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Inventing Motion Pictures
When you think of movies, you think of Hollywood. But before Hollywood, New Jersey was the movie capital of the world.
New Jersey became the movie industry's home because motion pictures were invented here. William Kennedy Laurie Dickson, a worker at Thomas Edison's West Orange laboratory, invented the first movie viewer and movie camera. The camera was called a kinetograph, and the peephole viewer was called a kinetoscope. The names come from the Greek word kineto, which means movement.
Work on the camera and viewer began in 1888. By October 1892, Dickson and Edison had finished versions of the products. They used flexible 35-mm film from the Eastman Company (now Kodak) to take the pictures.
The first movie devices looked like kitchen cabinets. The kinetoscope was originally four-feet tall. A peephole on top let the person see the image. Inside, 50 feet of film moved through a number of spools. A lamp beneath the film allowed the pictures to be seen. As the pictures rapidly moved over the lamp, the still pictures appeared to be moving. For more details on the Edison laboratory's work on inventing the movie camera and viewer, check out the Library of Congress' Web site on Edison Motion Pictures.
Black Maria
Now that they had a way to make and show movies, Edison and his assistants needed to produce things to show. In December 1892, the Kinetographic Theater, better known as the Black Maria, was opened in West Orange. Black Maria was a name used for police wagons at that time, and the Kinetographic Theater was a similar tar color.
Only sunlight was strong enough to allow images to be seen on movie film at that time, so the roof of the studio opened to let in sunlight. The entire Black Maria could be rotated to keep it aligned with the sun.
Inside the theater, there was a stage, which was barely 12 square feet. The kinetograph in the studio was very heavy and large, so it always stayed in one spot, pointed in one direction. For closer shots, people moved toward the camera.
In 1893, Edison conducted the first public demonstration of the kinetoscope at the Brooklyn Institute of Arts and Sciences. To Edison's surprise, the public responded in a big way. The first Kinetoscope parlor opened in New York, followed by similar openings all over the country.
The next year, more than 75 films were made in the Black Maria. Each lasted about 20 seconds. All films were silent and in black and white. Dickson and another Edison assistant William Heise were the first cinematographers.
Many different people and actions were filmed at the Black Maria. Segments of vaudeville acts, plays, magic tricks, and dancing were all captured. Many of the famous people of the day including Buffalo Bill, gunslinger Annie Oakley, and strongman Eugene Sandow performed for the camera. Many of Edison's films are still available, and you can view them online.
After a few years, Kinetoscopes began falling out of favor as other inventors had developed movie projectors. Viewers could now see films on a screen instead of by looking in a peephole. Also, smaller, portable cameras were now used. With these two advances, longer films shot in different scenes could be created. The Black Maria was too small to make such films, and it was closed in 1901.
"The Great Train Robbery"
The closing of the Black Maria did not spell the end for the movie industry in New Jersey. Thanks to its varied landscapes, New Jersey provided a great setting for many kinds of movies.
The most popular among New Jersey films was "The Great Train Robbery." (Watch the movie online.) Edison's cameraman Edwin S. Porter directed and filmed the landmark western. Porter, considered the "father of American story film," shot the ten-minute, 14-scene movie in various New Jersey locations including Paterson. It was the most popular and commercially successful film of its time.
The film was quite different from other movies. Edison had been filming everyday events such as snowstorms. Porter convinced Edison people would flock to the theaters to see a story on film. Porter was the first director to use close-ups and edit film to create suspense.
Porter and a group of local actors headed for the wilds of New Jersey to shoot the film. The plot was inspired by a true event that occurred on August 29, 1900, when four members of Butch Cassidy's "Hole in the Wall" gang halted a train on the Union Pacific Railroad tracks in Wyoming. The bandits blew up the safe in the mail car to escape with about $5,000 in cash before a posse arrested them.
The ending of the film was most exciting to viewers. A gun was pointed straight at the audience and fired right in their faces to startle them. The scene never failed to send viewers in the front row diving for cover.
With the popularity of narrative films soaring, movie stars were born. Fort Lee became the home to many of the first movie stars. Mary Pickford, Douglas Fairbanks, Pearl White, and Harold Lloyd all performed and lived in Fort Lee.
However, World War I spelled the end of the movie industry in New Jersey. Soon almost all movies were made in Hollywood. In recent years though, the film industry has come back to New Jersey, as it is no longer as necessary to shoot all movies in a central location.


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June 22, 2011 -- A single gene may be responsible for the pain suffered in many people diagnosed with a type of peripheral neuropathy that previously had no known cause, a study shows.
The discovery could lead to effective treatments for the disorder, which is often characterized by burning, tingling, and numbness in the hands and feet.
The study is published in the Annals of Neurology.
Peripheral nerves are any nerves located outside the spine or brain. Damage to them -- whether by injury, infection, diabetes, or other cause -- results in peripheral neuropathy.
Treating the underlying cause of peripheral neuropathy often relieves the pain. However, for nearly a third of those diagnosed with the disorder, no such underlying cause can be identified, which greatly limits treatment options.
"For millions of people, the origin of this intense pain has been a frustrating mystery," co-researcher Stephen Waxman, MD, PhD, a professor of neurobiology and of pharmacology at Yale University, says in a news release.
'Mystery' Cases of Peripheral Neuropathy
Now, though, Waxman and his fellow researchers at Yale, the Veterans Affairs Medical Center in West Haven, and the University Maastricht in the Netherlands believe they have found a genetic mutation that may account for as many as 30% of these mystery cases, known as idiopathic small nerve fiber neuropathy.
Twenty-eight Dutch patients were recruited for the study after being screened for any possible known causes of the disorder. Genetic analysis revealed that eight of these men had mutations in the SCN9A gene, which, the study notes, has been associated with other pain-causing disorders.
Further analysis showed that the mutation triggered hyperactivity in certain neurons, possibly leading to nerve degeneration and subsequent development of neuropathy.
"These findings will help us as clinicians to a better understanding of our patients with small fiber neuropathy and could ideally have implications for the development of future specific therapies," University Maastricht neurologist Catharina G. Faber, MD, PhD, one of study researchers, says in a news release.

subset: commoncrawl


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Browse by Journal Title
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Puthussery, Shuby, Twamley, Katherine, Mirsky, Judith, Macfarlane, Alison, Harding, Seeromanie and Baron, Maurina (2009) Born in the UK: Maternity and postnatal care needs of UK-born ethnic minority women. Diversity in Health and Care, 6 (1). pp. 65-72. ISSN 1743-1913 (Print), 1743-4904 (Online)


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|Oracle® Text Application Developer's Guide
11g Release 1 (11.1)
Part Number B28303-01
|View PDF
This chapter covers issues relating to migrating your applications from previous releases of Oracle Text. This chapter contains the following sections:
No changes to applications are required when migrating to Oracle Text 11g Release 1 (11.1).
This section covers issues relating to migrating your applications to Oracle Text 10g Release 2 (10.2). This information is provided for those users who may be upgrading from the next-to-last release of Oracle Text and who want to know what migration steps were required to upgrade to the last release.
For Oracle Text 11g Release 1, the
INSO_FILTER filter type has been replaced by the
AUTO_FILTER filter type. To maintain compatibility with existing Oracle Text applications,
INSO_FILTER functionality is supported by
AUTO_FILTER, and the
INSO_FILTER filter type is being retained, although its behavior has been changed to match that of
For most users, the change in filter types will have no significant effect, and most users will not have to change their applications or otherwise take any steps to migrate to the new filter type. The most significant differences produced by this change are as follows:
AUTO_FILTER supports a different set of document types than
INSO_FILTER. For a list of supported document types, see the Supported File Formats appendix of the Oracle Text Reference.
Display characteristics of HTML output from the new filter may differ from those output by the old filter.
A different set of platforms support the
AUTO_FILTER type than support
INSO_FILTER. For a list of supported platforms, see the Supported File Formats appendix of the Oracle Text Reference.
Along with the change from
INSO_FILTER to
AUTO_FILTER, several related changes are also part of the filter migration:
INSO_TIMEOUT and
INSO_OUTPUT_FORMATTING attributes of
MAIL_FILTER have been replaced by the
AUTO_FILTER_TIMEOUT and
AUTO_FILTER_OUTPUT_FORMATTING attributes, respectively.
INSOFILTER directive used in the mail configuration file of
MAIL_FILTER has been replaced with the
AUTO_FILTER directive.
The PL/SQL constant
TRACE_IDX_INSO_FILTER for tracing, used in procedures such as
CTX_OUTPUT.ADD_TRACE, has been replaced by the
TRACE_IDX_AUTO_FILTER filter.
