Advanced Entrepreneurship Research Paper Example | Topics and Well Written Essays - 1000 words

Propelled Entrepreneurship - Research Paper Example This will increase the value of the partners. This new brand will expand the incomes of the organization and lessen the danger of disappointment because of enhanced pay sources. The task may devour a normal of 50 million dollars for it to run adequately. The full execution could take a normal of 1 year. The new item will be SMART (explicit, quantifiable, attainable, practical and time bound) (Taylor, 2009). The item is wanted to incorporate cutting edge innovation that will help make an appeal for the affirmations. This will help increment the quality and evaluating of the classes. The organization additionally anticipates support from NGOs and the legislature. School charges will incorporate working costs in addition to benefit for the organization. The fundamental income target will be school expenses, library memberships and offer of activities done in the school by keeping/finishing understudies. Most scholastic establishments everywhere throughout the world will regularly show understudies the essentials to the region of study and leave them to investigate genuine applications for themselves. This implies managers should recruit experienced specialists or first train their own through temporary positions, interior preparing schools, inner online universities, broadened probations and agreements. On the off chance that Triangle arrangements could prepare their own product engineers, bosses would exceptionally welcome the alleviation and request such understudies. Understudies would likewise gain from the real engineers of programming. Triangle Solutions would have the chance of employing the best as well as the most gifted understudies as their staff. It would likewise be an open door for expanded exploration and expertise on programming improvement items. The understudies will enable the organization to build up its items and present new items. The open door will likewise assist the organization with increasing its staff and consistently train the current staff in a modest manner. Most organizations won't incline toward buying instant programming, yet they

Writing a Common Application College Essay

Writing a Common Application College EssayWriting a college common application essay requires preparation and understanding. By writing a college common application essay, students improve their chances of being accepted into the school. For this reason, it is necessary to prepare an essay that is unique, grammatically correct, and focuses on the student's academic and extracurricular accomplishments. Preparing a common application college essay involves being aware of the guidelines for writing the required essay and choosing the appropriate words, as well as developing a plan for editing the essay after it has been written.The first step in preparing a college common application essays is to develop a list of appropriate topics. When developing a list of topics, a student should keep in mind the main reason that they want to be accepted into the college or university. The topic should be related to the main reason for the student to be accepted into the college or university, while providing an insight into the student's history, personality, or overall career goals. Students may also find that writing about activities or interests that they have taken part in while attending the college or university will make their essay more interesting.Writing a college common application essays is not difficult. In fact, it can be quite fun and exciting when writing a college common application essay. Some students find that they are able to write quickly by using keywords. By using keywords, a student can come up with a list of synonyms for words or phrases and use these synonyms throughout the essay.Writing about what interests a student is an important part of writing a college common application essay. Some students find that they can write about why they are excited about the college or university. For example, a student may choose to discuss why he or she is excited about the school's auditorium or about how they believe the instructor's teaching style helps studen ts develop academically.Writing a college common application essays is also based on grammar and punctuation. Most colleges require that a college essay include a certain amount of grammar and punctuation. In order to get accepted into the college, a student must not only provide useful information, but must do so in a way that provides a positive impression of the college. By paying attention to grammar and punctuation, a student can build a good impression of the college and increase their chances of being accepted.The most common mistake that students make when writing a college common application essays is breaking the rules of grammar and punctuation. Many students find that they often break the rules of grammar by using an incorrect number of periods or by incorrectly placing commas within a sentence. In addition, many students will continue to break the rules of punctuation after a sentence has been completed, and do not proofread the work before submitting it.With careful pl anning and preparation, writing a college common application essays is easy and enjoyable. It is not uncommon for students to begin writing a college common application essay after reading a book or watching a video about writing a college common application essay. Taking advice from a friend who has successfully completed an application essay is a great way to start writing a college common application essay.It is also important to note that writing a college common application essays requires some time, but can be enjoyable. By taking classes in the basics of grammar and punctuation, writing a college common application essays is easy. By using these tips, a student can begin writing a college common application essay and improve their chances of being accepted into the college or university that they are applying to.

The USSR's Voracity for Power Essay Example | Topics and Well Written Essays - 3000 words

The USSR's Voracity for Power - Essay Example The two forces doubted one another. America hated Joseph Stalin’s autocracy and socialism in the USSR. The USSR, additionally alluded to as the Soviet Union likewise questioned America for not tolerating them into the universal network. They were likewise discontent with America’s deferral to partake in the World War II, prompting the passing of numerous Russians. In this manner, despite the fact that the Soviet Union and the United States battled during the Word War II as partners, they had just held hands to battle a shared adversary, the Nazi Germany. The significant reason for the Cold War was the move by the Soviet Union to attempt to pick up force and impact in East European nations. After the World War II finished, the Soviet Union isolated itself from the Western partners. The Soviet Union under Joseph Stalin started forceful arrangements so as to pick up impact in east European nations. The United States interceded to stop the Soviet Union’s extension, a nd this brought about the Cold War. After Stalin’s passing, the Soviet Union was taken over by Khrushchev and later by Brezhnev. These pioneers actualized different international strategies. This conversation investigates the Soviet Union’s ravenousness for force and impact as the main source of the Cold War, and the effect of Khrushchev’s and Brezhnev’s international strategies. Beginning of the Cold War Before World War II started, the United States and the Soviet Union had a few contrasts. Initially, the two countries upheld various kinds of governments. The United States upheld majority rules system while the Soviet Union supported socialism. There were additionally monetary contrasts whereby the United States bolstered world facilitated commerce. In any case, the Soviet Union was against global exchange as the Russians felt it would acquire impacts from the west that would compromise their domineering framework. Additionally, when Europe was debilita ted in World War II, the Soviet Union and the United States were the most persuasive forces and every one of them needed to control the other. At the point when the World War II finished, the doubt between the Soviet Union and the United States was elevated by the control of the USSR in Eastern Europe and the angry and overbearing demeanor of the United States to global issues, just as their ownership of a nuclear bomb (Painter, 1999: 15). The Soviet Union had increased impressive impact in Eastern Europe even before World War II finished. The Red Army was in charge of certain pieces of Eastern Europe by 1944. The Soviet Union additionally acquired the control of eastern Germany and got another fringe with Poland at the Yalta Conference in 1945. Towards the finish of the war in 1945, the Soviet Union effectively overwhelmed the eastern European control and affected the races to guarantee socialist mastery in their administrations. Also, socialists in these nations assumed responsibi lity for the most huge services of Military and Defense. The Soviet Union likewise impacted Western Europe’s post-war decisions in nations like France and Italy in 1946 (Phillips, 2001: 123). Stalin solidified the Soviet expert in east European nations and utilized the Soviet Union’

