

theft identification

Your merchant gets your full line of credit when you provide your credit card. This is true even if the transaction amount is very small. In reality, what happens is that credit cards work based on a “pull” system where the online store extracts the required amount from the account associated with the card. On the other hand, the digital currencies feature has a “push” mechanism where the account holder sends only the required amount without any additional information. Therefore, there is no possibility of theft.

open access

According to statistics, there are about 2.2 billion people using the Internet, but not all of them have access to conventional exchange. Therefore, they can use the new form of payment method.


As far as decentralization is concerned, an international computer network called Blockchain technology manages the Bitcoin database. In other words, Bitcoin is under the administration of the network and there is no central authority. In other words, the network works on a peer-to-peer approach.


Since cryptocurrency is not based on exchange rates, transaction fees, or interest rates, you can use it internationally without any issues. Therefore, you can save a lot of time and money. In other words, Bitcoin and other currencies like it are recognized all over the world. You can count on them.

So if you have been looking for a way to invest your extra money, you may want to consider investing in Bitcoin. You can become a miner or an investor. However, make sure you know what you are doing. Security is not an issue, but other things are important to consider. Hopefully, you will find this article useful.


How do successful leaders spell survival?

Did you know that the same skills that are used in survival situations are the
same skills needed for effective leadership? The US Army uses
the word SURVIVAL as a mnemonic device to help your troops and leaders
remember the right actions under fire. Visionary leadership:

*S: Assess the situation*. Survivors know that they need to survey their surroundings before acting. Today’s Successful Leaders
you need to do the same. Unfortunately I have seen too many newly promoted
managers, so eager to prove themselves, immediately begin making
changes before careful business/organizational analysis. The result:
A customer and employee disruption and often a negative one.
consequences for the organization. Always carry out Intel, before
offer an opinion or direction.

*U: *Undue Haste Makes Waste:* A partner of S in Survival with
an additional rule relating to crisis situations. Did you know that
Does the IQ of an angry or emotional person drop by 50%? How many leaders can
afford to lose so much mental power in decision making? Rule of
thumb: Never make a business decision while in an emotionally charged situation.
status and that includes targeting employees when under
pressure or under fire.

*A: Remember where you are: *Always check that your decisions and
actions are in accordance with your organization’s mission statements,
key business values ​​and goals. Ask yourself on a regular basis.
“Is this the best use of my time to achieve the overall goal
organization’s mission and strategic goals?” If the answer is no,
rethink the task. It takes discipline for a leader to stay on point
and not get lost in the jungle. Remember, the best way to be found in
the desert is to focus on not getting lost in the first place.
Clear vision and goals are key.

*V: Overcome fear and panic: *An animal that runs is a vulnerable animal.
Do you know leaders and managers who run around the office doing
everyone crazy? Do they see themselves as a leader who is cool and calm in a
crisis? I do not think so. Here is a simple communication rule to improve
your leadership credibility score. People who speak slower and wait 2
3 seconds to respond are considered much more believable. * *Use the
“The power of the pause in your favor”. If you find yourself cutting
people in the middle of a sentence or running frantically in response
to pressure, both are warning signs to slow down and take a break!

*I: Improvise: *Is it solution-oriented or problem-focused? from today
Successful leaders recognize that they will not always have the perfect world.
and they quickly became known as the McGuivers in their organization.
The question is: are you a leader of destiny or origin? a go to
leader, presents a solution for each problem presented.
leader complains about his lack of resources. You are the judge of what
category in which your organization would put you.

*V: Value Living: *I have met the brightest people who are
unfortunately bad managers because they know little about those
around you that make things happen. If you value the life of your
employees, they will value their association with you.

*A*: *Act like the natives: *Recognizes that empathy and finding common ground
ground with customers, employees, colleagues, and senior management are
the key to your survival. Entering as a tourist, telling the
natives what you do in their country will not earn you points in any camp.

*L: Learn something new*—–Every day! Today’s Successful Leader
it needs to be an information and learning machine. keep up better
practices, new consumer trends, competitors, and yes, even pop culture.
Its adaptability to the ever-changing conditions of life is the key to
your survival Have you ever met someone who talks about the good old days?
Most likely, they are not survivors of leadership!