The system-defined preference
CTXSYS.INSO_FILTER has been replaced by the
CTXSYS.AUTO_FILTER preference.
The default values of
DEFAULT_FILTER_FILE and
DEFAULT_FILTER_BINARY system parameters has been changed from
CTXSYS.INSO_FILTER to
CTXSYS.AUTO_FILTER for new installations and databases upgrading to this release, if these default values have not been modified. For databases upgrading to this release which have modified these default values, the modified default values will continue to be used.
For backward compatibility,
INSO_FILTER, as well as most of its associated filter types, constants, and attributes have been retained in this release; however, users should use
AUTO_FILTER in new applications and update their older applications whenever possible.
Most applications will not have to be modified to reflect the change to the
AUTO_FILTER type. The following migration steps will be performed automatically when you upgrade to this release:
If an existing index uses the
INSO_FILTER filter type, then it will be migrated to the
AUTO_FILTER filter type.
If an existing index uses the
MAIL_FILTER filter type, then the
INSO_TIMEOUT and
INSO_OUTPUT_FORMATTING attributes will be migrated to the
AUTO_FILTER_TIMEOUT nd
AUTO_FILTER_OUTPUT_FORMATTING attributes, respectively.
If the default values of the system parameters
DEFAULT_FILTER_FILE and
DEFAULT_FILTER_BINARY have not already been modified, then they will be migrated from
CTXSYS.INSO_FILTER to
Although no actions are required to migrate to the new filter system, Oracle Text users upgrading their databases to this release should take the following steps to migrate away from using APIs deprecated by this release:
If an index uses the
MAIL_FILTER filter type with a nondefault mail configuration file, edit the file, replacing all occurrences of the
INSOFILTER directive with the
AUTO_FILTER directive.
Replace the use of the PL/SQL constant
TRACE_IDX_INSO_FILTER in your application with the
TRACE_IDX_AUTO_FILTER constant.
Replace the use of the system-defined preference
CTXSYS.INSO_FILTER in your applications with


text:
- With Smart Replication, you can perform DR drills and failover testing without reseeding of source data. Like other scenarios, application data is always replicated to your own Azure Storage account to ensure security and isolation.
- With Support for Resize of Source Volumes, your on-premises applications can grow in size, without losing the assurance of ASR's on-going replication and protection
- Now, your DR setup can scale to meet your organizations needs with Process Server Failover and Load Balancing
- With Multi-NIC Support for your Linux workloads, you get better control over how your virtual machines' network connectivity is configured when you replicate them to Azure
- We are also expanding coverage for non-English deployments; customers that use non-English locales for their ESXi host names, vCenter Server names, resource names, and source machine names, can now benefit from ASR's replication and protection to Azure capabilities
Announcing the GA of Disaster Recovery for VMware Virtual Machines and Physical Machines to Azure using ASR
I'm excited to announce the GA of an important functionality in Azure Site Recovery (ASR) that lets you enable replication and protection of your VMware workloads and physical machines to Azure. ASR, with its ability to protect Hyper-V or VMware virtual machines and physical machines, is a unified solution for workload-aware disaster recovery and protection of your heterogeneous and hybrid IT environments. The functionality has been in Preview since March this year, and has successfully passed the rigorous evaluation and validation goals of our early customers. With marquee customers already on board, and with their early feedback incorporated, ASR's SLA-backed offering is now ready to replicate your on-premises workloads to Azure. ASR, as the replication technology behind Microsoft's Availability on Demand (AoD) solutions, enable enterprises and service providers of all sizes, to use Microsoft Azure for DR, Cloud Migration, DevTest, and other enterprise scenarios. The GA builds on top of the feature set that we delivered during the Preview, which has been expanded to offer the following enhancements:


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How Tasty Was My Little Frenchman is a witty tale about a tribe of naked Brazilian savages and their violent contact with the encroaching Europeans. Veteran Brazilian director Nelson Periera dos Santos (Vidas Secas) fashions a fascinating vision of life among the cannibals that makes us think about the eradication of America's indigenous peoples.
Watching How Tasty Was My Little Frenchman is almost like watching One Million Years, B.C.: Since everyone is talking in a foreign language the hero barely understands, the film is an almost comic examination of two cultures in conflict. Our hero protests that he's French, and even the native warrior chief decides that his language sounds like that of a Frenchman, not a Portuguese. But the ritual of slaying and eating captured enemies is strong in the Tupinambá tribe, a balanced little community of beautiful naked people that divide their time between enjoying nature and waging bloody war on their neighbors.
Our Frenchman is in a bind from the beginning. Deciding that he's an edible Portuguese seems more a matter of appetite than logic, even though the Frenchman strives to prove how useful his two little cannon can be during war raids. The chief gives the Frenchman "eight moons" to live and assigns a young widow to take care of him; he's soon cutting his hair after Tupinambá fashion and participating in battles. The Frenchman is also stark naked along with the rest of the cast, giving How Tasty Was My Little Frenchman its only troubling detail: how does he avoid becoming horribly sunburned? The Frenchman's beautiful new wife seduces him and treats him as a precious object, all the time referring to him as "My little neck." That's the part of his body that the chief says will become her personal meal. The heathen Tupinambas believe that by consuming an enemy, they incorporate his spirit, personality and special strengths. The conquering Europeans talked about 'assimilating' native populations into their superior social systems, which usually meant the eradication of tribal religion and customs, if not outright extermination. These tribesmen are doing the same thing, more honestly. The Frenchman may be consumed, but he'll become part of everyone who eats him, and therefore truly enter the tribe. When Seboipepe says she'll eat him, it's a twisted term of endearment. She loves him like a husband, but in eight moons he's going to be dessert.
The greedy trader makes the French captive work for him in exchange for a vague promise to help him escape. A jar of gold coins immediately comes between the two Europeans, with predictable results. The Frenchman develops a secret escape plan with a hidden canoe ready to go. Unfortunately, the Tupinambás haven't survive hundreds of years in the wild by being stupid.
In How Tasty Was My Little Frenchman we learn along with the Frenchman how life in the native village functions. Tribal ways are simple and direct, with a most communal activity centered on the paternal chieftain figure. Although the wall-to-wall nudity reportedly kept the film out of some festivals, we soon adjust to all the naked people. Unlike many stories about primitive cultures, the tribal camp looks clean and the natives healthy. The picture also doesn't dwell on violence or sex scenes.
The film maintains its satiric edge by periodically introducing quotes from the notebooks of early explorers, commenting on the weirdness of the tribes they have discovered. Although How Tasty Was My Little Frenchman hastens to its only logical ending, a text postscript assures us that 'justice' would soon be done. Within a decade, the newly appointed governor of Brazil will start a campaign of extermination against the many native tribes. An entire civilization would soon be wiped out.
New Yorker's DVD of How Tasty Was My Little Frenchman is a good-looking disc mastered from excellent printing materials. The flat image is colorful and the soundtrack brims with unusual native music composed by Guilherme Magalhaes Vaz and José Rodrix. Columbia University film instructor Richard Peña talks at length on the film in an interview, but Dos Santos biographer Darlene L. Sadlier's liner notes are more concise and informative. Brazilian native Ailton also speaks on camera, praising How Tasty Was My Little Frenchman's a positive image of tribal peoples.
On a scale of Excellent, Good, Fair, and Poor,
How Tasty Was My Little Frenchman rates:
Movie: Excellent and pretty much in a class of its own, ethnographically speaking
Video: Very Good
Sound: Very Good
Supplements: Interviews with Richard Peña and Ailton; liner notes by Darlene L. Sadlier.
Packaging: Keep case
Reviewed: May 10, 2007
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Hogan, Ben
Hogan, Ben hō´gən [key], 1912–97, American golfer, b. Dublin, Tex. A former caddie, Hogan began his professional playing career in 1937. One of the game's great money winners, he won the Professional Golfers Association championship in 1946 and 1948. After sustaining serious injuries in an automobile accident (Feb., 1949), Hogan made a dramatic comeback with his second U.S. Open victory in 1950. His career featured victories in nine majors, including two Masters titles, one British Open crown, and four U.S. Open wins. He won all of these three major tournaments in 1953.
See biography by J. Dodson (2005), also the author of American Triumvirate: Sam Snead, Byron Nelson, Ben Hogan, and the Modern Age of Golf (2012).
The Columbia Electronic Encyclopedia, 6th ed. Copyright © 2023, Columbia University Press. All rights reserved.
See more Encyclopedia articles on: Sports: Biographies


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"Take part in a greatest car racing competition in this car racing game. Download free full version game now!
""Dhoom Race"" is a racing game with all new themes and concept.
5 players are running in ""Dhoom Race"" to compete and win this prestigious Race.