Standard Departure, Route planning, and Weather Considerations - 275 Words

Standard Departure, Route planning, and Weather Considerations (Research Paper Sample) Content: Standard Departure, Route planning, and Weather ConsiderationsStudents NameUniversity AffiliationStandard Departure, Route planning, and Weather Considerations The trip captain is in charge of flight planning associated information such service needs, ground transportation, reservations and catering. He may assign this role to any co-pilot but holds the role of for the work. There ought to be no misinterpretation as to why the pilot is to execute this function. The pilot undertaking the flight planning will make full utilization of accessible data and particular equipment (such as commercial weather services and computer flight planning) offered by the department. Usually, the trip Captain will fly the first leg as PIC when he is departing a departmental site. Succeeding leg shall be according to operational qualifications and through mutual covenant. DEPARTURE PLANNING Most importantly, you should know if your airplane performance is sufficient to satisfy the flight requirements for the particular departure you are about to enforce. These minimums are instituted in Departure and Minimums Procedures. The climb rates stated in the takeoff procedures are in the form of feet for each nautical mile. Thus, you ought to convert those numbers into feet for each minute centered on the groundspeed. If the needed climbs authorizations are even near your airplane performance, do not bet your life. Wait until the visibility and the ceiling are better enough to evade the obstacles visually (Pratt, 2011). If constraint procedure is not posted, you can still climb at about 200 feet for each nautical mile. This should not be an obscurity for a number of aircrafts at sea level though it doubtful as density altitude rises. Light piston identical drivers now aware a 200 ft. per nm climb proportion might not be probable on the individual engine, thus it would be advisable to distinguish if the lower terrain is available around the airstrip (Pooley, 2014). To exe rcise safety about terrain up to when you can go back to a landing to least safe altitude would want that you satisfactory cloud ceilings and visibility. As a least visibility, you may need to take into account having 1mile of visibility per 60 knots the pilot is to fly (Teets, 2010).
Before every flight, the Pilot will acquire aviation weather forecasts and reports and examine the following information to identify the impact on the recommended operations: Up-to-date NOTAM for the terminal of departure, flight route, the destination and the optional destination. Forecast for all relevant stations and routes. Surface weather clarifications for relevant stations.Reports of predictions of severe turbulence, icing or weather and any typical air traffic delays (Pratt, 2011). Pilots will analyze weather forecasts appropriately in advance of recommended aeronautical and alert Dispatch of every condition that may interfere with traveler schedules (Pooley, 2014). This comprises examining w eather forecasts a night prior to an early morning planned departure. Required Publications The Company airplane will carry a modern collection of aerospace charts, instrument methodology procedure charts for the base of function and useful supplementary data. The FAA-certified aircraft flight manual, charts and any useful operating handbooks and supplements for every airplane and installed alternative instrument will be by means of revision/subscription service, as applicable. Every Section airplane will carry aboard an up-to-date set of handbooks during all the trips operation (Teets, 2010). Extra and supplemental publications may be accessed as required. The Chief Pilot must authorize the entire airport-associated subscription and primary purchasers of books. The Co-Pilot first major job is to observe the flight environment by gathering information concerning forecast and current conditions alongside the route he plans to take, and the applying information to create a better con ceptual picture of the situation he can anticipate experiencing during the flight. Since there are numerous bases of weather information nowadays, the issue is just recognizing how and where to search for weather conditions you require. The pilot should seek National Weather Service data and additional flight scheduling information into a suitable, user-responsive platform that is envisioned to provide him with specified details and a big image outlook of the flight surrounding (Pooley, 2014). Flight Service provides four fundamental conference packages for example:StandardOutlook (for many flights)Telephone information briefing serviceAbbreviated (for updating specified items following a standard briefing) Route Planning Air route planning take pre-demarcated passageways know as routes. Routes can be supposed of as three-dimensional freeways for the airplane as shown in figure 2.2 below.
A number of land zones of the globe, airplanes are mandatory to fly routes between takeoff an d terminus airports. The policies guiding airline routing, Standard Terminal Arrival, and Standard Instrument Departure are broadcasted flight procedures covering air speed, altitude and qualifications for arriving and departure routes are 4 kilometers (8 nautical miles) wide, and the route flight levels separates airplane by a minimum of 500 vertical ft., from airplane flying at a level beyond and lower (Pratt, 2011). These routes are shown below:
When working under IFR, amid the altitude and the surface of the flight level of 290, no airplane should come nearer vertically over 1,000 ft. Beyond 290 flight level, no airplane is permitted to come nearer than 2,000 ft. Unless within the airspace in which reduced vertical split-up minima can be employed whereby the vertically isolated is decreased to 1,00 feet. Routes normally interconnect at NAVAIDS designating the allowable points for shifting from one route to another (Pratt, 2011). Routes contain one or a variety of letters follow ed by a single or more numbers. Weather Considerations The specified weather information included in a standard briefing incorporate sky conditions, weather synopsis weather conditions, and visibility, at the departure, en route and destination basis. Also incorporated are hostile conditions, icing conditions, altimeter settings, surface winds, dew points, thunderstorm activity, temperature, breezes aloft, precipitation intensity, pilot reports, notes to airmen, and others (Pooley, 2014). Even though a Flight Service briefing of weather remains the single most inclusive supplement of weather information for Etihad Flying, it can be challenging to captivate the entire information delivered in a cell phone briefing. Pictures are invaluable when it turns to showing sophisticated, vibrant information such as precipitation and cloud cover. For this purpose, you may find it accommodating to start the preflight preparation process by viewing weather results from a variety of providers (Pr att, 2011). The objective of this self-briefing course is to create a general perceptual picture of forecast and current weather conditions and determine places that need closer inquiry with the aid of and FSS briefer. Severe Weather and Detection Devices Flight within regions of forecast or known severe weather shall be avoided by the pilot to the maximum degree probable. When a flight is required is places of informed thunderstorms, turbulence, icing, and others, avoidance will be achieved through airborne radar, visual means, and when accessible, air traffic control assistance. Practicable weather radar should be mounted on the airplane if the operation is scheduled into basis of forecast or informed thunderstorm scenario in which evading cannot be achieved through visual method (Teets, 2010).En-Route and Arrival Procedure En route instrument flying rules (IFR) map reading is changing from the earth base navigational aids (NAVAID) route system to a complex computer and satellite- based system that can produce courses to construct the operational needs for nearly any flight. The FAA Global Navigation Systems (GNSS) offers satellite-based timing, position, and navigation services to allow performance-based functions for every phase of aeronautical, to incorporate en-route navigation (Eglise, 2013). Every Departmental co-pilot is making an IFR departure; approach or arrival at the airport (foreign or domestic) shall abide by the weather minimums and appropriate instrument published for that particular facility (Eglise, 2013). At airstrips where weather broadcasting services are a...