Rosemary Rein, is the author of GO Wild! Go BIG! Training seminars
Leadership and Customer Service., delivering keynote presentations and
1-day seminars in the United States, Canada and Latin America.

Send an email to Romero@

[email protected]

Home Kitchen

A detailed guide to shutters

To get an in-depth look at the windows in your home, take a 360-degree view of your home from the inside out and see what your windows look like. Does it look too simple? Take a deep look at the window frame, the glass, and the way they sit there. Now your real work begins! Analyze everything in and around your house. Imagine the windows with a little treatment added to the interior as well as the exterior window coverings.

Why are blinds designed?

Shutters are designed with two main functions in mind. First, they should help protect against the elements, especially the wind, along with privacy. Second, they add a decorative look to your home.

Why this guide?

You may be wondering why we are providing you with this detailed guide. And the reason behind this is to help people in their research on home decoration and style. We’ve even done research on a particular topic (here-shutters) and presented it in front of our audience in a way that really makes sense.

Here in this guide we have a number of different sections that explain the different elements of a blind. All these aspects will surely help you to buy the most suitable blinds for your home. Let’s take a look:

  1. Shutter Location: Inside vs. Exterior
    1. Interior blinds: These blinds are easily adjustable from the inside from a privacy standpoint. In addition, interior window coverings offer many options for the homeowner, such as partial, full-height, and level-over-level window coverings. Otherwise, you can also get custom shutters built to your specifications.
    2. Exterior shutters: For the most part, the windows on the exterior of your home serve an aesthetic purpose or curb appeal. On the other hand, they can be functional as they provide privacy.
  2. Panel styles:
    1. Blinds: These blinds have a series of wooden slats that overlap each other in the same frame and are used for both interior and exterior blinds. They can be adjusted to let in more or less light. These shutters add a country look to your home.
    2. raised panel: These blinds are made with box-shaped designs where a series of rectangular elements will stand out from the rest of the frame. This shutter design is usually identical to your kitchen cabinets.
    3. vibrating screen: It resembles the raised panel shutter but has a flat body. The rectangular shape gives it a nicer, more detailed look without standing out.
    4. Plantation: These blinds offer wide blinds or angled slats set around a series of invitations and also allow light to move through them.
    5. Others: There are many other panel styles to consider as well, including half-batten, Scandinavian, board and batten.
  3. Window coverage:
    1. Coffee style: Windows with this type of siding combine a planting at the bottom of the window. This is given a nicer look that also adds a stunning look with a strong sense of detail in mind.
    2. Full Height: This type of coverage can be combined with any type of blind, from slat and solid blinds.
    3. Level on level: This type of window covering gives you the option of which part of your window you would like to open and which part you would like to close.
  4. Shutter forms: There are a number of blind shapes to choose from among the popular options. Some of these shapes are: arch, rectangle, French door cutouts, trapezoid, circles, and special shapes like: perfect arch, full arch, brow arch, top angle, octagon, etc.
  5. Accordion shutters: Most shutters are single-panel, meaning they don’t have any folds. However, for wider windows, folding blinds are a better option than non-folding ones. There are three types of blinds when it comes to panel folds:
    1. No fold i.e. single panel
    2. Bi-fold, that is, two panels
    3. Triptych
  6. Shutter Materials: While you are looking for blinds, there are many great materials available for you to take a look at. And as a homeowner, you need to choose the option that best suits your needs. Available materials include wood, engineered wood, laminate, PVC, metal, and synthetic foam. Choose the material for your home’s shutters wisely.

ATV Cectek Quadrift 500cc EFI – Quadricycle

Fun on 4 wheels?

When I first saw this Quad Bike in early 2009, I thought “Oh my gosh, this is another one of those Sinclair episodes!”

How wrong was I?

Cectek has gone completely crazy developing something that the market was working on, but with some love and attention on features that other manufacturers try and charge you more for. While they were very careful with what they did, there was no compromise on quality and production.

Designed with a little extra fun in mind, the Cectek Quadrift 500 EFi has come very close to the mark and borders on something else. Not only have they filled a void in the quad market, but they’ve also created another, which once you’ve taken the time to ride one, you’ll fully understand what I mean.