Many levels of race is there to complete. You have to complete all the levels to win this Trophy.
Total distance cover will be the deciding factor to win this race.
New racing concept is also there.
You can also watch the current position of players in Map View.
Features :-
***** Smooth control.
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***** Easy to play yet addictive
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Download and enjoy. Do provide your feedback as review."


text:
TV's Hottest Cop
Depending on the language, the culture and the particular time in history, the story of a great winged bird being consumed by fire and then rising from the ashes—sometimes larger, grander and more glorious than before—may differ in name, but the lesson or moral is the same: out of death comes rebirth; out of ashes and rubble, a grand rebuilding. The early Egyptians called this creature Bennu. In Russian folklore it's Zhar-Ptitsa, the firebird. And the early Greeks called the creature by its more familiar name, the phoenix. Today, in Hollywood, it's called David Caruso.
Numbers matter in Hollywood but even Tinseltown's most talented screenwriters would have a hard time coming up with a more compelling "phoenix from the ashes" story than that of actor David Caruso. His staggering success on "CSI Miami" eclipses nearly any rebirth-and-success script that Hollywood could possibly produce.
Each week, an estimated 50 million viewers around the world tune in to catch Caruso—as dedicated crime scene investigator Lieutenant Horatio Caine—and the rest of the "CSI: Miami" cast fight terrorists, snatch potential tsunami victims out of harm's way and catch (or kill) drug lords, murderers and kidnappers through their work on the street and in the forensics lab. That the show is so spectacularly successful around the world should come as no surprise; "CSI: Miami" is, after all, the 2002 spin-off of the then-two-year-old, No. 1 drama series on television, "CSI: Crime Scene Investigation."
A spin-off of any show, even one with the incredible ratings of a "Friends" or "Seinfeld," could—and often does—bomb right off the bat with the fickle American audience. But with the original Las Vegas—based "CSI" introducing its Miami-based little brother and cast—especially David Caruso as the male lead—Act 2 in the "CSI" series was orchestrated beautifully, right from the opening credits.
Now in its fifth season and having, in turn, helped spin off yet a third act in the CBS—Jerry Bruckheimer franchise by introducing the cast and story line behind "CSI: New York," the show's success makes perfect sense. But the fact that Caruso, as the red-haired, fair-skinned and infinitely grim Horatio Caine, has become an international star still comes as a bit of a surprise to the 50-year-old actor. A pleasant surprise.
"On a return trip to Los Angeles from Cannes this spring, I was in Heathrow and there were people from all over the world [recognizing] me and talking to me, and suddenly there was this gaggle of about 20 people from Taiwan that came running over. The only word they knew in English," says Caruso, a little sheepishly, "was 'Horatio.'"
Caruso grins and shakes his head as he tells the story. "It wasn't, you know, as if it was the Rolling Stones walking [by] at Heathrow. I mean, it's not like seeing and running up to Mick Jagger…now, he's bigger than life!"
Well, in some respects, so is David Caruso's Horatio Caine. "CSI: Miami" now airs in some 200 countries and is estimated by industry tracking guides to be the most-watched television show on the planet. That 12 years ago David Caruso was having trouble landing acting roles—any role, much less one as the lead in a series with the lineage and capacity for success that "CSI: Miami" offered—isn't lost on him.
For one thing, as Caruso is quick to point out, he doesn't have what he calls "leading man looks. In acting, especially in motion pictures, in my opinion, you have to have a level of physical beauty that is on the superlative level. If you look at the current crop of stars out there, they have a very superior physical presence on camera. Let's face it, you just can't look away from Brad Pitt," Caruso laughs. "Pitt has tremendous physical beauty and presence, much like Paul Newman did. Now, if they're interested in me, they're interested in, you know, a 'street version' because I just don't look like a leading man."
David Caruso is, in fact, an attractive man and one of those rare creatures in Hollywood who is actually more attractive in person than on the screen; he has a softer, more animated face that not only lights up when he smiles and laughs, but also moves when his expression changes, a rarity in Botox-friendly Southern California.
Whether it's Caruso's looks by themselves or his ability to portray a strong, responsible, "nobody-knows-the-trouble-I've-seen" street-weary cop, the actor has an undeniable "it" factor when it comes to popularity with both male and female viewers; for proof, one need look no further than the success he had on the gritty crime drama "NYPD Blue."
Although Caruso had some modest success in the '80s with small roles in movies such as Thief of Hearts, An Officer and a Gentleman and First Blood, it was his skill at playing Detective John Kelly on "NYPD Blue" that first made David Caruso a household name. Well, that and an episode involving his naked butt, which helped set a new standard for nudity on prime-time television.
When it debuted in 1993, "NYPD Blue" had the same kind of impressive pedigree as "CSI: Miami." Created and executive-produced by Steven Bochco, the same man behind the back-to-back hit dramas "L.A. Law" and "Hill Street Blues," "NYPD Blue" featured an ensemble cast of characters whose strengths and weaknesses, foibles and faux pas were recognizable to the average viewer. Even in its first season the show was a runaway hit, and much praise was heaped on the cast, which included Gordon Clapp, a relatively unknown Dennis Franz and, of course, Caruso.
If there were industry rumors that egos were expanding—and clashing—on the "NYPD Blue" set, these tales were muted compared to the hype surrounding the show itself. Caruso was terrific as Kelly and he played the role to the hilt…for just 26 episodes. In 1994, only four episodes into the second season of the top-rated show, Caruso decided to play a little career poker. With a movie offer in hand, he asked for an extraordinary salary increase. The network called his bluff and Caruso walked, telling the press that "'NYPD Blue' will not be successful when I leave."
The movie that Caruso left to make was Kiss of Death, a medium-budget suspense feature that had Caruso playing a good-hearted ex-con opposite Samuel L. Jackson and Nicolas Cage. Perhaps the film's title should have served as an omen to Caruso; released in late 1994 and grossing less than $15 million in the United States, the film didn't live up to anyone's expectations, especially Caruso's. And his next big-screen venture did even worse. In spite of returning Caruso to a role that had him on the right side of the law, the erotic thriller Jade cost nearly $50 million to make and took in less than $10 million in its U.S. release. A year after Caruso had earned an Emmy nomination and a Golden Globe award, for Best Performance by an Actor in a Television Series—Drama, for "NYPD Blue," he found himself nominated for a Razzie Award for Worst New Movie Actor.
With those kinds of box-office numbers and generally scathing reviews of his performances, 1995 was a bittersweet year for the actor, then 38. It was also the beginning of a very quiet decade in David Caruso's career and no one, it seems, takes on the burden of responsibility for that debacle more than David Caruso.
"I wasn't ready for the success," he says, quietly. "Not then."
When reminiscing about his early career and the people he worked and spent time with, Caruso is unflinching both in his admission of "letting others down" in his abrupt departure from "NYPD Blue" and his acknowledgement of the wide berth that Hollywood gave him in the years to follow.
"My experience over the past 30 years [acting] is that Hollywood casts itself and Hollywood will let you know where you belong," Caruso explains, haltingly. "Different people serve different functions. Hollywood will say, you know [pointing as if to an actor lineup], 'features, features, television, television, features, television, theater, features, television.' And," he pauses, "they cast it themselves because there are people they have needs for. They need to fill these slots and these functions, and some people are considered big-screen people and some are television people."
Caruso had always dreamt of being on the big screen, but, he says, Hollywood told him "television." Caruso had done some TV roles prior to "NYPD Blue" and, in fact, had come to interest Steven Bochco as a possibility for the role of John Kelly because of the recurring role he played on Bochco's earlier police-themed hit, "Hill Street Blues."
Caruso insists that he loved the idea of "NYPD Blue" from the moment he was approached to play Detective Kelly, calling the show "one of the greatest [television] hours ever. 'NYPD Blue' had a feature [film] sensibility and a feature quality to it, and when I first looked at a brilliant script by David Milch for the show, it read like a 1930s Jimmy Cagney picture! It was brilliant and it read, it felt, like a feature movie."
Unfortunately for Caruso, although it was a hugely successful role for him, it wasn't the feature movie that he'd always dreamed about. When the offer came for the lead role in Kiss of Death, he says he made a knee-jerk decision.
"I think," Caruso says slowly, "that my inexperience in the area of responsibility and my inexperience with the suddenness of opportunity caught up to me…the sudden opportunity to be on the big screen. It was something that I'd always fantasized about but I guess never taken that seriously because I [hadn't] gotten that signal from Hollywood. Remember, I was 'television,' not 'feature.'"