Capital Punishment Controversy - 1553 Words

Although it is argued that capital punishment is a strong deterrent to crimes and serves as a just punishment, nevertheless, capital punishment should be abolished because it is a violation of human rights, carries a risk of executing innocent people, is a burden on taxpayer’s money and is discriminant in application. Capital punishment has been argued to be a violation of human rights. The Universal Declaration of Human Rights that was adopted by the United Nations General Assembly in 1948 recognizes that every person has a right to life and further states â€Å"No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment† . Death penalty however, is a violation of both these fundamental human rights as it†¦show more content†¦In 2003 alone, 10 wrongfully convicted defendants were released from death row. These statistics depict an intolerable risk of killing the innocent in the name of justice. There have been several cases globally when a person was executed and his/her innocence was later proven. One such case was in Taiwan when a Taiwanese soldier was executed in 1997 for rape and murder of a five year old girl. Before his death, he had repeatedly claimed that he was wronged and that he did not rape and murder the girl. He was deprived of his life, and branded a rapist and a murderer. Fifteen years later, the authorities caught the real killer Xu Rong-zhou who admitted that he was responsible for the crime . However, the damage had been done. There was nothing that could be done to bring the innocent back to life. Historically, death penalty has also been misused intentionally leading to wrongful executions. For example, the former Prime Minister of Pakistan, Zulfiqar Ali Bhutto was hanged in April 1979 for charges of murder. This execution is very controversial since it was alleged that the then President of Pakistan, Zia-ul-Haq had used the death penalty and judicial system as a tool to get rid of his rival, Bhutto as Benzir Bhutto writes,† There were no eye-witnesses to the attack.......that the FSF guns, which the ‘confessing accused claimed to have used in the murder attempt did not match the empty cartridges found atShow MoreRelatedCapital Punishment and its Controversies 1434 Words   |  6 PagesCapi tal punishment uses death penalty as a form of punishment in many states and countries. It is a practice that has raised endless questions all over the world. Capital punishment or death penalty policy has changed in many countries overtime. Countries such as, New Australia, Zealand and 15 states in the US do not have capital punishment. One of the major concerns arising with capital punishment is because it causes ending of a human life. People and organizations of different backgrounds areRead MoreThe Controversy Of Capital Punishment1374 Words   |  6 PagesThe Controversy of Capital Punishment Capital punishment, or the death penalty, is a form of punishment that has been used as far back as the Colonial Era in America. Although it has been around for the entirety of American history, most of the scrutiny and controversy involving capital punishment arose in the 1972 Supreme Court Case of Furman v. Georgia, in which it was abolished, but quickly returned in 1977. It is evident that many citizens have ambivalent stances on capital punishment; someRead MoreEssay on The Controversy of Capital Punishment.2184 Words   |  9 PagesThe Controversy of Capital Punishment Since the earliest times, man has struggled with the concept of justice. The controversy of capital punishment has weighed on the minds of humans since the beginning. When we are wronged it is our natural instinct to demand compensation. This thirst for revenge can be seen in the earliest civilizations and societies. Ancient Hammurabi code states â€Å"An eye for an eye, a tooth for a tooth† (History of the World). For many people this little axiom seemsRead MoreCapital Punishment Is Not A Longstanding Controversy Essay1151 Words   |  5 PagesWhether capital punishment is fair or not a longstanding controversy. Currently the punishment has still been carried out in some countries, such as China and the United States. Numbers of capital punishment in China is in the first place, compared to other countries (Sterbenz, 2014). However, 98 countries have abolished capital punishment (Amnesty International facts and figures on the death penalty, 2007). Although most of co untries have no capital punishment to crimes, it is still argued whetherRead MoreCapital Punishment : The Nation S Controversy3247 Words   |  13 Pages CAPITAL PUNISHMENT: THE NATION’S CONTROVERSY Matthew Isaac Political Science 102 Dr. Percival May 10, 2015 A rarity exists in a single topic that can cause a degree of controversy so large that it attracts politicians, judges, community organizers, economists and even religious officials to discuss it. This issue is one that some support and others oppose; that is, the issue of capital punishment. Capital punishment is loosely defined as the execution of an offenderRead MoreThe Controversy Over Capital Punishment2295 Words   |  10 PagesThe controversy with capital punishment has been debated for hundreds of years. The Supreme Court is likely to sway its opinion often about whether it should be abolished or instituted throughout the United States. There have been many court cases and lawsuits regarding this issue that has suggested that legislation would be the most effective way to ending the discussion once and for all. In order to abolish the death penalty, the majority has to agree in support of abolition for any legislatureRead MoreCapital Punishment Has Always Been A Major Controversy1710 Words   |  7 PagesCapital punishment has always been a major controversy ever since the Supreme Court ruled it constitutional. Capital punishment, also known as the death penalty, became extremely popular as a use of â€Å"punishment† for ones illegal actions. The death penalty was first established during 1834 for crimes committed such as â€Å"idolatry, witchcraft, blasphemy, murder, manslaughter, poisoning, bestiality, sodomy, adultery, man stealing, and false witness in case rebellion† (Bohm). According to Bohm’s articleRead MoreThe Capital Punishment Debate Essay1396 Words   |  6 PagesCapital Punishment, also known as the death penalty is a legal sentence for a criminal to be put to death. The Punishment is rising to a controversial topic and has led to a lot of heated debates. As of 2014, over 150 countries have abolished the death penalty and 40 others have not used it in recent years, although it is still legal. The death Penalty is mostly used in extreme cases of crime like rape or murder. The convicted criminals are mostly put to death in inhuman ways such as lethal injectionsRead MoreShould It Be Abolished Or Not?1396 Words   |  6 PagesWilliam Furman guilty of all charges and is to be sentenced to capital punishment. However, what is capital punishment? The definition from dictionary.com states: The practice or legal sanction of allowing the imposition of the penalty of death for people convicted of committing certain crimes. There are five lawful me ans of sentencing which are electrocution, hanging, lethal injection, gas chamber, and firing squad. Capital punishment is a delicate topic amongst the people but there are certain aspectsRead More Capital Punishment Essay - True Justice Through Application of the Death Penalty1069 Words   |  5 PagesApplication of the Death Penalty      Ã‚  Ã‚   The death penalty, as administered by states based on their individual laws, is considered capital punishment, the purpose of which is to penalize criminals convicted of murder or other heinous crimes (Fabian).   The death penalty issue has been the focus of much controversy in recent years, even though capital punishment has been a part of our countrys history since the beginning.   Crimes in colonial times, such as murder and theft of livestock were dealt

Essay on The American Christian Holocausts - 5005 Words

The American Christian Holocausts As a high school student I was always annoyed by students who would ask: Why do we have to learn this stuff [history] anyway? We learn history so we dont repeat our mistakes. This is the common answer that my teachers, my father, and just about any other adult would give. This answer made perfect sense to me then, and I easily accepted it. In high school, students learn about the Nazi-Holocaust, and rightfully so. Information abounds regarding this topic. However, my teachers never taught me that our country has a Holocaust of its own (actually there are two; one killing 40 to 60,000,000 Africans, and one killing 100,000,000 Native Red Peoples). Hitler himself often expressed his admiration for†¦show more content†¦Parts of Browns book remained in my mind, in particular, the Sand Creek Massacre (in present day Colorado). I went to the library to read more about the subject. I was in a hurry, so I quickly grabbed an encyclopedia. I first looked under Sand Creek Massacre, shocked at finding nothing, I searched under Battle of Sand Creek and found nothing. The Sand Creek Massacre did not appear anywhere! I was, to use Mcphersons word, appalled. I kept looking, surely the World Book would have it. To my surprise, the book ignored one of the bloodiest and most grotesque massacres in American history. Well, I thought, surely the Encyclopedia Americana will have it. Blank. All encyclopedias had somehow forgotten those Native American men, women, and children. Why was it that the Boston Massacre, wherein 5 men lost their lives, was in every book? The 133 human beings who lost their lives in the most grotesque and mutilated way on Sand Creek were nowhere to be found. If a massacre like Sand Creek did not appear in encyclopedias and textbooks how were young people (and adults) to be taught of the Camp Grant Massacre, the Piegan Massacre, the Massacres of California, the Marias Massacre, the Wa*censored*a Massacre, Guatemala in the 70s and 80s,Show MoreRelatedThe American Holocaust : The Conquest Of The New World1183 Words   |  5 PagesThe American Holocaust – The Conquest of the New World The book I chose from the reading list of nonfiction books was The American Holocaust – The Conquest of the New World by David E. Stannard. In this nonfiction book, David E. Stannard describes in horrifying detail, the destruction and holocaust of nearly all early American societies that resulted from the European contact with the Western Hemisphere. I did not choose this book for any specific reason, but I thought it would be an interestingRead MoreEssay about Supporting Israel: Recent Rise of Anti-Semitism1198 Words   |  5 Pagesargues the importance of supporting Israel and the validity of Christian Zionism. It is rather important for Christians to become well informed of anti-Semitic claims, whys supporting Israel is necessary, and what Christian Zionism is, because Israel is at a crucial point in time and needs all the support it can get. Beginning with and introduction to anti-Semitism, followed by the whys of supporting Israel, and ending with Christian Zionism the reader will be more informed of this subject in orderRead MoreSwastika: Misunderstood Beauty790 Words   |  3 Pagesswastika originates from India. Artifacts outside of the region have also used this symbol with their own slight variations. Greek coins, Scandinavian artifacts, pre-Christian Celtic artifacts, the catacombs of the early Christians in Rome, and several buildings during the Byzantine period used the swastika as decorative images. Native Americans have also used the swastika to represent good luck. However, it was not always regarded with the same kind of respect after the rise of the Nazi party during WWIIRead MoreThe Holocaust And The Bosnian Genocide1310 Words   |  6 Pagespast hundred years, there have been several attempted genocides around the world. Two of the most well-known genocides are the Holocaust (the Nazi’s attempt to destroy the Jewish people) and the Bosnian genocide (the Serbians attempt to destroy the Bosnian population). This paper analy zes a political cartoon relating to genocides, describes the events that led to the Holocaust and the Bosnian genocide, describes several similarities and differences between them and explains why genocides continue regardlessRead MoreEssay on The Holocaust503 Words   |  3 PagesThe Holocaust Nearly six million Jews were killed and murdered in what was called the holocaust. In the years between 1933 and 1945, the Jews of Europe were marked for death. Inanition anti-Semitism was given legal sanction. It was directed by Adolf Hitler and managed by Heinne Himmler, Reinhard Heydrich, and Adolf Eichmann. There were many other great crimes and murders, such as the killing of the Armenians by the Turks , but the holocaust stood out as the only systematic and organizedRead MoreSocial Justice Counseling Aims For Equal Access And Opportunity833 Words   |  4 Pagesseeking a life free of prejudice due to their religion, gender, socioeconomic status or anything else that could hinder one from having equal access to the same liberties as others. Due to an array of cultures such as Arab Americans, Jewish American, Native Americans and African Americans, counselors must become culturally competent in all four disciplines and any other culture that their client(s) associates with. All four of the cultures mentioned have some similarities and differences that one mustRead MoreSpielberg s List And Roman Pola Ä ¹Ã‚Æ' Ski s The Pianist1366 Words   |  6 Pagesmovies, plays an important role in shaping the public’s opinions and understanding of the world. The Holocaust for example is a subject that has received a lot of media attention, including three Academy award-winning films in the past two decades. Most people know little about the Holocaust and these films serve as the primary sources of their knowledge, therefore, how they perceive the Holocaust is directly related to the way it is portrayed in these popular movies. Steven Spielberg’s Schindler’sRead MoreThe Tragedy Of The Holocaust1599 Words   |  7 Pagesassigned Adolf Hitler as their chancellor. Once Hitler had finally reached power he set out to complete one goal, create a Greater Germany free from the Jews (â€Å"The reasons for the Holocaust,† 2009). This tragedy is know n today as, â€Å"The Holocaust,† that explains the terrors of our histories past. The face of the Holocaust, master of death, and leader of Germany; Adolf Hitler the most deceitful, powerful, well spoken, and intelligent person that acted as the key to this mass murder. According to a researchRead MoreExamples Of Anti-Semitism In The Merchant Of Venice1091 Words   |  5 Pagesis filled with Jewish slurs, anti-Semitic remarks, and no justice for the main Jewish character is, in theory, seen as despicable. After the Holocaust, all Jewish slurs and stereotypes, like calling someone â€Å"dog Jew† or thinking Jews only care about money, have been exiled from moral society. This even applies to pieces of art that were produced pre-Holocaust. However, William Shakespeare’s The Merchant of Venice is not only read, but taught in schools across the nation. The Merchant of Venice providesRead MoreAnne Frank And The Holocaust1016 Words   |  5 Pagesbright future, but it was taken away from her by the Nazi’s and Holocaust. Before the Holocaust, Anne Frank was just the typical young girl. During the Holocaust, she had to adapt to a dangerous situation. Then, after her death, she has left a legacy that has impacted the hearts of many. Through Anne Frank’s early childhood years, the years during the Holocaust, and the years after her death she has left a legacy that has influenced American culture. Annelies Marie Frank was born on June 12, 1929, in