With an extremely low center of gravity, they have thrown down the cards and said, “Do you want to have some fun?”

Personally, I think this is something we ALL could do in our lifetimes to remove the gloom of modern political torture and news that is fit for people who have nothing better to do.

What these guys have done is take something that was or has been very bland for a while and add two extra lumps of sugar to sweeten it up. The extra low center of gravity makes this bike handle like it’s on rails, and with the perforated gasket 500cc EFi power plant, you’ll turn on the blue touch paper and watch this rocket explode.

The return of a childhood of more than 30, perhaps? And it doesn’t stop there!

Talk about being considerate, (or this marketing gone crazy) they’ve also included a goosebump-raising experience called “Transmission Drifting.” Now you MUST have the drift? (I am sorry…)

Switch from the limited slip differential to drift mode and you’ve got that rear end fully locked up and running like Roger Clark’s Ford Escort Mk1 in the ’70s. This feature alone will have you pushing those eyes back into their sockets, leaving you with bags. of time to enjoy the experience and incredible control.

And if that’s not enough, they refuse to charge you for things like alloys and digital dashboard (unlike some manufacturers I might mention). This is just a snippet of what you can expect:

  • Frame – Something they call “UCS”, which stands for Ultra Secure Chassis
  • Suspension – Fully independent suspension with adjustable shock absorbers
  • Wheel – Stock alloys with low profile tires
  • Brakes – Dual 250mm front and rear brake discs
  • Instruments – LCD racing effect dials offering a multifunction display

And when I say multifunction, there’s more to play than your average game console!

Is this fad completely gone, or is it clever design and marketing?

Personally I think it’s a good mix of both with a touch of extra strength in the design department. There is one thing I guarantee (apart from the obvious fun that it is), give the industry 6-12 months and I will stand by these words: everyone will do something more or less the same but more expensive.

As for Cetek (gold see tek as they like to be known) already have the next stage of this machine in the design shop. As for you, you will find it difficult to get one in the spring of next year due to the high demand, so don’t wait for the sale, because there won’t be one!

Digital Marketing

What is a Tour Broker and how to become one

A person who operates a tourism business is a broker. A broker is an intermediary. Brokers buy or arrange items or services and sell them to the ultimate buyer. Some examples of intermediaries are:

Independent insurance agents. These agents do not offer insurance; arrange insurance for you from an insurance company. Insurance agents typically receive a commission from an insurance company.

Stockbrokers. Like insurance agents, stockbrokers help you buy and sell stocks. They do not own the shares. These brokers also receive a commission based on the amount sold.

real estate agent. Again, these brokers do not own the properties they sell and they get a commission based on the value of what they sell.

There are also travel agencies. Tour brokers serve a variety of customers. This article is about what a travel agency is and the basics of this business.

Here is a good description of what a tour is: A trip with visits to various places of interest for business, pleasure or instruction.

Travel is defined here: Going from one place to another, as on a journey; trip.

A trip, then, is not just a trip, but a trip with the purpose of being of pleasure or interest. You can think of a tour as an extended trip whose goal is to see and experience an area. Traveling, on the other hand, is usually just about moving from one place to another.

A tour agent works with people on an ongoing basis. If he is going to get involved in this kind of business, he would like to work with people: he must be a people person.

Travel brokers are not travel agents. Travel agents organize the travel needs of their clients. Typically, a travel agent will only work with individuals or small groups (families, for example). Travel agents also always buy something that is already in the works (air travel, car rentals, hotels, etc.), they do not originate anything.

Tour agents originate: they organize tours, arrange transportation, arrange accommodation, arrange meals, and arrange other services for their clients. A travel broker plans what type of trip he wants to operate.

Next, the tour agent organizes the various components of the tour: transportation, food, accommodation, attractions, etc.

There are many types of tour companies. Some offer guided tours of a local area, tours of a city or an attraction, for example. Some offer tours in a natural environment; guided tours of the Grand Canyon fall into this category. Some offer tours to various national and state parks. Some offer tours of a large area, a multi-state tour is a good example.