Suddenly, Caruso says, his popularity and immense exposure on "NYPD Blue" gave him that big-screen opportunity and, he admits, some arrogance. "I was overwhelmed with the suddenness of it…and I didn't have the wherewithal and the experience to make good decisions at the time. I was making decisions from a very green perspective and it got away from me in a way that was painful to a lot of other people. The easy, cheap answer is that if I had the opportunity to redo it I wouldn't have left 'NYPD Blue' because that was my world, my opportunity and, you know, at the end of the day in show business, you just don't," Caruso chuckles, "leave a hit show."
If, as Caruso puts it, the entertainment industry takes it upon itself to cast talent in the style and roles it deems fit, it also reprimands those who step outside of the slot in which they've been assigned. With the rare exception of names such as Clooney, Depp, Travolta and Aniston, very few actors have successfully made the move from television to features, and Caruso, who had ruffled some feathers on his journey, suddenly became Hollywood's very public poster boy for bad decisions and bad behavior.
Late-night comedians and talk show hosts routinely used phrases such as "pulling a Caruso" when referring to someone's career backslide; film critics would use Caruso's career decisions as a measuring stick when looking to diss another television actor's foray into feature films, and even Comedy Central's animated show "South Park" got in a dig when one of the main characters urged his brother to jump from a dangerous height with the words, "Show me your imitation of David Caruso's career!"
Ouch. Being openly dissed in an industry so ready to eat its own might make a lesser man turn, tuck tail and run. What no one counted on was Caruso showing some stamina. And some spine.
Born in Forest Hills, New York, David Caruso was simply born stubborn, an amalgam of an Italian father, an Irish mother and a family that split apart just two years after David's birth. To support David and his older sister, David's mother, Joan, moved with her young family into her parents' home and went back to school to become a librarian.
Caruso describes his early years growing up in Queens as merely average. He was, by his own admission, a mediocre student who didn't get excited about much of anything unless it involved the movies. In fact, there was one particular movie that, he says, goes a long way toward defining the sheer wonder he felt as a child, at spending two hours in a darkened theater.
"It was The Godfather," Caruso says, "and my closest friend, Lou Mathis, and I went to see it on a Friday night. We took the Q60 bus down Queens Boulevard to the Elmwood Theatre to see The Godfather. We were 13 years old and we came back changed. Changed! We stood under the lamppost on Puritan Avenue and I said, 'Lou, I'm going to do that for a living.'"
Caruso shakes his head and smiles at the memory. It was an impractical aim for the boy that he was, coming from a neighborhood where the straight-A students would choose law or medicine, and those with study habits like Caruso's would opt for civil service jobs.
"I was 13 years old and it was an absolutely ludicrous statement to make," says Caruso. "I was not as academically inclined as some people and I don't think I had the discipline at the time. I'm more of a left-brain person. The consumption of repetitive material is something that I'm, uh, not designed for."
That perceived deficit didn't, Caruso admits, keep him from repetitively consuming The Godfather—and the first sequel—many times over. "Which character did I identify with? God, every one of them was so electric that I think that varied. Some days you were Sonny, some days you were Michael and some days," Caruso grins, "you were Fredo."
In spite of his career declaration at 13, Caruso simply waded his way through the rest of school and, although he played a little basketball when he attended Archbishop Molloy High School in Queens, he didn't have a specific game plan for his life or career until, once again, he found himself in a darkened theater, this time, as a movie usher.
While Caruso never doubted his absolute certainty about acting as a career choice, he knew that, for a boy from a middle-class neighborhood in Queens, the chances of achieving that dream were pretty slim.
"There was no reality to that [early] desire because I was just another boy on the F train. But," Caruso pauses, "when I became the usher at the movie theater and began to be more influenced by the films, I think the seed of something kind of regerminated. And the thing about New York," Caruso grins, "is that anybody could make up a résumé and go around and try to get people, fool people, into hiring you."
That Caruso easily admits to the emphasis he placed on the "make up" and "fool" part of his résumé is simply evidence of the spine that Caruso would develop in earnest when he decided to go after an acting career.
"The catch-22 with this town is that you have to have something on film for them to even consider looking at you, but how do you get something on film to show unless…? So, OK, I had a résumé that wasn't entirely accurate, but it wasn't about what I had done, it was about what I was capable of. And agents in New York are, of course, the gateway to opportunities, so it was all about the seduction of those agents and the pursuit of those agents. I was a fairly aggressive young man," Caruso says, grinning again, "and I was one of those guys out there in February with my 8 by 10, pushing it under their door."
It became, says Caruso, a game. "I'd push it under, they'd push it back. I'd push it under, they'd push it back. This would go on until finally the guy would open the door and furiously say, 'Look, you're not right for me. If you don't leave, I'm going to call security.' And I," Caruso says, laughing, "would put my foot in the door and say, 'Let me make you a deal.' Now, this is an actual situation I'm telling you about! I'd say, 'Here's the deal. If you send me out once and I don't get the job, I will never bother you, never darken your doorway again.'"
One agent, unable to slam his door shut with Caruso's foot wedged in the jamb, was intrigued enough to ask the then 19-year-old to do an impromptu monologue. Sufficiently impressed, the agent sent the teenager out to audition for an A&W commercial and Caruso snagged the job. Suddenly he had his first legitimate acting credit.
A root beer commercial does not an instant star make, but it was the turning point for Caruso. With that lone credit to his name, along with an actual agent, he was able to snag a few additional acting jobs, and then, with $1,000 in his pocket, he made his way to Hollywood.
By the early 1980s Caruso was getting regular roles on television shows such as "CHiPs," "T. J. Hooker," "For Love and Honor" and, ultimately, Steven Bochco's "Hill Street Blues." Caruso, who'd married actress Cheri Maugans not long after arriving in Los Angeles, divorced in 1984 and quickly got married again, to another actress, Rachel Ticotin. Caruso and Ticotin had a daughter, Greta, before divorcing three years later.
Caruso's career continued on a steady pace, a mix of television shows such as "Crime Story" and small parts in big-screen features such as King of New York, Hudson Hawk and Mad Dog and Glory before landing the role of Detective John Kelly in "NYPD Blue."
For the first time in his career, Caruso had real fame—the kind of fame that had fans flooding the network with letters and people on the street begging for autographs—and if Caruso's decision to leave the show backfired on him, Caruso couldn't, he said at the time, do much about it. "I went from a guy, kind of a working actor, a supporting player, to magazine covers and being offered the studio picture really quickly. Nobody was comfortable with it. I wasn't really comfortable with it," Caruso said in an interview years after leaving. "I was a guy who abandoned a TV show. I didn't care about people. They didn't want to see good things happen to me."
But, not unlike a Rocky-style Hollywood movie script that has a battered fighter pushing his way back up to champ status, good things did happen to Caruso during the period when, as he put it, "I went from starring in a Paramount movie to unemployment for two years. Literally, I couldn't get a job for almost two years."
Caruso had remarried in 1996—he and Margaret Buckley divorced nine years later—and, ultimately, a couple of feature movie roles came his way, as well as the lead role in the short-lived television series "Michael Hayes." In the middle of it all, Caruso says, he got offered a role that, in hindsight, helped predict the happiness and success that was to come his way many years later. That role was in a TV movie called Gold Coast.
A Showtime cable production directed by Peter Weller, a good friend of Caruso's, the movie was set in Miami Beach, and Caruso's female costar was Marg Helgenberger, now the female lead of "CSI: Crime Scene Investigation."
When Gold Coast was being shot, in 1997, neither Caruso nor Helgenberger could possibly have had an inkling of their future successes on "CSI," but everyone on the set could see a definite sizzle between the two red-headed actors.
"There's a chemistry between [us]," Caruso explains, "but what really makes this all interesting is that I had never been to Florida before we began filming [Gold Coast] and we flew into Jacksonville and kind of made our way down the coast of Florida and ended up in Miami. So the interesting thing is that I discovered Miami with Marg," Caruso says, "and while we were there we ran into Jerry Bruckheimer one night when we were out to dinner.
"Now, we all knew Jerry from other projects, but what you have to remember," Caruso explains excitedly, "is that this was 1997, 1998 and 'CSI' didn't exist yet, not for Marg and certainly not for me. When I look back it was a very interesting foreshadowing for a lot of what was to happen to me, including the whole Miami chapter of my life. I moved to Miami way before I ever got the job, and when I think back on that night at dinner there was a lot of foreshadowing."
At the very least, the universe was sending Caruso some very strong signals. Margaret Buckley, Caruso's wife, had gone down to Miami with him during the shoot and the two fell in love with the city, so much so that they bought a luxury condo there with the intention of living in Florida part-time. The concept worked for both of them and, prior to their divorce, they opened Steam, an upscale clothing boutique in South Beach that Caruso still owns with partners.