Taxation Law Work Related Expenses

Question: Describe about the Taxation Law for Work Related Expenses. Answer: 1:- For the Australian residents the incomes, earned from all direct and indirect sources within or outside Australia, are considered as the assessable income. Any income generated from the sale of property by any Australian resident, therefore, should be treated as an assessable income of the individual resident (Woellner et al. 2012). However, under ITAA 1997, the assessable incomes are classified into two sections ordinary income and statutory income. Ordinary incomes can be described as the incomes, generated from ordinary or general course of action. Under section 6-5, the main ordinary incomes are stated below: Income from personal exertion, such as, salary, wages, leave encashment, monthly pension etc. Income from property, such as, rent from properties, interest on deposits, dividend from investments etc. Income from business, such as, net profit from business, sale of trading stocks, net income from farming etc (www.dlsweb.rmit.edu.au, 2016) On the other hand, statutory incomes can be defined as the income, which has not been generated from ordinary courses. These incomes, as described in the section 10-5, are described below: Capital gains from sale of capital assets Lump Sum payment, received on termination of employment Bonus on Insurance Bad Debts recovered Profit from Barter transaction Royalties Imputation credit (www.dlsweb.rmit.edu.au, 2016) The statutory incomes are calculated separately to determine the taxable amount from such incomes. Peta, had purchased the house with tennis court for living in the house permanently and to earn profits by selling the tennis courts in units. However, she sold the whole tennis court later to a tennis club. The income from the sale of the tennis court is surely an assessable income. Peta had purchased the property with an intention to sale the tennis courts for earning profits. Therefore, the net income, after deducting the expenses, incurred for resurfacing and fencing, can be considered as business income. In that case, it can be included as an ordinary income of Peta under section 6-5 (Austlii.edu.au, 2016). However, it should be noted that though Peta had an intention to sale the property, she did not involve in any kind of real estate business. Apart from that, she had intended to sell the property in small units, but had to sell it in a whole. Hence, the income from the sale of the property should be considered as statutory income under section 10-5, instead of, ordinary income. Moreover, if Peta would show the income as ordinary income, then she has to pay tax on the net income, by deducting the cost price and other expenses, incurred for the assets. However, if it is shown as capital gain, she can claim for 50% exemption on the net income (Ato.gov.au, 2016). Therefore, from both the point of views, the receipt of $600000 should not be considered as an ordinary income under section 6-5. 2:- It is necessary to made the following assumptions for ascertaining the Fringe Benefit Tax liability of ABC Pty. Ltd. on the expenses, made for Alan:- Salaries and wages, paid to the employees, are not considered for FBT and therefore, the salary of Alan will not be included for FBT liability computation (Bender et al. 2013). Mobile phone bill, paid by the employer, on behalf of employee, is treated as expense fringe tax benefit. ABC Pty. Ltd. has not reimbursed the mobile phone expenses to Alan, but paid to the third party directly. Though, the monthly mobile expenses is lower than $300, but annually the expense ins amounted to $2640. Therefore, ABC Pty. Ltd. can consider the mobile expense for fringe tax benefit (Ato.gov.au.2016). The school fees of the Alan children, paid by ABC Pty. Ltd, are also an expense fringe benefit, where the employer is paying the employees private expenses directly on behalf of the employee. Hence, it should be included for fringe benefit taxation purpose (Delany 2012). The mobile phone is provided to Alan for work purpose. From employers end, it should be treated as work related expenses. Hence, the cost of mobile phone should be included for calculating the total amount for GST Inclusive items and later the gross-up amount of the hand set should be excluded from the FBT taxable amount (James et al. 2013). Any expenses, paid for the entertainment of the employees by the employer, are referred as entertainment fringe benefits. It should be noted that the employer can claim for deduction on such expenses under otherwise deductible rule (Rimmer et al. 2014). However, the claim can be made only for the amount, spent for the employees only. Any expenses, spend for the entertainment of the family members or associates of the employees, cannot be included in the entertainment fringe benefits. As the exact per head amount, spent for the entertainment purpose of the employees only, is not possible for ABC Pty. Ltd., the total amount is included in the fringe benefit tax calculation (Jones 2015). It is necessary to compute the total amount of GST inclusive benefits and GST free benefits separately. Then the total values are summarized by multiplying the individual Gross up rates, applicable to the different types of benefits (Ramli et al. 2015). The net taxable value, after deducting the exempted amount from the total gross up value, is then charged with FBT rate, i.e., 49% to calculate the total Fringe Benefit Tax Liability of the employer (Soled and Thomas 2015). On the basis of the assumptions and rules, the fringe benefit tax liability of ABC Pty. Ltd. is calculated in the following table:- In the Books of ABC Ltd. Calculation of Fringe Benefit Tax Liability as on 31.03.2015 GST Inclusive GST Free Particulars Amount Amount $ $ Payment of Phone Bill 2640 Payment of School fees of Employee's Children 20000 Dinner at Restaurant 330 Providing Mobile Phone 2000 Total of GST Inclusive/Free Benefits 4970 20000 A B Gross-up Rate 2.1463 1.9608 C D Gross-up Value 10667.11 39216 E = A x C F=B X D Total Taxable Fringe Benefit 49883.11 G = E + F Less : Exemption for Mobile Phone at gross-up value 4292.60 ($2000 x 2.1463) H Net Taxable Fringe Benefit 45590.51 I = G - H Fringe Benefit Tax Rate 49% J Fringe Benefit Tax Liability 22339.35 K = I x J 2.b:- If ABC Pty. Ltd. includes only 5 employees for dinner and the total cost of dinner remains same, in that case, the per head dinner cost will become higher. It would result in higher FBT liability (Kaplan and Price 2014). The calculations are given below: In the Books of ABC Ltd. Calculation of Alternative Fringe Benefit Tax Liability as on 31.03.2015 GST Inclusive GST Free Particulars Amount Amount $ $ Payment of Phone Bill 2640 Payment of School fees of Employee's Children 20000 Dinner at Restaurant 1320 Providing Mobile Phone 2000 Total of GST Inclusive/Free Benefits 5960 20000 A B Gross-up Rate 2.1463 1.9608 C D Gross-up Value 12791.95 39216 E = A x C F=B X D Total Taxable Fringe Benefit 52007.95 G = E + F Less : Exemption for Mobile Phone at gross-up value 4292.60 ($2000 x 2.1463) H Net Taxable Fringe Benefit 47715.35 I = G - H Fringe Benefit Tax Rate 49% J Alternative Fringe Benefit Tax Liability 23380.52 K = I x J However, if the per head cost of dinner remains same and the total cost of dinner would reduce accordingly, then the total FBT liability will remain unchanged as per the calculations, shown in answer 2.a (Shields and North-Samardzic 2015). 2.c:- The entertainment fringe tax benefit is only applicable for the benefits, provided for the employees. If ABC Pty. Ltd. includes its clients, then also the fringe tax benefit would include only the cost, incurred for employees. The company cannot get any deduction for the entertainment of the clients (Martocchio 2013). References:- Ato.gov.au. (2016).Fringe benefits tax (FBT) | Australian Taxation Office. [online] Available at: https://www.ato.gov.au/General/Fringe-benefits-tax-(FBT)/ [Accessed 27 May 2016]. Delany, T.P., 2012. Fringe benefits tax James, S., Wallschutzky, I. and Alley, C., 2013. The Henry Report and the taxation of work related expenses: Principles versus practice Jones, S., 2015. 'Cost-to-company'explained: tax planning.Tax Breaks Newsletter, (349), pp.6-7 Kaplan, R.L. and Price, D.J., 2014. Change and Continuity in Fringe Benefit Taxation: Seeking Sense and Sensibility.NYL Sch. L. Rev.,59, p.281 Martocchio, J., 2013.Employee benefits. McGraw-Hill Higher Education Ramli, R., Palil, M.R., Hassan, N.S.A. and Mustapha, A.F., 2015. Compliance costs of goods and services tax (GST) among small and medium enterprises.Jurnal Pengurusan,45, pp.1-15 Rimmer, X., Smith, J. and Wende, S., 2014. The incidence of company tax in Australia Soled, J.A. and Thomas, K.D., 2015. Revisiting the Taxation of Fringe Benefits.Washington Law Review, Forthcoming Woellner, R., Barkoczy, S., Murphy, S., Evans, C. and Pinto, D., 2012.Australian taxation law. CCH Australia www.dlsweb.rmit.edu.au. (2016). www.dlsweb.rmit.edu.au/toolbox/finance/fnbacc02a/preparetax/keyprinciple/ordinaryi.htm. [online] Available at: https://www.dlsweb.rmit.edu.au/toolbox/finance/fnbacc02a/preparetax/keyprinciple/ordinaryi.htm [Accessed 13 Sep. 2016]. www.dlsweb.rmit.edu.au. (2016). www.dlsweb.rmit.edu.au/toolbox/finance/fnbacc02a/preparetax/keyprinciple/statutoryi2.htm. [online] Available at: https://www.dlsweb.rmit.edu.au/toolbox/finance/fnbacc02a/preparetax/keyprinciple/statutoryi2.htm [Accessed 13 Sep. 2016]. Ato.gov.au. (2016). What to include in your assessable income | Australian Taxation Office. [online] Available at: https://www.ato.gov.au/Business/Income-and-deductions-for-business/Working-out-your-assessable-income/What-to-include-in-your-assessable-income/ [Accessed 13 Sep. 2016]. Bender, M., Contacos-Sawyer, J. and Thomas, B., 2013, July. Benefits Strategies for Attracting and Retaining Employees. InCompetition Forum(Vol. 11, No. 2, p. 165). American Society for Competitiveness Shields, J. and North-Samardzic, A., 2015. 10 Employee benefits.Managing Employee Performance Reward: Concepts, Practices, Strategies, p.218 Austlii.edu.au. (2016). INCOME TAX ASSESSMENT ACT 1997 - SECT 6.5Income according to ordinary concepts (ordinary income). [online] Available at: https://www.austlii.edu.au/au/legis/cth/consol_act/itaa1997240/s6.5.html [Accessed 13 Sep. 2016].