You may be required to conduct inspections of the hotels and attractions that will be part of your tour. If you’ve been taught correctly, you’ll know how to get “comp” (short for free) rooms and meals. If you continue with the tour, you should expect to get freebies again. How to set it up so you get freebies is something your mentor should teach you.


As I mentioned before, this is a people business. Having a taste for working with people and a taste for solving problems is a primary requirement.

Just as a church is a church because someone calls it a church, a tour agent is a tour agent because someone says they are a tour agent. There is no requirement for a license. If you operate a business, you may be required to obtain a federal tax identification number and your county or city may require you to obtain a business license. As for the need for a license to become a tour agent, a license is not required. From the mid-1930s to the 1980s, transportation was strictly controlled by the Interstate Commerce Commission (ICC). Under the Deregulation Act of 1982, competition was allowed and the need for federal authority became a thing of the past.

Depending on where you are, you may need some type of business license. Call your local county office and ask for the office that handles business licenses. This should be easy, as all they really want is for you to submit a few documents and pay them a small fee.

If you’re going to make money (and why else go into business?), you’ll need to get a federal tax identification number. This number is called a Tax Identification Number (TIN) and is used in business much like your Social Security number is used for benefits.

I have looked at various sites on the internet that claim to be concerned with how to become a tour operator. Most don’t seem to understand what a tour operator is or does. Those who have come close to the concept offer to teach or provide links to sites that can prepare someone to be a tour guide. A tour guide is not a tour operator; At best, a tour guide works for a tour operator.

A tour operator runs his own business.

It’s as simple as that: you own and run the business. If you plan to make a profit, follow this rule: buy low, sell high. People tend to make things too difficult. You buy at one price and sell at another price, easy, huh?

The real “trick” to making money in the touring business is to understand the concept of equilibrium (BE). The break-even point is where you don’t lose money and where you don’t make money. To help you understand this idea, you need to understand that there are two types of costs in most businesses: fixed and variable. A fixed cost is one that will occur whether you have 10 clients or 46. Office rent is a fixed cost. You have to pay rent whether or not you operate any tours. A variable cost is a cost that depends on something else. An example of a variable cost would be the cost of an attraction (theme park). If you have 20 customers, the total cost of the attraction depends (varies) on the number of customers you have.

The lack of good information about this business led me to believe that those in this business either don’t want competition or don’t have the time to write about how they run their business. A well thought out tour, advertised correctly, can generate thousands of revenues. For example, suppose you operate a seven-day bus tour. The tour sells for $985.00 (per person, double occupancy) and has 36 people on your tour. The gross receipts from this tour will be over $35,000.00 and you should be able to keep at least $10,000.00 of that amount.


It is possible to make a lot of money in this business; you could also lose money. Here are some basic requirements that you must have before starting such a business.

You must like working with people.
You should not panic when things go from good to bad or even worse.
You should be able to organize things easily.
You must have at least a working knowledge of certain computer programs: word processing, spreadsheet, email
You must have a photocopier and a fax machine.
You must have at least one phone
You must have at least one fairly up-to-date computer

What kind of tours and what should I do next?

The world is your oyster

This is really the fun part: you can go anywhere! Successful racers operate three-day tours from Denver to the nearby Rocky Mountains and seven-day tours to Branson, Missouri. East Coast Racers offer tours of New England and parts of eastern Canada, as well as longer tours of the southwestern United States.

Brokers in Seattle do a brisk business operating tours in Mexico’s Copper Canyon. Some brokers offer visits to music events, art shows, and short trips to New York City for holiday shopping.

Where to go is up to you, as long as you keep it reasonable. Going to Iraq now may not be the best option, but there is a company in the UK that offers and operates tours to Iraq. Make sure your clients sign plenty of statements stating that you are not at fault in the event of their death. Given the current state of the economy, it may be wise to limit your offerings to North America, but trips to Costa Rica seem to sell very well.

To learn more about this exciting business, click here.