"Miami is," Caruso muses, "a magical place…the American Riviera. I say that it's a four-hour plane ride to Europe because it's very European, and I think the influences there are very good to experience [because] priorities there are different. It's less about competition and material resources and money and more about quality of life. I think it's the city in America."
Caruso also credits the magic of Miami with helping propel "CSI: Miami" to the worldwide success it's had. "I think that when we get down there [to shoot], we connect with our soul as a show. It's very authentic and it's good for 'CSI: Miami' to be shooting in Miami, on the streets, in the Everglades sometimes, on some airboats."
Each week the show opens with aerial views of the Miami skyline and pan shots of Miami's beaches that are, while heart-stoppingly beautiful, strictly Hollywood creations; the vast majority of the show is actually shot on a film stage in the California suburb of Manhattan Beach.
Still, Caruso enthuses, on those rare occasions that they get to shoot in Miami, there's a natural response and energy from the cast, the crew and the film that immediately comes across. "When we get to shoot footage down there, you can see the difference right away. From a physical standpoint, the light and the environment simply explode onto the negative [when shooting] in Miami. The California footage is great, but there is a very unique electricity about south Florida when it's on the negative."
As someone who now lives on both coasts, Caruso points out another big difference that he says becomes apparent when they shoot in Miami. "Los Angeles is a big city. A smaller city like Miami means that you have relationships that are very real and day to day, and you're seeing the [same people] all the time. It's much harder, for instance, in Los Angeles where you can do a movie or work on a show with someone and they might be living [in the neighborhood] where I live but I might not see them for 10 years even though they're three blocks away! In Miami, you're going to see them all the time."
Another reason Caruso enjoys his time in Miami is being able to serve as a board member of the nonprofit organization Best Buddies. Based in Miami and founded by Anthony Kennedy Shriver, the international organization helps connect those with intellectual challenges to a "best buddy" at school, at work and in the community.
Caruso's support of the organization and his relationship with his own best buddy, George Morilla, has always been important to the nonprofit, says Shriver, but it sends a special message now that Caruso is so highly visible around the globe. "David's got an impossible schedule, a brand new baby and a top-10 show," says Shriver, "but he's also managed to stay actively involved in his community. I think there are a lot of people who think, 'Oh, I don't have enough time to get involved' or 'The little bit of time I have won't make a difference' and then they see David making time and they start to think, 'Hey, if he can do it, I guess I can do it.'"
The commitment Caruso has made to Miami—on-screen and off—is obvious. He happily spends 10 minutes just mentioning some of his favorite things about South Beach—the best places for a drink, best places for Italian food, best art galleries to visit—and at no time does a smile or a sense of excitement leave his voice. Caruso may reside most of the year in L.A., but there's no doubt that he considers Miami his home.
"You asked me where I exhale?" responds Caruso to a question. "Miami. I exhale in Miami."
Plenty of what he exhales is cigar smoke. Caruso is a cigar lover, and the deck of his condo in Miami has seen a fair amount of cigar smoking over the last few years. "A cigar is a ritual for me, and also a unique way to take a brief vacation from the world…a great way to literally stop the world, have a respite from the things that you need to face.
"I once heard David Letterman say, when talking about cigars to Danny DeVito, I think, 'You get a good one of those and it can change your whole day.' And I have to say there are times where I may have been experiencing some stress or a particularly challenging day and I've said, 'You know what? I'm going to smoke a cigar right now.' "And," he laughs, "the day really does change."
Caruso, who is a member and regular visitor of the Grand Havana Room, both in Beverly Hills and New York, pauses when asked if he's got a favorite smoke or two. "Wow…well, there's a Cuban cigar called a Trinidad which is a fantastic cigar, and I'm also a fan of the Quai d'Orsay, another Cuban cigar. Then there's the Romeo y Julieta Churchill and the Punch Punch and…"
As he rattles off the names of five or six other cigars, it's obvious that he feels strongly not just about what cigar he likes, but what cigar he wants for a particular moment in his life.
"If you're in Paris," muses Caruso, "and it is lunchtime, you want a Montecristo No. 4 because all the Parisian businessmen are sitting and smoking No. 4s! It's a good, short, afternoon smoke. If you are in Italy, in Positano, for instance, there might be an occasion to have a morning cigar, which is also great, but it calls for a different cigar."
Caruso credits his longtime friend, the actor-director Peter Weller, with introducing him to the enjoyment of a cigar. Another close friend of Caruso's who enjoys a good cigar is Rex Linn, who plays Detective Frank Tripp on "CSI: Miami." "So I'm covered," he says, "when I'm in L.A."
Caruso mentions the Lincoln Road area as a great place to shop for cigars in Miami ("Some of the cigar stores have live salsa music in them…very authentic"), but says that when he's not at home, relaxed and sitting on his own deck, he still prefers a club atmosphere when he goes out.
"There is a kind of ritual to going to the Grand Havana Room and meeting another pal who appreciates a good cigar on a Friday afternoon. It's a great reward for me to go there, have lunch and smoke a cigar…it's a male experience in Los Angeles."
Caruso stops for a moment, then adds, "It's not that it's separate from the female experience, because women do go there and enjoy themselves. Sometimes Liza [girlfriend Liza Marquez] comes to the Grand Havana Room with me and if the night is right, she'll take a puff off a cigar and that's pretty cool, pretty sexy."
When Caruso talks about the women in his life—his grandmother and mother, his daughter, his assistant and his girlfriend—there is a distinct change in his voice and demeanor when he describes them, their accomplishments or their roles in his life. Caruso has, it seems, surrounded himself with very strong, very intelligent women.
Caruso describes his mother, Joan, as simply "strong and still living in Forest Hills. She is tough, man, and she's not going anywhere." He describes his daughter, Greta, a 22-year-old recent graduate of Yale, as "beautiful, brilliant. When you have a child like Greta—a very accomplished, incredibly sincere, decent, effective human being—it's a real source of pride."
As for Liza Marquez, his girlfriend of two years and the mother of his 16-month-old son, Marquez Anthony, she is simply called the boss. "She's the boss, man. You know, she's a self-made woman. She's a Penn State graduate. She speaks Spanish and French fluently. She's from San Antonio—a native Texan—and they are strong women!" he laughs. "She has a very developed toughness and softness but at the same time there's also an expectation on you, with Liza, to be a man. She has a limited tolerance for some things. She'll care for your boy side, your scared little boy side, but there's a limited tolerance for it because, at the end of the day, she fell in love with a man and she wants a man, her man, to be there."
When asked if that translates into her calling him on his crap, Caruso throws his head back in serious laughter before responding. "There's no question about it. None. There's absolutely no hesitation on her part to straighten me out."
David Caruso may believe that taking the role in Gold Coast in 1997—the teaming with Marg Helgenberger, the running into Jerry Bruckheimer over dinner, the introduction to Miami—was ultimately a foreshadowing of the launch of "CSI: Miami" (and the significant relaunch of his career), but there was still a five-year gap in which Caruso continued to struggle.
First came a number of parts in small films and then, in 2000, a fairly substantial role in Proof of Life opposite Russell Crowe and Meg Ryan. While the high-profile, offscreen romance of Crowe and Ryan was blamed for the movie's lower-than-expected box office returns, at least one person who saw the film paid attention to the red-haired mercenary-for-hire played by Caruso: CBS executive Les Moonves.
Moonves is the same studio head who, in 2000, gave the original green light for "CSI: Crime Scene Investigation" to the show's creator, Anthony Zuiker, and its producer, Jerry Bruckheimer. It was also Moonves who, having seen the success that rival network NBC had with its "Law & Order" franchise, urged the show's executive producers to develop an additional "CSI" series in 2002 and who, by the way, had an actor in mind for the male lead. Moonves, it seems, had always thought that Caruso kicked serious acting ass in his role as Detective John Kelly on "NYPD Blue."
One of the show's executive producers, Ann Donohue, says that after an arranged meet-and-greet dinner one evening, she and fellow executive producers Zuiker and Carol Mendelsohn walked away convinced that Caruso was, in fact, the man to play Caine. Ironically, she says, David had to fly into Los Angeles from Miami for the meeting.
"There we all were at Morton's for dinner," recalls Donohue, "and David walked in in his leather jacket and jeans and looked so casual and so cool. We talked about what a hero is, what drama is and what we could do with the city of Miami. He'd already fallen in love with the city and had moved there, so he was keen to show Miami's beauty and its uniqueness. Well, literally, we were all kicking each other under the table. We were thinking 'Oh, my God, this is Horatio! This is the guy.'"
Many leather jackets later, Caruso obviously is the guy, and while he responds with humor to the ribbing he gets about his character always running around in the heat and humidity of Miami in black leather or black suits (albeit well-tailored designer suits) while his female costars chase criminals and totter around crime scenes and morgues in three-inch stilettos ("Hey, I'm telling you…Miami is a very, very sexy city!"), he sobers up instantly when asked to describe what makes the terse lieutenant with the dark shades and gunslinger's stance so immensely popular.