Who ever loved that loved not at first sight free essay sample

This poem starts with the description of the young lovers: the incomparably lovely virgin, Hero, dedicated to the service of the love goddess – she is Venus nun(line 45) and the handsome Leander. Both young people are described as having more than human beauty. Hero is so beautiful that the love-god Cupid mistakes her for that most beautiful of the goddesses, his mother Venus. Leanders description is even more extreme, and perhaps a bit bizarre. He is described as so attractive that even men find him beautiful. Marlowe shows his extreme handsomeness as feminine. Some swore he was a maid in mans attire (line 85). Later, Marlowe describes him, however, in great detail, with a muscular, masculine figure. This feminization of Leanders beauty was a Renaissance poetic convention. There was a limited vocabulary, at this time, for male attractiveness, and a feminine description was sometimes deemed necessary even when the subject was, perhaps, not as androgynous as it might seem. We will write a custom essay sample on Who ever loved that loved not at first sight ? or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page However, in this case the homoerotic undertones of Leanders beauty are a foreshadowing of a future event in the poem. The two lovers live on either side of the Hellespont (the strait which joins the Black Sea and the Aegean.) Hero lives in Sestos, where she is a virgin priestess of the goddess. Her duties are to sacrifice to Venus, and to remain sexually pure. She has aroused, it appears, a dangerous desire for her beauty in her many suitors. Her kirtle blue, whereon was many a stain/Made with the blood of wretched lovers slain (lines 15-16). We see her first, in a sacred grove, sacrificing turtle doves to the goddess. The long-haired Leander lives across the water in Abydos. During the yearly festival to Adonis (one of Venus lovers) in Sestos, Leander and Hero first meet. After Leander has seen and fallen in love with Hero, Hero is subsequently shot with an arrow of love by the god Cupid. The two meet and speak of their prodigious attraction, but Hero has made a vow to the goddess Venus, no less, to keep her chastity. Though Leander uses clever-sounding rhetoric to assure Hero that remaining a virgin is no way to serve her goddess (or herself), Vessels of brass, oft handled, brightly shine (line 232), Hero demurs and returns to her tower. Leander is afraid of being missed, and goes home across the water to Abydos. There, his father can tell by his face that he has fallen in love. Leander flees and goes to stand upon the rocks, gazing across the water at Heros tower. He cannot bear to be parted from Hero any longer, so he takes off his clothes and dives into the water to swim back to her. While Leander is swimming, the sea-god Neptune sees him and mistakes him for another famously handsome youth – the king of the gods Zeuss cupbearer Ganymede. Neptune has long coveted this young man, and takes this as an opportunity to steal him from his brother-god. He captures Leander and takes him down to his palace in the deep. Descriptions of sea-nymphs and mermaids, and the wealth under the oceans, ensue. Once Neptune realizes that Leander is almost drowned, and therefore cannot be Ganymede (who was made immortal by Zeus), the god brings Leander back to the surface. Breathing air again, Leander begins to swim toward Sestos, but Neptune follows underneath him, kissing and caressing him at every stroke. Leander is frightened by this and cries out O let me visit Hero ere I die! (line 661) Neptune will not relent, and continues caressing him and talking of love. Once again Leanders sexual ambiguity is brought up – he tells Neptune he is no woman. Neptune at last sees that Leander will not give into him, and sadly lets him go. Leander reaches Heros tower, and knocks on her door. Hero is surprised to find Leander standing there, dripping wet and  naked. She brings him inside, and since he is cold she lets him lie next to her in bed. They engage in amorous embraces, but Hero, mindful of the value of her sacred chastity, attempts to hold Leander off for a time. Eventually they are overcome by their feelings, and, though they are both a little unsure of how to proceed, they consummate their love. The poem ends as morning dawns. Analysis Hero and Leander is a poem – an epyllion, that is, a short epic poem – which Marlowe composed based on work by the sixth-century poet Musaeus. The story, of course, is much older, based on various versions of a Greek myth. The narrative itself is one of iconic separated lovers, a tale full of Roman mythological references which would have been clear and meaningful to most of Marlowes readers. This poem was written in the last year of Marlowes life, 1593. It was a plague year, and the London theatres all were closed. Therefore Marlowe could not write for the stage, and poetry was his creative outlet. For a poem written in such a dark time, and about such a tragic subject (although the lovers end is actually not shown to us by Marlowe), Marlowes tone is surprisingly light, and the lines are full of a love of humanity and a wonder at the beauty of the world. Particularly the descriptions of Leander and Hero, and the vivid picture of the underwater kingdom of Neptune, are vivid and compelling. The poem has been termed mock-epic because it is so full of humor. Hopkins calls it one of the most deliciously comic poems of Elizabethan literature (literaryencyclopedia.com). Marlowes poem is thought to be unfinished, because the story of Musaeus goes on to tell of the lovers tragic demise. It is possible that Marlowe meant to continue the story (for he introduces characters who are not mentioned again – such as the dwarfish beldame (line 351) and Leanders father), but, in the absence of evidence to the contrary, it is just as likely that Marlowe meant never to continue this poem any further. Since the poems tone is so light and full of humor, it is hard to imagine the subject matter changing so drastically from the joy of young lovers to their deaths. However, Marlowe had already proved that he was capable of writing compellingly about the full range of emotions, so he could have intended to finish the story. The poem as it stands, however, can be judged as a complete work of art. George Chapman divided Marlowes lines,  later, in to two sestiads, and composed an additional four to finish the story. Those lines, however, are Chapmans, and differ greatly from Marlowes original work. They are not considered here. The insistence of Leanders feminine beauty, not once but twice in this poem, is seen by some critics as evidence of Marlowes homosexuality. It may well be, but this convention of the allure young men have for other men is evident in the original story, not invented Marlowe. The classical world was much more accustomed to references to homosexuality than the Elizabethan Christian world of Marlowe. He delights in it, however, lingering lovingly on descriptions of Leander (a full forty lines on Leanders description alone, compared with forty-five on Hero, though her description is as much about her dress as her person) and his attractiveness. The importance placed on Leanders attractiveness, however, is more than is usual in poems of this type. It is easy to see how Marlowe may have been putting some of his own feelings into the poem. On the negative side, the courtship of Leander by Neptune is both explicit and disturbing, because Leander is frightened, does not desire the attention, and doesnt exactly know what is happening. He is nearly drowned, and cannot imagine what this god would want from him. Leander shows his sexual ignorance by insisting that he is not a woman. This is not the only instance of his extreme naivetà ©; later, Leander he does not understand what it to be done to consummate his relationship with Hero. This extreme sexual innocence is common in classical poems (such as Daphnis and Chloe) and was considered by the Romans especially to be an interesting subject for a love-poem. This is not a common theme in Elizabethan poetry, so Marlowe took this from Musaeus. The joyous meeting and reunion of the lovers is love-poetry of a particularly effective kind. The emphasis is on the looks in the eyes of the lovers, the words they speak, the embraces they attempt. The realistic touches (such as Leander attempting, by sophistry, to convince Hero to sleep with him) are charming, and remind the reader that these two are not simply iconic lovers from the distant past. Hero and Leander are compelling because their reactions (even the less-than-truthful words of Hero, as she attempts to hold off Leander) are innocent and based on universal human emotions. Marlowe took a story from Greek myths intact, but made the characters believable to an Elizabethan audience. Who ever loved that loved not at first sight free essay sample Who ever loved that loved not at first sight? This poem starts with the description of the young lovers: the incomparably lovely virgin, Hero, dedicated to the service of the love goddess – she is Venus nun(line 45) and the handsome Leander. Both young people are described as having more than