Health Fitness

How physical training increases resilience when meeting goals

Exercise not only rejuvenates a healthy mind and body, but also helps fulfill the goals of the individual in various fields of work. Fitness freaks who indulge in different activities always prefer to get proper training from an instructor who can make them perfect in different categories like sports, jobs (Army, Navy) and different martial arts like Judo, Kung fu and Karate. They seek the help of a coach because they find it difficult to set such goals for themselves.

physical training improves your performance in various categories of work. Intense training and a resilient athletic body are essential for fields such as the military, police, navy, airlines, and sports. The orientation or physical training can help to meet the objective on those platforms.

Psychological benefits of training

Research has shown that exercise not only strengthens your body but also manages stress and anxiety. Physically active people have a lower rate of depression and other psychological problems. Some of the psychometric benefits of training are highlighted below:

  • Exercises can improve your mood.
  • It reduces the symptoms or risk of depression and protects you from diseases such as hypertension and other mental disorders.
  • It sharpens the decision-making capacity of an individual.
  • Rejuvenates the power of resistance and increases inner comfort.

Physical benefit of exercise

There are multiple benefits of physical activity if done correctly. The advantages of the trainings are the following:

  • Exercise controls weight and gives your body a proper shape by balancing your Body Mass Index.
  • Health problems such as diabetes, metabolic syndrome, high blood pressure, cholesterol, heart disease, etc. They can be controlled with physical activities.
  • Physical activity helps strengthen muscles, bones, and joints.
  • Increases the possibility of living longer.
  • Exercise also helps to overcome insomnia and provides good sleep.

Fitness Training Goals

Everyone has the idea of ​​the benefits of a workout, but few people are familiar with the side effect of wrong exercise, which can be the main reason for multiple health problems or injuries. Without proper guidance from a professional fitness instructor, it can be difficult to achieve your fitness goals. The following are the guidelines suggested by fitness gurus:

  • They established regular trainings.
  • Instructors always try to guide their clients through important steps and techniques to prevent injuries during training.
  • Fitness trainers empower their clients on job-specific platforms by scheduling the appropriate workouts for their jobs or other activities.
  • For beginners, some steps are designed by the trainers so that the student does not feel difficulty in an exercise routine.
  • Fitness instructors don’t overtrain, which can harm a beginner.
  • They suggest that you follow a balanced diet chart according to your body’s BMI.
  • They make you start exercising with warm-up and stretching.

Satisfying various types of physical activities may not bring fruitful results if you do not take professional guidance. Therefore, the lessons provided by physical training can be beneficial and help to reach the goal in a specific time and increase the resilience in the individual.

Legal Law

Are you blaming your tax preparer for your screwed up tax return?

How a taxpayer argued and lost in Tax Court. Takeaway: You really do have to take some responsibility for your taxes. Have you ever wondered if you could blame your tax preparer to avoid a 20% penalty from the IRS? Do you create a new version of “The dog ate my homework” or “The devil made me do it”? If your tax return is audited and you “lose,” the IRS is quick to assess your negligence penalty in addition to back taxes, plus interest. The additional tax you owe is called the “deficiency” and the penalty is the “accuracy-related penalty” and is imposed at a flat 20% of the deficiency: if you owe $5,000 because you missed the audit, the penalty is $1,000.

“Expect!” you can cry “I gave all my stuff to the preparer. The fact that he made mistakes shouldn’t be a reason to penalize me. I already have enough trouble finding the deficiency. I’m a victim here. It’s not fair. I’m going to Tax Court.” Which is precisely what a California woman did when she was faced with a fine of $1,059.20. Because she didn’t want to pay a lot of money for a tax attorney, she represented herself. [Pro Se] before the Tax Court [T.C. Memo 2009-278]. And she lost.

What happened? She had her long-time tax preparer prepare her 2005 Form 1040. She gave the preparer financial documents, including a 2005 Form SSA-1099, Social Security Benefits Statement, indicating that she and her late husband had received $21,445 in Social Security benefits in 2005. However, you did not provide the Preparer with a 2005 Form 1099-DIV, Dividends and Distributions, indicating that you had received $216 of dividend income, or a Form 1099-INT, Income from Interest, indicating that he had also received $24 of interest income. .