"I like to describe him as the consummate civil servant, a high-stakes civil servant, the kind [with a job] where you might not return home at night," says Caruso. "The majority of society is held together by civil servants who are making no money, who will never be acknowledged and who will often never meet the people that they sacrifice their lives for. In a funny way there's almost a calling to that profession and [Horatio] explores the darker side of man. Man has that darker side, and [his actions] have real impact on people's lives. This guy injects himself into these events and handles it. It's what I call the "resolve and relief" of the situation. We need to believe in someone like him, to believe that there are people who can handle things, resolve them."
Horatio Caine—typically called "H" on the show—and the rest of "CSI: Miami" were initially introduced to viewers in an episode merged with "CSI: Crime Scene Investigation," and if the droll one-liners shared between Helgenberger and Caruso had a "been here, done that" familiarity, so much the better. "CSI: Miami" debuted in September 2002 and was immediately successful; in the fall of 2004, the show even did a combined storyline with the newest addition to the CSI franchise, "CSI: New York."
When asked about the early rumblings from the original "CSI: Crime Scene Investigation" cast to the press about the potential for "CSI: Miami" diluting their own success, Caruso shrugs off the thought that there might still be concerns or hard feelings. To the contrary, he says, cast members from all three shows have personally coordinated parties and get-togethers. Any success that one series or series cast member sees could only happen based on the support and success of the others, says Caruso.
"You know, if anything, you could say [our success] was cheating in that we had 'CSI' in the title of our new show and they ["CSI: Crime Scene Investigation"] were number one, the number one drama on television. The other cheat is that we have three senior producers, the creators of 'CSI,' as the captains of our departure. So we had some real vision, some real power behind us, [but] it was also our job to distinguish ourselves and to find out what our signature was, because if we didn't do that we would just be in the shadow of the big show, the Las Vegas show. They basically gave birth to us, introduced us on their show. I understand the business element of it," says Caruso, "but they handled us very well and gave us a real opportunity."
To illustrate his feelings on the subject, Caruso tells of being at an industry event in New York with "CSI: Crime Scene Investigation" stars Helgenberger and William Petersen and feeling the need to address the "push" that the one show had given to the other.
"We—Marg, Billy and I—were at Carnegie Hall together, riding up an elevator, and I just turned to Billy and said, 'Thank you.' And he said, 'For what?' And I said, 'Well, if you weren't so good on this show, I wouldn't have a job right now!'"
If this sounds like a kinder, gentler David Caruso than how the actor was portrayed within the industry 10 years ago, perhaps he has mellowed a bit. For one thing, says Caruso, he's a dad. Again.
"I never thought I'd be a parent again at 50," Caruso laughs, "but it also feels pretty good. I think I have a natural instinct to be a parent, and being a parent makes sense to me."
Still, Caruso admits, it will be a whole different ball game raising Marquez Anthony than it was raising Greta. "You know, boys are vulnerable in a different way. Little girls are developed right away," Caruso says, snapping his fingers, "like that. Boom! They're smart, they're citizens of the world right away. I mean, young ladies are born with credit cards and driver's licenses! They're with it, they know who they are, what they want, they're ready to rock and roll.
"Now, little boys are like 'Uh, what's going on?' and that only continues until they're about 40," Caruso grins. "By 40 you realize you don't know what's going on at all, and by 50 you realize you're totally wrong about everything!
"Females are simply more advanced and have a greater understanding of life right from the get-go. And that's why younger women belong with older men," he says with a laugh. "It takes a long time for young men to start getting what's happening. It takes a long road of repetitive misunderstanding of situations and relationships to really understand what your function is and what's going on. Younger women are too much for men their [own] age.
"Now, Liza is [biologically] a number of years younger than I am, but, as I mentioned before, females are [developmentally] very, very advanced."
Caruso grimaces when asked to share Liza's age ("Uh, you'll need to ask her that one"), but offers that, at perhaps a comparable age, he "didn't have the experience to handle the opportunities I was given. I hurt myself greatly with the decision to walk away [from "NYPD Blue"] and I can tell you in all candor that there was a period where it was hard for me to get work and there was a perception that I needed to work, to change, and that was my responsibility. And I'm not saying that there was a perception that wasn't accurate. It was accurate.
"I had a great deal to learn in order for me to be happy or to be living a quality existence. So the road to where I am now, which I would describe as the happiest I've ever known, is based on that education."
When asked if he could have defined "happy" a decade ago, Caruso thinks long and hard before answering. "Yeah…and I would have been wrong. You know, that's the great mystery and miracle of life. The philosopher in me says to people on occasion, 'Gentlemen, what we do in the next 10 minutes will determine the next 10 years.' I have a greater understanding now of being in the moment and allowing the big picture to shape itself, as opposed to running after the big picture, being concerned about the big picture."
For a man who believes in fate and foreshadowing, perhaps Jerry Bruckheimer's choice for the theme song of "CSI: Miami"— the Who's "Won't Get Fooled Again"—could also serve as a personal philosophy.
"I used to carry around a fortune in my wallet from a fortune cookie, and the fortune read: 'Chinese proverb: If my wishes were granted, my dreams would be smashed.' What that means to me is that if I were given what I think would be good for me, I would shortchange myself; if I were given my version of dreams, I would far under-exceed what life could possibly provide."
Does he still carry a fortune cookie slip in his wallet? "No, but if I did," he says with a laugh, "it would say: 'Chinese proverb: Listen to Liza. She's probably right.'"
Betsy Model is a frequent contributor to Cigar Aficionado.


text:
In its 20th year of publication, Business Line, the business daily from The Hindu stable, has gone in for a relaunch, accompanied by a redesign.
In the image above are the front pages of the paper the day before (left) the new design (right) was unveiled on Thursday, January 23.
Writes BL editor Mukund Padmanabhan in the first issue of the relaunched paper:
"The new look, created by one of the country's finest designers, Aurobind Patel, achieves the extremely difficult task of showcasing content without screaming or attention-grabbing gimmickry.
"Starting with the careful selection of fonts and the colour palette, attention has been paid to the smallest detail to give you a design that is exquisite in its simplicity and its elegance. The effort has been to resolve the traditional conflict between content and design by fusing them into an integrated and harmonious whole."
For the record, Aurobind Patel designed the original India Today and was design director of The Economist, London, before returning to India. He redesigned the Economic & Political Weekly (EPW) two years ago.
The earlier Business Line was designed by Mario Garcia.
Also read: Another boiler-plate redesign from Mario Garcia
Good heavens, another Mario Garcia redesign
Yet another paper redesigned by Mario Garcia
How come Mario Garcia didn't redesign this one?
Finally, a redesign not done by Mario Garcia


text:
Editor: Anthony S. Bakale, CPA, M. Tax.
Consolidated Returns
The IRS Office of Chief Counsel released Advice Memorandum 2012-010, which discusses how certain acquisition-related transaction costs should be allocated between short tax periods when a target corporation (the terms "target" or "subsidiary" are used interchangeably as the context requires) joins a consolidated group. The advice memorandum considers the following three deduction items: (1) The target's nonqualified stock options and stock appreciation rights (SARs) vest on the date of a change in control; (2) the target's financial advisory and investment banking fees incurred in connection with the acquisition become fixed and determinable on the date of a change in status; and (3) the target's debt is retired at a premium after closing on the acquisition date. To aid understanding of the guidance in the advice memorandum, this item briefly summarizes some of the relevant rules that govern the tax years of subsidiaries that join or leave a consolidated group.
Tax Year of Consolidated Group Members
As a general matter, Regs. Sec. 1.1502-76(b)(1)(i) provides that a consolidated group's tax return includes the common parent's items of income, gain, deduction, loss, and credit for the entire consolidated return year. However, the group's return includes a subsidiary member's items only for the portion of the year during which it is a member of the group. The subsidiary member's items that are not included in the group's return must be included in a separate return (including the consolidated return of another group). Specific rules govern the allocation of such items to avoid their duplication or elimination.
End-of-the-day rule and exceptions: Under Regs. Sec. 1.1502-76(b)(1)(ii)(A)(1), if a target becomes or ceases to be a member of a consolidated group during a tax year, its status as a group member begins or ends at the end of the day on which the change occurs. The target's tax year ends for all federal income tax purposes at the end of the change date. The regulations also require that appropriate adjustments be made, such as the restoration of intercompany transaction items or excess loss accounts.
