Big Brother Movie With English Subtitles Download
Genciana Haggins
At issue in Sorensen v. Commissioner is whether the value of nonvoting Firehouse Restaurant Group Inc. shares that were given and sold by the brothers to their trusts as part of an estate plan is governed by a defined-value formula and the value of the company at the time of the transfers . Tax Court Judge David Gustafson ordered the case continued July 7.
Both valuation experts used the income and market approach, but differed over the discount to be applied to the value of comparable public companies. Rey applied a 60 percent discount while Anderson applied none. Rey also applied a capital equity discount rate of 26 percent, and Anderson applied a 13.14 percent rate.
Courts tend to lean toward the better appraisal, Hoffman said. Having said that, there are still instances where the better appraisal does not exist, and the court is stuck coming up with its own opinion. In that case, sometimes a result that splits the values can still occur," he told Tax Notes.
The IRS objected to the defined-value formula used by the Sorensens in determining how many shares they were transferring to the trusts, which was similar to the formula in Wandry v. Commissioner, T.C. Memo 2012-88, appeal dismissed (10th Cir. 2012).
ANNOUNCER: In Moscow, a city transformed by the young and wealthy, the Kremlin has just arrested one of them, the richest man in Russia. An exclusive interview with New York Times reporter Sabrina Tavernise.
BRIAN KNAPPENBERGER: For years as a reporter, Sarah had come and gone from war zones, increasingly with misgivings about the devastation shed left behind. But this time, in Afghanistan, a chance conversation would change her life. It was at a dinner with the uncle of President Karzai.
SARAH CHAYES: We had, you know, a wonderful meal and a wonderful conversation, as always. We were looking ahead. Now the Taliban have fallen, Hamid Karzai has been named interim premier, and its, like, What are the prospects for the future? As I got up to go, he kind of cocked his head and said, "Wouldnt you come back and help us?" Just like that. And it was, like, the signal, you know? It was really incredible.
SARAH CHAYES: Ive made a couple of major changes in the direction of my life. And sometimes Ive made changes away from something that didnt feel right. This time, it was making a change towards something that did feel right.
BRIAN KNAPPENBERGER: After 14 hours on the road, we are nearing the former Taliban stronghold of Kandahar. Theres a wedding in the Karzai family tonight, and weve been invited to join Qayum, his uncle and the new president. But what we didnt know is that afternoon, as Hamid Karzai made his way through the streets, and just as a young boy leaned in to greet him, an assassin opened fire.
In an attempt to save the president, the boy had jumped on the gunman, but in the confusion, the American special forces assigned to guard Karzai opened fire. Three were killed in the melee-- the assassin, another guard and the boy who saved the presidents life. That night, under stepped-up security from U.S. special forces, the president decided to go ahead with the wedding as planned.
QAYUM KARZAI, President Karzais Brother: It was a very strange, strange night. You know, on one had, you were struggling to be happy. On another hand, there was this reminder that an assassin-- major, major assassination, point-blank assassination plot just failed. Hes the symbol of peace. If hes not here, peace is not here.
BRIAN KNAPPENBERGER: Kandahar remains a dangerous place. Here loyalty is to warlords, not to the central government in far-off Kabul, and there is still deep support for the Taliban. In the late days of the war, the Taliban fled along this road out of Kandahar. They made their last stand in small villages to the north. Were headed to one of them now.
SARAH CHAYES: It really got hammered, you can see. Its right near the airport, which was basically the last stand of al Qaeda. It was, like, the last hold-out, where the last major battle was fought. And these villagers all had run away, obviously, by that time. Its quite likely that
BRIAN KNAPPENBERGER: More than half of this village was destroyed in the bombing, 13 homes in all. Sarah is here to rebuild them, using private aid money she helped raise back in Concord, Massachusetts, for Qayums foundation. Its a story in the small about the big challenges this country faces after decades of war.
SARAH CHAYES: The bombing of Akokolacha was justified. Were not trying to say this was a mistake, and therefore the United States should pay for it. Whether it was wrong or whether it was right, these people deserve to have their houses to live in.
BRIAN KNAPPENBERGER: Before any construction can begin, there are some decisions to be made. Sarah and Qayum hold a shura, a meeting of village elders who are considered to be the tribal leaders. This is democracy Afghan-style. Voices can get loud, but here they will decide how the homes will be built.