Now, the Preparer, in the language of the Tax Court, “did not consider or include” these three taxable items when preparing the 2005 Form 1040: Social Security Income $21,445, Dividends $216, and Interest $24. He forgot to put in the $21,445 and, of course, he couldn’t put in the dividends and interest income, because he didn’t know them. However, the Preparer provided the Taxpayer with a summary of the items to be included on the tax return, but no copy of the return was provided to the Taxpayer until the return was filed electronically and the filing was recognized by the IRS. . (This is not considered acceptable practice for any tax preparer.)

The Taxpayer was fully aware of the receipt of taxable Social Security Benefits in fiscal years 2002, 2003 and 2004. However, he did not detect errors in the summary of income items considered by the Preparer both when preparing the return, nor in the form itself when it was delivered after receiving the electronic filing.

The IRS, using its document matching programs, noted the unreported income and generated a letter calculating the deficiency of $5,296 and assessing the related accuracy penalty of $1,059.20. A direct calculation of 20% multiplied by $5,296. [IRC Sec. 6662(a)].

The legal framework is as follows:

The penalty
Internal Revenue Code subsection (a) of section 6662 imposes an accuracy-related penalty of 20 percent of any underpayment that is attributable to the causes specified in subsection (b).

Among the reasons that justify the imposition of the sentence is

or any material understatement of income tax as defined in section 6662(d)
or a material understatement occurs when the amount of the understatement exceeds the greater of

– [1] 10 percent of the tax that is required to be shown in the return for the taxable year, or
– [2] $5,000.
– In this case, the deficiency is $5,296, which is greater than $5,000 and meets the second condition.

Penalty Exceptions
The section 6662(a) penalty is waived if a taxpayer can demonstrate

or (1) reasonable cause for underpayment and
or (2) that the taxpayer acted in good faith with respect to the underpayment. Dry. 6664(c)(1).

subjective considerations
The regulations promulgated under section 6664(c) further provide that

o The determination of reasonable cause and good faith “is made on a case-by-case basis, taking into account all relevant facts and circumstances.” Dry. 1.6664-4(b)(1), Income Tax Regulations.
o Relying on the advice of a tax professional may, but need not, establish reasonable cause and good faith for the purpose of avoiding a section 6662(a) penalty.

Based on this, the Taxpayer, of course, tried to fit his case into the Exceptions mentioned above by alleging special facts and circumstances, as well as relying on the advice of his tax professional. A taxpayer can’t really accomplish more than that.

The Tax Court has established the following three requirements for a taxpayer to use reliance on a tax professional to avoid liability for a section 6662(a) penalty:

or (1) the adviser was a competent professional who had sufficient experience to justify the reliance,
or (2) the taxpayer provided necessary and accurate information to the assessor, and
or (3) the taxpayer actually relied in good faith on the assessor’s judgment.” See Neonatology Associates, PA v. Commissioner, 115 TC 43, 99 (2000), affd. 299 F.3d 221 (3d Cir. 2002). .

These requirements are also known as “points”, a three-pronged test. Unconditional trust in a preparer or adviser does not always, by itself, constitute reasonable trust. The Tax Court has established additional guidelines based on facts and circumstances. [Such guidelines are called dicta]

o The taxpayer must also exercise “diligence and prudence”. Marina v. Commissioner, 92 TC 958, 992-993 (1989), affd. no published opinion 921 F.2d 280 (9th Cir. 1991).
o “The general rule is that the duty to file accurate statements cannot be evaded by attributing responsibility to an agent.” Pritchett v. Commissioner, 63 TC 149, 174 (1974).
o Taxpayers have a duty to read their returns to ensure all items of income are included.

– Relying on a preparer with complete information about a taxpayer’s business activities does not constitute reasonable cause if a superficial review of the return by the taxpayer would have revealed errors. Metra Chem Corporation v. Commissioner, 88 TC 654, 662-663 (1987).

or “Even if all data is provided to the preparer, the taxpayer still has a duty to read the return and ensure that all income items are included.” Magill v. Commissioner, 70 TC 465, 479-480 (1978), affd. 651 F.2d 1233 (6th Cir. 1981).