Special rules apply when an S corporation becomes a member of a consolidated group. Under Regs. Sec. 1.1502-76(b)(1)(ii)(A)(2), except where the S corporation becomes a member through a qualified stock purchase with a Sec. 338(g) election in place, an S corporation becomes a member of the consolidated group at the beginning of the day that includes the acquisition, and its tax year ends for all federal income tax purposes at the end of the day preceding the acquisition. This rule prevents the acquired S corporation from having a one-day tax year for the date of acquisition for which it would be required to file a return.
Next-day rule: In certain situations, the regulations acknowledge, strict application of the end-of-the-day rule makes little sense. In such cases, the regulations prescribe a next-day rule. Regs. Sec. 1.1502-76(b)(1)(ii)(B) provides that if, on the day of a subsidiary's change of status as a member of the group, a transaction occurs that is properly allocable to the portion of that day after the event resulting in the subsidiary's change of status, then the subsidiary and all related persons (within the meaning of Sec. 267(b)) must treat the transaction as occurring at the beginning of the following day. The regulations provide some leeway when applying the next-day rule, provided that the treatment is reasonable and consistently applied by all affected persons. The following factors, among others, are considered when making such determinations: (1) whether the items are inconsistently allocated to maximize a seller's Regs. Sec. 1.1502-32 consolidated investment stock basis; or (2), in cases where the transaction causes the subsidiary to affiliate or disaffiliate, whether the applicability of certain special consolidated tax return rules require that the tax consequences associated with the transaction be viewed as occurring while the subsidiary is still a member of the group.
For example, if a member transfers encumbered property to a nonmember target that results in the target's becoming a member of the group, will Sec. 357(c) apply? If the next-day rule is applied, Regs. Sec. 1.1502-80(d) "turns off" Sec. 357(c), and the subsidiary's consolidated Regs. Sec. 1.1502-32 investment basis is reduced to the extent of assumed liabilities, possibly resulting in a Regs. Sec. 1.1502-19 excess loss account. On the other hand, if a subsidiary is a member but becomes a nonmember as a result of a stock redemption using appreciated property, the subsidiary's Sec. 311(b) gain is treated as occurring before the deconsolidation event.
Ratable-allocation election: Regs. Sec. 1.1502-76(b)(2)(ii) permits affected groups to make an election to allocate certain items between periods on a pro rata basis. However, so-called extraordinary items may not be ratably allocated. A detailed discussion of these rules is beyond the scope of this item; however, the ratable allocation rule and the ex traordinary item exception are briefly touched on below.
Advice Memorandum 2012-010
Advice Memorandum 2012-010 discusses how Regs. Sec. 1.1502-76 should be applied when determining the short tax year in which a target should report certain deduction items with respect to liabilities that the target incurs on the date it joins or leaves a group. The deduction items considered are (1) the target's nonqualified stock options and SARs that vested on the date of a change in control; (2) the target's financial advisory and investment banking fees that were incurred in connection with the acquisition and that became fixed and determinable on the change in status date; and (3) outstanding target debt that was retired at a premium on the acquisition date but after the closing.
The advice memorandum presented the following facts: Acquiring is the common parent of a consolidated group (Acquiring Group). On Nov. 30, 201X, a member of Acquiring Group effected a reverse subsidiary taxable cash merger with Target, with Target being the surviving company. The Target shareholders received cash in exchange for their Target stock. Pursuant to Rev. Rul. 90-95, the transaction is treated as a purchase of Target stock. A Sec. 338 election is not made. Acquiring Group and Target are calendar-year corporations. The advice memorandum assumes that each of the three items listed above is deductible by Target on Nov. 30, 201X, the acquisition date. The Regs. Sec. 1.1502-76 treatment of each item is discussed below.
Item 1. Stock options and SARs: At the time of the acquisition, Target had outstanding nonqualified stock options and SARs issued to certain employees. The options did not have a readily ascertainable fair market value within the meaning of Regs. Sec. 1.83-7. In addition, neither the options nor the SARs provided for deferred compensation within the meaning of the Sec. 409A regulations. Under the terms of Target's agreements with its employees, Target was obligated to pay the employees certain amounts for their stock options and SARs in the event of a change in control. Acquiring Group's purchase of the Target stock constituted a change of control that obligated Target to pay its employees under the stock option and SAR agreements. Hence, Target's obligation to make such payments became fixed and determinable on the acquisition date. Target paid its employees a few days after the acquisition date using its own funds or funds provided by other members of Acquiring Group.
Item 2. Target's financial advisory and investment banking fees: Target engaged financial advisory and investment banking firms to provide consulting services for Target in connection with the acquisition. Target's obligation to pay for these services was contingent upon the successful closing of the acquisition, at which time these fees became fixed and determinable.
Item 3. Target debt retired at a premium: In contemplation of the acquisition, Acquiring Group requested that Target retire some of its outstanding debt. Prior to the acquisition date, Target and Acquiring Group agreed that Target would make a nonbinding tender offer to its bondholders to tender their bonds for redemption at an amount that exceeded Target's adjusted issue price. Under the terms of the tender offer, the bondholders could tender their bonds to Target (or, having done so, could withdraw their tender) on or before the acquisition date, but Target was not obligated to accept the tendered bonds. On the acquisition date but after closing, Target accepted the tendered bonds for redemption. Later that same day, Target retired the tendered bonds at a premium using its own funds or funds received from Acquiring Group.
Analysis: Target became a member of Acquiring Group at the end of the day on the acquisition date, Nov. 30, 201X. Pursuant to Regs. Sec. 1.1502-76(b)(1)(ii)(A)(1), the last day of Target's tax year as a stand-alone C corporation was the acquisition date. Consequently, Target had two short tax years during 201X. The first year (a separate return year) began on Jan. 1, 201X, and ended on Nov. 30, 201X. The second tax year (as a member of Acquiring Group) began on Dec. 1, 201X, and ended on Dec. 31, 201X. As a threshold matter, the advice memorandum noted that the proration election described in Regs. Sec. 1.1502-76(b)(2)(ii)(B)(1), which permits subsidiaries that join or leave a group to prorate certain items between the two short years, did not apply with respect to the three deduction items described above because they were extraordinary items.
Items 1 and 2. End-of-the-day rule: The advice memorandum noted that Target's deduction items relating to (1) its nonqualified stock options and SARs vested on the acquisition date and (2) its financial advisory and investment banking fees that were incurred in connection with the acquisition became fixed and determinable on the acquisition date. The advice memorandum reasoned that it would be inappropriate to apply the next-day rule to these items because they did not arise with respect to a transaction involving Target's stock, even though the consummation of the acquisition fixed Target's obligation to pay the deduction items. Instead, both items related to transactions that preceded the acquisition date and to services provided by Target's employees and consultants. Accordingly, the advice memorandum concluded that it would not be reasonable or appropriate to allocate these items to Target's post-closing period. Hence, both items should be allocated to Target's preclosing short-period tax return pursuant to the end-of-the-day rule.
Item 3. Next-day rule: In contrast to its conclusions regarding Items 1 and 2, the advice memorandum commented that Target's deduction item relating to its retirement of the tendered bonds at a premium on the acquisition date but after the closing could properly be allocated to Target's post-closing short period under the next-day rule. The advice memorandum reasoned that the deduction item arose as a result of Target's post-closing decision made on the acquisition date. Although not expressly mentioned, a relevant consideration may have been that Target retired its bonds at the request of Acquiring Group.
Planning Opportunity
Although the advice memorandum may not be cited as legal precedent, it provides some insight into the IRS's view on how certain deduction items should be allocated between short tax periods when a subsidiary joins or leaves a consolidated group. Unfortunately, the practical utility of the advice memorandum is somewhat limited because the facts associated with the deduction items were somewhat contrived, particularly with respect to the application of the next-day rule. Nevertheless, practitioners and taxpayers may be able to optimize the application of the Regs. Sec. 1.1502-76 rules with careful planning.
Anthony Bakale is with Cohen & Co. Ltd., Baker Tilly International, Cleveland.
For additional information about these items, contact Mr. Bakale at 216-774-1147 or firstname.lastname@example.com.
Unless otherwise noted, contributors are members of or associated with Baker Tilly International.


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Sundays with Pastor Phil Morgan at 10am.
PRAYER SERVICES: SUN @ 6pm, TUE / THU @ 8am, FRI (LADIES) @ 10am
Welcome to Brookfield First
Jesus made 3 great statements that chart the course for what the Church is to always be about:
Love the Lord your God with all your heart … soul … and mind.
Matthew 22:37-38
Love one another as I have loved you.
John 13:34
Go and make disciples of all nations.
Matthew 28:18-20
As simply as we can say it, this is our dream here at Brookfield First. A church that really does live and breathe the values of Jesus: Loving God, Helping Each Other, Changing the World.