human beauty. Hero is so beautiful that the love-god Cupid mistakes her for that most beautiful of the goddesses, his mother Venus. Leanders description is even more extreme, and perhaps a bit bizarre. He is described as so attractive that even men find him beautiful. Marlowe shows his extreme handsomeness as feminine. Some swore he was a maid in mans attire (line 85). Later, Marlowe describes him, however, in great detail, with a muscular, masculine figure. This feminization of Leanders beauty was a Renaissance poetic convention. There was a limited vocabulary, at this time, for male attractiveness, and a feminine description was sometimes deemed necessary even when the subject was, per haps, not as androgynous as it might seem. We will write a custom essay sample on Who ever loved that loved not at first sight ? or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page However, in this case the homoerotic undertones of Leanders beauty are a foreshadowing of a future event in the poem. The two lovers live on either side of the Hellespont (the strait which joins the Black Sea and the Aegean.) Hero lives in Sestos, where she is a virgin priestess of the goddess. Her duties are to sacrifice to Venus, and to remain sexually pure. She has aroused, it appears, a dangerous desire for her beauty in her many suitors. Her kirtle blue, whereon was many a stain/Made with the blood of wretched lovers slain (lines 15-16). We see her first, in a sacred grove, sacrificing turtle doves to the goddess. The long-haired Leander lives across the water in Abydos. During the yearly festival to Adonis (one of Venus lovers) in Sestos, Leander and Hero first meet. Marlowe described it with a memorable ten lines, which is often extracted from the longer poem as its own, stand-alone love-poem. Note the familiar sentiment about love at first sight; Shakespeare used something similar in Act 3 Scene V of As You Like It: It lies not win our power to love or hate, For will in us is overruled by fate. When two are stripped, long ere the course begin We wish that one should lose, the other win. And one especially do we affect Of two gold ingots like in each respect. The reason no man knows; let it suffice What we behold is censured by our eyes. Where both deliberate, the love is slight: Whoever loved that loved not at first sight? After Leander has seen and fallen in love with Hero, Hero is subsequently shot with an arrow of love by the god Cupid. The two meet and speak of their prodigious attraction, but Hero has made a vow to the goddess Venus, no less, to keep her chastity. Though Leander uses clever-sounding rhetoric to assure Hero that remaining a virgin is no way to serve her goddess (or herself), Vessels of brass, oft handled, brightly shine (line 232), Hero demurs and returns to her tower. Leander is afraid of being missed, and goes home across the water to Abydos. There, his father can tell by his face that he has fallen in love. Leander flees and goes to stand upon the rocks, gazing across the water at Heros tower. He cannot bear to be parted from Hero any longer, so he takes off his clothes and dives into the water to swim back to her. While Leander is swimming, the sea-god Neptune sees him and mistakes him for another famously handsome youth – the king of the gods Zeuss cupbearer Ganymede. Neptune has long coveted this young man, and takes this as an opportunity to steal him from his brother-god. He captures Leander and takes him down to his palace in the deep. Descriptions of sea-nymphs and mermaids, and the wealth under the oceans, ensue. Once Neptune realizes that Leander is almost drowned, and therefore cannot be Ganymede (who was made immortal by Zeus), the god brings Leander back to the surface. Breathing air again, Leander begins to swim toward Sestos , but Neptune follows underneath him, kissing and caressing him at every stroke. Leander is frightened by this and cries out O let me visit Hero ere I die! (line 661) Neptune will not relent, and continues caressing him and talking of love. Once again Leanders sexual ambiguity is brought up – he tells Neptune he is no woman. Neptune at last sees that Leander will not give into him, and sadly lets him go. Leander reaches Heros tower, and knocks on her door. Hero is surprised to find Leander standing there, dripping wet and naked. She brings him inside, and since he is cold she lets him lie next to her in bed. They engage in amorous embraces, but Hero, mindful of the value of her sacred chastity, attempts to hold Leander off for a time. Eventually they are overcome by their feelings, and, though they are both a little unsure of how to proceed, they consummate their love. The poem ends as morning dawns. Analysis Hero and Leander is a poem – an epyllion, that is, a short epic poem – which Marlowe composed based on work by the sixth-century poet Musaeus. The story, of course, is much older, based on various versions of a Greek myth. The narrative itself is one of iconic separated lovers, a tale full of Roman mythological references which would have been clear and meaningful to most of Marlowes readers. This poem was written in the last year of Marlowes life, 1593. It was a plague year, and the London theatres all were closed. Therefore Marlowe could not write for the stage, and poetry was his creative outlet. For a poem written in such a dark time, and about such a tragic subject (although the lovers end is actually not shown to us by Marlowe), Marlowes tone is surprisingly light, and the lines are full of a love of humanity and a wonder at the beauty of the world. Particularly the descriptions of Leander and Hero, and the vivid picture of the underwater kingdom of Neptune, are vivid and compelling. The poem has been termed mock-epic because it is so full of humor. Hopkins calls it one of the most deliciously comic poems of Elizabethan literature (literaryencyclopedia.com). Marlowes poem is thought to be unfinished, because the story of Musaeus goes on to tell of the lovers tragic demise. It is possible that Marlowe meant to continue the story (for he introduces characters who are not mentioned again – such as the dwarfish beldame (line 351) and Leanders father), but, in the absence of evidence to the contrary, it is just as likely that Marlowe meant never to continue this poem any further. Since the poems tone is so light and full of humor, it is hard to imagine the subject matter changing so drastically from the joy of young lovers to their deaths. However, Marlowe had already proved that he was capable of writing compellingly about the full range of emotions, so he could have intended to finish the story. The poem as it stands, however, can be judged as a complete work of art. George Chapman divided Marlowes lines, later, in to two sestiads, and composed an additional four to finish the story. Those lines, however, are Chapmans, and differ greatly from Marlowes original work. They are not considered here. The insistence of Leanders feminine beauty, not once but twice in this poem, is seen by some critics as evidence of Marlowes homosexuality. It may well be, but this convention of the allure young men have for other men is evident in the original story, not invented Marlowe. The classical world was much more accustomed to references to homosexuality than the Elizabethan Christian world of Marlowe. He delights in it, however, lingering lovingly on descriptions of Leander (a full forty lines on Leanders description alone, compared with forty-five on Hero, though her description is as much about her dress as her person) and his attractiveness. The importance placed on Leanders attractiveness, however, is more than is usual in poems of this type. It is easy to see how Marlowe may have been putting some of his own feelings into the poem. On the negative side, the courtship of Leander by Neptune is both explicit and disturbing, because Leander is frightened, does not desire the attention, and doesnt exactly know what is happening. He is nearly drowned, and cannot imagine what this god would want from him. Leander shows his sexual ignorance by insisting that he is not a woman. This is not the only instance of his extreme naivetà ©; later, Leander he does not understand what it to be done to consummate his relationship with Hero. This extreme sexual innocence is common in classical poems (such as Daphnis and Chloe) and was considered by the Romans especially to be an interesting subject for a love-poem. This is not a common theme in Elizabethan poetry, so Marlowe took this from Musaeus. The joyous meeting and reunion of the lovers is love-poetry of a particularly effective kind. The emphasis is on the looks in the eyes of the lovers, the words they speak, the embraces they attempt. The realistic touches (such as Leander attempting, by sophistry, to convince Hero to sleep with him) are charming, and remind the reader that these two are not simply iconic lovers from the distant past. Hero and Leander are compelling because their reactions (even the less-than-truthful words of Hero, as she attempts to hold off Leander) are innocent and based on universal human emotions. Marlowe took a story from Greek myths intact, but made the characters believable to an Elizabethan audience.