The Tribunal began with a consideration of Point Three, the good faith reliance on the Preparers’ judgment. In a display of common sense rarely seen in any federal court, the Tax Court issued its opinion that

o “We conclude that the petitioners did not rely in good faith on [the Preparer] to accurately prepare your return. We conclude that the petitioners did not rely in good faith on [Preparer’s] advice because they didn’t review your return before sending it to the IRS. [Emphasis added]

– There you go! If you don’t read the statement, you’re not really trusting someone, are you?
– “Thus, the unconditional confidence of the petitioners in [The Preparer] does not constitute reasonable reliance on these facts and does not excuse your failure to closely examine your statement.”

What about the second tip? That the Taxpayer must provide necessary and accurate information to the Preparer.

o The Tax Court noted that the “defense of confidence is also undermined by the fact that [Taxpayer] did not provide [Tax Preparer] with the necessary 1099 documentation regarding your dividend and interest income in 2005.

– Sure, the amounts are insignificant, $216 in dividend income and $24 in interest income. But the fact of not delivering them shows negligence and makes the taxpayer not comply with the Second Tooth.

After considering the Second and Third Points, the Tax Court did not even concern itself with the First Point, if the tax advisor was a competent professional. It concluded that the Taxpayer “had not demonstrated good faith and reasonable cause for its underpayments corresponding to 2005. Consequently, the Court holds [the IRS] determination that petitioners are liable for the section 6662(a) accuracy penalty for material income tax understatements for tax year 2005.”

That is all. The 20% penalty is maintained. Obviously, the Taxpayer was protesting the principle of the penalty, since $1,059.20 is not a lot of money and not worth the trouble of filing a Petition to hear the case in Tax Court. We have discussed this particular case because it illustrates quite clearly the principles involved in protesting the penalty, as well as the burden of proof required by the taxpayer.


Sexual Harassment Prevention in California

“Sleep with me if you want to keep your job.”

Sound good to you? What if your superiors have offered you as such?

In these modern times, it is hard to believe that sexual harassment in the workplace still exists. Unfortunately, it is still happening. Whether you are in a small or large organization, there is always a tendency to get mugged at work without even realizing it. Some would even use their power in the office to get what they want in exchange for job security. But what is sexual harassment? How do you know if it is sexual harassment?

According to Wikipedia, sexual harassment is intimidation or coercion of a sexual nature or the unwanted or inappropriate promise of rewards in exchange for sexual favors. In the state of California, sexual harassment prevention in California stalking cases tends to increase each year. According to statistics from the California Coalition Against Sexual Assault (CCASA), California rape crisis centers served 31,790 survivors of sexual violence in the state during the 2011-2012 fiscal year. In fiscal year 2011-2012, 134,322 people received community sexual assault education in fiscal year 2011-2012. There are an estimated 8.6 million survivors of sexual violence other than rape in California. There are an estimated 2 million female victims of rape in California, 5.6 million women in the state have been victims of sexual violence other than rape. There are an estimated 3 million male survivors of sexual violence other than rape in California. Studies suggest that 40-70% of women and 10-20% of men have experienced sexual harassment in the workplace.

With the rise in sexual assault cases in California, especially by supervisors, California sexual harassment training, as required by law, is vital for superiors. Also known as California State Law AB 1825, which is part of the Fair Employment and Housing Act, first went into effect on August 17, 2007. The legislation requires statewide sexual harassment training for any employee who perform supervisory functions within a company of 50 or more employees. Under AB 1825, supervisors must be trained within six months of being hired and must be retrained every two years. The new training, effective January 1, 2018, stipulates that the training must include specific examples of such harassment on the basis of gender identity or expression or sexual orientation and that at least some of the training must be delivered by trainers with knowledge and experience in these areas. To make it easier for everyone, web-based training has been established in the form of webinar and e-learning. These training solutions are consistent, compliant, and don’t take up valuable employee time. California bullying online training courses are also easily tailored to meet the unique needs of your organization under AB1825. Failure to comply will result in laws amounting to thousands of violations and fines.

For the victims who failed to stand up for their rights, there is still HOPE! The sexual harassment law offers strong protection in California. There are numerous consulting companies that offer free workplace bullying consultations.

Just speak up and don’t be afraid sexual harassment is never pretty!