Everything we do is about moving us closer to fulfilling that vision of our Lord.
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Ebola caseload could exceed 20,000 in course of emergency, UN response roadmap shows
Dr. Bruce Aylward, WHO Assistant Director-General for Polio, Emergencies and Country Collaboration, told a news conference in Geneva: "What we are seeing today in contrast to previous Ebola outbreaks [are] multiple hotspots within these countries, not a single remote forested area, the kind of environments in which it has been tackled in the past. And then not just multiple hotspots within one country, but international disease, and it is now, as you know, really a multinational effort, three countries, heavily affected."
According to the Ebola response roadmap launched by Dr. Aylward, the key milestones are to "reverse the trend in new cases and infected areas within three months, stop transmission in capital cities and major ports, and stop all residual transmission with 6 to 9 months."
The roadmap "responds to the urgent need to dramatically scale up the international response," WHO said in a statement. "Nearly 40 per cent of the total number of reported cases have occurred within the past three weeks."
"The $490 million indicative budget for the roadmap presents a consolidated view of the estimated global resources required over the next six months – by national governments, WHO, some UN agencies and other partners – for the health response to stop Ebola transmission," according to the 27-page document issued by the Geneva-based UN health agency.
Priority is being given to needs for treatment and management centres, social mobilization, and safe burials, it said.
The latest official number of Ebola virus disease (EVD) cases in Guinea, Liberia, Nigeria, and Sierra Leone stands at 3,069, with over 1,552 deaths, making this the largest Ebola outbreak ever recorded, WHO says. An unprecedented number of health care workers have also been infected and died due to this outbreak.
According to the latest West African update, "the overall case fatality rate is 52 per cent. It ranges from 42 per cent in Sierra Leone to 66 per cent in Guinea." A separate outbreak of Ebola virus disease, which is not related to the outbreak in West Africa, was laboratory-confirmed on 26 August in the Democratic Republic of Congo (DRC).
In that update, WHO reiterated that it "does not recommend any travel or trade restrictions be applied except in cases where individuals have been confirmed or are suspected of being infected with EVD or where individuals have had contact with cases of EVD.
The WHO roadmap issued today "assumes that in many areas of intense transmission the actual number of cases may be 2-4 fold higher than that currently reported. It acknowledges that the aggregate case load of EVD could exceed 20,000 over the course of this emergency."
The plan "recognizes that a number of currently unaffected countries could be exposed to EVD (Ebola Virus Disease), but assumes that the emergency application of the standard control strategies will stop any new transmission within 8 weeks of the index case."
The roadmap was based on comments received from a large number of partners, including health officials in the affected countries, the African Union, development banks, other UN agencies, Médecins Sans Frontières (MSF), and countries providing direct financial support, WHO said.
A situation reports map is expected to begin this week containing hotspots and hot zones, present epidemiological data showing how the outbreak is evolving over time, and communicate what is known about the location of treatment facilities and laboratories, together with data needed to support other elements of the roadmap.
Today's Ebola response roadmap covers the health dimensions of the international response. These dimensions include key potential bottlenecks requiring international coordination, such as the supply of personal protective equipment, disinfectants, and body bags.
The roadmap will be complemented by the development of a separate UN-wide operational platform that brings in the skills and capacities of other agencies, including assets in the areas of logistics and transportation. The UN-wide platform aims to facilitate the delivery of essential services, such as food and other provisions, water supply and sanitation, and primary health care.
WHO also said today that it continues to monitor for reports of rumoured or suspected cases from countries around the world and systematic verification of these cases is ongoing. Countries are encouraged to continue engaging in active surveillance and preparedness activities, the healthy agency recommended.
Dr. Margaret Chan, the WHO Director-General, and Dr. David Nabarro, the UN System Coordinator for Ebola who just completed a visit to the affected countries, are expected to be at UN Headquarters in New York next week, a UN spokesperson said.


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Business Standard books' reviewer Nilanjana S. Roy—and CNN-IBN anchor Sagarika Ghose (who has a column in Hindustan Times)—provide the latest update on the state of Indian newspapers.
indian journalism review
Business Standard books' reviewer Nilanjana S. Roy—and CNN-IBN anchor Sagarika Ghose (who has a column in Hindustan Times)—provide the latest update on the state of Indian newspapers.
It is great that Sans Serif has picked up this issue. It has become fashionable these days for some elitists to criticize Chetan Bhagat.
Is it because Chetan Bhagat's books get read by the same "unwashed" middle class masses, whom the elite loves to hate. Perhaps they hate Chetan Bhagat because he does not speak in flawless Harvard accent.
Perhaps they hate him because his books get sold without getting any positive reviews from the elite reviewers in the country. Chetan Bhagat does not need reviewers, he is capable of communicating directly with his audience.
The kind of hatred some elites are capable of conjuring towards bestselling authors of pulp, is amazing. They don't want anyone outside their close knit club to succeed in life.
By the way, my tastes mostly lie in philosophy, politics, technology, history, etc. Hence I have not read the light-hearted stuff that Mr. Chetan Bhagat is known for.
Though I have read his articles in Times of India, and I strongly empathise with his strong views. Someday when I have time and some money, I will try to buy his books and read them.
Well, I enjoy Chetan's articles in TOI. They are witty, timely and uncomplicated communication.
So, what is so wrong with 'anyone who can write passably' voicing their opinion, in news analysis? Is there a rule that only a literary genius is qualified to comment on weighty issues? And is there a reason to read 'newspapers' for a literary taste? I miss Ms. Ghose's point.
Don't understand why mainstream newspapers run after published writers to write 'columns'. Quite often these 'columnists' just fill their columns with trash, because they have to meet 'deadlines'. The most 'prolific' columnist who fills his columns with bilge is Kushwant Singh. But then, he is not alone. Writers who made 'some' name agree to write columns but do not have the honesty to say, 'I am sorry but this week, I do not have anything to say.' They therefore fill their regular columns with trash and even the biggies among newspapers accept it. To cite a recent example, in her recent 'column' in 'Deccan Chronicle', Shobha De had nothing better to do than to review an interview of Digvijay Singh by Barkha Dutt on NDTV. To report what Barkha asked and what Digvijay replied would amount to normal journalism and not 'celebrity columnism'! How then did Shobha supervene it? Oh, come on! It is not so difficult for Shobha who penned 'so many' salacious scenes in her novels. She therefore converted a normal interview of a politician by a journalist into a 'scene' in a 'B' grade Hindi movie! Therefore a lecherous Digvijay flirted with and a coquettish Barkha in the interview. We do not know whether the ageing Digvijay actually flirted with Barkha or whether Barkha actually behaved like a coquette – but that was the gravamen of the column.
Again with the "everyone loves to hate him" card… Can't people agree that his writing is just not that good? His books are completely cliched and his characters have no development at all. So predictable is his work, that even an online Chetan Bhagat plot generator does better! If someone can read the Three Mistakes novel and say that is the best novel they've read, it clearly shows that they've never read any of the classic works of literature. Instead of criticizing the "elitists'" legitimate point of view, why not focus on every newspaper's zeal to have a slice of "Chetan Pie" to boost readership? And if you notice, many of the Chetan articles in print and online at the TOI contain numerous errors (lack of capital I's strike me).
And for all the foot-in-mouth statements; the Coke machine "joke" being the most recent gaffe, people should be dropping this guy like a hot potato. Instead they heap accolades on him despite his poor writing and for supposedly "writing for the common man".
Usually, the Sunday newspapers in other countries have lots of features, critical pieces, and investigative reports. It is only in India that the Sunday newspapers are very boring and offers intellectual zilch. Some of the European newspapers run to 100 plus pages and even there are online specials. Just compare a few of these sites with Indian newspaper and TV sites. They are mostly full of politics and Bollywood trash.
Just ask a question to readers of Indian newspapers: who won the Kendra Sahitya Akademi Award last year? Or who is the most well-known novelist in France today? You will not get an answer. But ask them about the latest item dance and sex scandal. You will definitely get an answer.
Jai Ho Indian journalism.
strange, but true. we cannot deny the fact that the quality of indian newspapers are deteriorating day by day. if we compare only the magazine portion of earlier newspapers with the papers of today, we will definitely find more filth and trash in today's newspapers than what we used to read in magazines five years back. earlier the magazines contained articles about the various sciences, astrological information, vastu shastra, feng shui, nutritional value of various fruits and vegetables, home made remedies, solutions to various problems and discords in marital life, whereas todays' magazines are filled with information regarding Bollywood, salacious articles regarding Hollywood, pictures of various actresses with their coquettish behaviour and the so called information regarding fashion industry which is like absolute bilge used to fill in the newspaper coloumns.