President Harding essays

President Harding essays The two former presidents Warren G. Harding and Calvin Coolige were alike in some ways and different in others. President Harding was a news paper owner from Ohio. He was chosen as the Rep. candidate after serving as an Ohio senator. Calvin Coolige was the Vice-president at the time of Warren Harding's death. Coolige fished the rest of Harding's term and then was re-elected. President Coolige followed Harding's policies when finishing his term, but after re-election he began to make some of his own. Harding focused on trying to settle the nation back into peace. He tried to ensure this peace by making treaties and disarmament acts. Harding also tried to lower taxes, take care of war veterans, protect farmers, and collect wartime debts owed to the U.S. . However Harding was not prepared to face the huge problems of the presidency. He made the mistake of appointing some of his Ohio friends to high ranking positions. The men he appointed were involved in many scandals and money stealing. Calvin Coolige like Harding was an admirer of American business. They both believed that business should mainly be left alone without government interference. Coolige especially believed business would be less profitable with more regulation. He also believed, unlike Harding, that nothing could be done to help the U.S. farmers. Coolige vetoed many bills designed to help farmers, like the McNary-Haugen bill, by saying "Farmers have never made much money and I don't believe we can do much about it" . These two presidents were also very different when it came to their personalities. Harding was laid back and likable, always playing cards with his friends and smoking cigars. Coolige, on the other hand, was very quite plain and thrifty. He said very little, earning him the nickname "Silent Cal." These two presidents were more different than alike. They shared only a few views and had very differ...

Poverty in the USA Research Paper Example | Topics and Well Written Essays - 750 words - 1

Poverty in the USA - Research Paper Example For a person to get a satisfying job, he/she needs to have the quality education (Kotler, 12). Most students leave school due to diverse reasons such as early pregnancies or drugs; hence, cannot find a rewarding job. Monetary instability causes low quality or no education at all. Many youths desire to advance their education and acquire rewarding jobs. Unfortunately, their parents and guardians are unable to pay their fees; thus they have to abandon school to secure jobs and help their parents pay debts. Â  Therefore, they create a cycle that never ends, that is from uneducated parent to an uneducated child. American citizens’ faces poverty since they can not grant the manpower needed to ensure a boost in the country’s economy. Majority of the developing states globally lives in destitute scarcity. The wealthy states such as America are a source of refuge to the growing states. They are perceived as ‘lands of opportunities’. America is one such country, of ten referred to as the world’s superpower nation because of her stable economic. This makes it a niche for citizens of developing countries to scramble for employment possibility from its citizens and illegal immigrants. Since the immigrants can settle for any amount of money they are mostly offered jobs, unlike the Americans. The immigrants can work for the extra time, and do multiple jobs. For this reason, they further deny employment opportunities to the citizens who meanwhile, are fighting with the youths for menial jobs.

Preliminary Trial Balance of Wilma Wildcats Company Assignment - 1

Preliminary Trial Balance of Wilma Wildcats Company - Assignment Example The annual interest rate is 8%. 2. The Equipment was purchased prior to 2010. The company uses the straight-line method, assumed a $2,000 salvage value and an estimated useful life of 15 years. Record depreciation expense for 2010. 3. The company issued a $175,000 bond in a prior year at face value. The bond has a contract rate of 9% and pays interest annually on January 1st. Record the adjusting entry for the accrued interest expense on December 31st. 4. The company uses the allowance method to estimate its uncollectible accounts. The new Chief Financial Officer (CFO) decided to use the percent of receivables method and estimated that 10% of Accounts Receivables at December 31, 2010, will be uncollectible. Record the adjusting entry for bad debt expense for 2010. 6. Employees were last paid on December 24, 2010. Several employees worked through December 31st and wages due but not yet paid were $4,200. An adjusting entry needs to be recorded to reflect this liability. Use the space below for T-accounts (REQUIRED FOR GRADING). For each account in the journal entries, you will need to adjust the balance from the preliminary trial balance with the debit or credit from the journal entry. (only need to do T-accounts for those that change) Part 2: Using the trial balance below, complete the income statement and prepare the Statement of Retained Earnings and Classified Balance Sheet on the pages which follow.  