BRIAN KNAPPENBERGER: It is decided at the shura that the villagers will provide the workers. And Haji Baba, the oldest of the village, will have his house built first. Everyone accepts the outcome.
BRIAN KNAPPENBERGER: As a woman, Sarahs presence at the shura is far from normal. Women are not allowed, but she is playing a primary role. As she goes about her daily life here, Sarah always attracts attention.
SARAH CHAYES: I kind of pile it on, right? Im non-Afghan, Im female, Im wearing mens clothes, including a turban, and Im driving a car. That does attract a lot of attention. All the time, people wonder if Im a man or a woman. Ill hear kids say, "Thats a woman!" You know? And then Ill turn around and say, "Yeah, yeah, its a woman".
BRIAN KNAPPENBERGER: The next morning marks the first day of construction, but already theres a problem. There are no workers. In spite of what was agreed at the shura, only a handful of villagers showed up.
BRIAN KNAPPENBERGER: Haji Baba is in a joking mood, but when we leave, he turns more serious. That night, Sarah learns that Haji Baba wants a change in plans. The next morning, she returns to Akokolacha to find him.
BRIAN KNAPPENBERGER: The local governor is blocking the villagers shipment of foundation stone. Sarah didnt know why, but she did know who, Governor Gul Agha Shirzai. Hes a former warlord, pictured here on the left with President Karzai. Shirzai and his troops seized Kandahar after the war, and Karzai reluctantly named him governor. Now, at gunpoint, some of Shirzais soldiers were seizing the quarry just outside of Akokolacha.
BRIAN KNAPPENBERGER: The owner of the stone quarry is Haji Abdullah. Though Sarah and the engineer need their stones, Haji Abdullah has problems of his own. He has been forced out of his own factory.
The notorious road from Kabul to Kandahar is about to be repaved with funding from the United States government. A recipient of the lucrative cement contract? Governor Gul Agha Shirzai and his brother-in-law, Razak.
QAYUM KARZAI: A government that is-- a government that is setting up small businesses and monopolizing, and evicting other people, evicting other people not to conduct business. I see it as an impediment to the whole legitimacy of the government reconstruction process.
SARAH CHAYES: Absolutely. Absolutely. Right now, I mean, in a very concrete way its impeding the reconstruction process because we have a village to build, and we cant build it because we dont have stone. What could we do?
BRIAN KNAPPENBERGER: During the bombing campaign, Haji Abdullahs machinery was seriously damaged. He had just made the repairs when the governor shut him down. Now, if he cant sell the stones legally, his family and his employees will go hungry.
BRIAN KNAPPENBERGER: When the sun comes up the next morning, it begins to look like their plan may have worked. They managed to smuggle at least a tractorful of the precious cargo out of the quarry-- not enough for the entire village, but stone enough to at least start Haji Babas foundation.
BRIAN KNAPPENBERGER: Haji Babas house is under way, but the next attempt to get stone ends badly. The workers gather the next load, but as their truck tries to leave the quarry, Shirzais soldiers once again intervene.
BRIAN KNAPPENBERGER: In post-war Afghanistan, even the stones are worth fighting for. Sarah and the Engineer are left with only one choice, to confront Governor Shirzai directly. Because of her status as an American and her alliance with the Karzais, we dont have to wait long to get an audience. Other people with grievances wait outside the gate for days or even weeks.
GUL AGHA SHIRZAI: [subtitles] We have prohibited taking stone from two places. One is in the old part of town where there are ancient writings we must preserve. The other is in Shurendom, the place you have named, because we are creating a cement factory.
That mountain has to be saved for using on cement from his goddamn factory, and nobody is allowed to have stone for foundations. Hes cornering a market completely, and hes the governor and hes the part owner of this factory, of this new cement factory. So hes using his governmental power to protect that monopoly.
WORKER: [subtitles] I have no stone. I have no water. I cannot work. Look at the foundation. Look at what we have done so far. Its half done. We dont have enough stone to finish. If we have the stone, we can finish tomorrow.
BRIAN KNAPPENBERGER: Eventually, Sarah is not only denied access, but we are physically threatened by one of the governors higher-ranking guards. It takes hours for Engineer Abdullah to finally negotiate their way to the deputy minister.
SARAH CHAYES: Remember, yesterday, you said this morning that you would bring people from Mines and Industry to find us stone from a quarry near-- in the south, near the base? Remember, thats what we agreed on. So?
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