Investment Strategies Order Number Essay Example for Free

Investment Strategies Order Number Essay There are many methods an investor can use to determine if a stock is a good buy or not. Three indicators often used to assess the risk of a security are beta, alpha and the Sharpe ratio. One of the most popular measures of risk associated with a security is its beta. Beta is a measure of a stock’s volatility in relation to the market as a whole. The market is given a beta of 1. 0 and individual stocks are ranked according to how much they deviate from the market’s beta. Stocks with a beta of less than 1. 0 are considered less volatile than the market and, therefore, pose less risk. Stocks that have betas higher than 1. 0 are considered more volatile than the market and, therefore, pose more risk. All things being equal, an investor would expect to see higher returns on a stock with a beta higher than the market than one with a beta lower than the market. (1) Beta is also a key component for the capital asset pricing model (CAPM). The original CAPM defined risk in terms of volatility, as measured by a stock’s beta coefficient. The formula is: Kc = Rf + beta Km – Rf) where Kc is the risk-adjusted discount rate (also known as the cost of capital) Rf is the rate of a â€Å"risk free† investment, i. e. ten-year treasury bill Km is the return rate of a market benchmark, such as the SP 500 Kc is the expected rate of return you would require before you would be interested in a particular stock at a particular price. The CAPM expresses the amount of risk a particular stock has and gives an investor an idea of the expected returns he should expect given a certain level of risk. The more risky a stock is the higher the level of returns an investor would expect for that particular stock. (2) A stock’s alpha is a mathematical estimate of the amount of return expected from a stock’s inherent values, such as the rate of growth of in earnings per share, management strengths or other factors, as opposed to general market conditions. Stocks with an alpha greater than 1. 0 can be expected to outperform the market regardless of what happens to the market as a whole. (3) The Sharpe ratio helps investors determine the best possible proportion of securities to use in a portfolio that can also include cash. The formula for the Sharpe ratio is: S(x) = (Rx – Rf) / StdDev(x) where x is some investment Rx is the average annual rate of return of x Rf is the best possible rate of return of a â€Å"risk free† security (i. e. cash) StdDev is the standard deviation of Rx The Sharpe ratio is a direct measure of reward-to-risk. In other words, the Sharpe ratio is used to characterize how well the return of an asset compensates the investor for the risk taken. (4) Although beta, alpha and the Sharpe ratio are useful for an investor to gauge the risk of a security or portfolio of securities there are also other methods an investor can use to determine whether a security is a good investment or not. The two most common methods used to determine the investment potential of a security are fundamental analysis and technical analysis. Fundamental analysis is the process of looking at a business from its financial statements. This type of analysis typically looks at various ratios of the business to determine its financial health. The goal of fundamental analysis is determine the current worth of a stock and how the market values the stock. (5) Probably the most two important factors looked at in fundamental analysis are a company’s earnings and revenue growth. Investors like to see earnings and revenue increasing by at least 25% for each of the last three quarters and year-to-date. Return on equity (ROE) is also a major fundamental factor. ROE reveals how much profit a company earned in comparison to the total amount of shareholder equity found on the balance sheet. (6) The higher a company’s ROE compared to its industry the better. Investors typically look for an ROE of at least 17%. Technical analysis is a method of evaluating stocks by relying on the assumption that market data, such as charts of price, volume and open interest can help predict future market trends. (7) Investors using technical analysis typically look for trends in chart data and use a variety of technical indicators, such as moving averages, Bollinger bands, fast and slow stochastics, MACD, and RSI to determine the right buy point for a stock. More sophisticated investors use a combination of fundamental analysis and technical analysis to determine whether a stock is a good buy or not. They use fundamental analysis to make sure a company is healthy from a financial standpoint and is a leader in its industry. Once determining a stock is healthy from a fundamental standpoint, these investors will use technical analysis to determine the correct buy point for a stock. A stock’s chart will show the investor how the stock is actually performing in the market and whether it is rising out of a good base or is overbought based on how far its current price is from its 50 day moving average. If a stock’s price is 30% or more above its 50 day moving average, the risk that it will fall into a correction is greater. References: (1) http://www. investopedia. com/articles/stocks/04/113004. asp Beta: Know the Risk (2) http://www. moneychimp. com/articles/valuation/capm. htm CAPM Calculator (3) http://www. allbusiness. com/glossaries/alpha/4943389-1. html Business Definition for Alpha (4) http://www. moneychimp. com/articles/risk/sharpe_ratio. htm The Sharpe Ratio (5) http://stocks. about. com/od/evaluatingstocks/a/Fundanatools1. htm Tools of Fundamental Analysis (6) http://beginnersinvest. about. com/cs/investinglessons/l/blreturnequity. htm Return on Equity (ROE) (7) http://www. investorwords. com/4925/technical_analysis. html Technical Analysis

Thomas Hardys The Sons Veto, Graham Greenes The Basement Room and al

Thomas Hardy's The Son's Veto, Graham Greene's The Basement Room and alan Sillitoe's Uncle Ernest In each of the three stories, 'The Son's Veto' by Thomas Hardy, 'The Basement Room' by Graham Green and 'Uncle Ernest' by Alan Silitoe, the respective writer conveys a sense of isolation regarding the central character. There are numerous similarities between the characters based on their common plight, but each story differs in the portrayal of these characters. The writer's effectively present the characters using a varying range of literary styles. In 'The Son's Veto' the disabled Sophy is denied happiness from not fitting in to a higher social class. Graham Green in 'The Basement Room' employs a surreal situation to demonstrate the vulnerability and naiveity of youth. 'Uncle Ernest' is a story, which adopts a dreary approach to Ernest's life. The opening descriptions of the three characters are very effective and induce stereotypical views. This applies to Ernest especially in 'Uncle Ernest' as we first hear of him wearing a "dirty raincoat" and looking as though he "hadn't washed for a month". These observations imply that Ernest is homeless and the use of "dirty" further emphasize the fact that something is wrong in his life. Sophy also stands out from everyone else in 'The Son's Veto' but for different reasons to Ernest. Hardy creates Sophy's character to be misplaced in society, as she is a "young invalid lady" and wheel chair bound. In contrast to this her "nut brown hair was a wonder and a mystery". Her hair is used to make reference to her history suggesting a mysterious and dark background yet its vibrancy allowed her to maintain a part of her character. The wheel chair depicts isolation espe... ...he war. The reader is overwhelmed with sympathy for Ernest, as nothing ever seems to result in happiness for him. Our sympathies lie with all three characters as their isolation has been conveyed to the reader effectively by each author. Philips loneliness is a result of a troubled up bringing which leaves him mentally scared for life. Sophy and Ernest on the other hand are similar to each other and unlike Philip. They both induce a sense of helplessness in the reader after a life of persistent disappointment denies them from any chance of happiness. It becomes almost inevitable that Ernest and Sophy would end up completely isolated as events throughout the stories favor this outcome. On the other hand Philip's situation is different, he is portrayed as a very vulnerable character and it's as if he is prevented from ever having a chance to live a life.

A Consideration of the Role of Feste in Twelfth Night

Shakespeare portrays Feste as a well-drawn, wise, cunning, adaptable character. His character is used in Twelfth Night to reflect on the actions and emotions of the others by keeping himself at a distance from the other characters and not becoming emotionally involved in any of the plots at the beginning of the play. Feste subtly conveys his messages and thoughts through his songs to the audience about the other characters in the play. He reveals in his songs that Orsino is â€Å"roaming† after the wrong love in his pursuit of Olivia. Feste somewhat becomes the narrator of the play by commenting on actions that occur within the play and foreshadowing events. When Feste first enters into the play he has been absent from Olivia's court a long time and must now return into her favour. He does not want to listen to what Maria says to him and using his quick wit manages to answer her. Feste demonstrates his quick wit and ability to juggle words effectively when he says: Let her hang me; he that is well hanged in this world needs to fear no colours. This remark reveals that Feste does not fear Maria's threats and also reveals his intelligence and his philosophical side for he would rather be hanged than be in a war, â€Å"needs fear no colours†. Shakespeare portrays him as a wise man although the Elizabethan audience might consider him a coward and unpatriotic for not wanting to protect and defend his country. Feste carries the stigma of stupidity, which previous fools in literature have inflicted upon all fools but Shakespeare created Feste as an intelligent fool who would change the audience's perception of the role of fools. Shakespeare displays Feste's skill at juggling words as an example of the differences between Feste and other fools as traditionally fools are considered to be ignorant buffoons who are there to entertain using jokes and juggling objects to create amusement. However, Feste displays his insight about the people surrounding him instead while also offering his thoughts about which ruinous condition he would rather be in, â€Å"many a good hanging prevents a bad marriage†. Here he hints that a bad marriage may take place and that death is better than to be unhappy in life. Feste is not loyal to his mistress like Malvolio is to Olivia and Viola is to Orsino for he wanders through the different courts always in search of favour and money. In Orsino's court he sings of love and how it can kill, â€Å"I am slain by a fair cruel maid† man's folly and man's deceitful nature while in Olivia's court he sings to Sir Toby and Sir Andrew he sings more joyful and careless songs but still reflecting on the characters' actions. When he sings the type of song Sir Toby selected he adds on to it when he sees they like it and makes the song relevant to what is happening and sings about what he has seen as an outsider watching the scenes that are happening. Even when he uses music he acts in his capacity as the fool for the house and is secretly wording the advice he would give to certain other characters in the play should he be allowed to tell them. This illustrates his perceptiveness and ability to adapt to any situation no matter what he is supposed to do. Feste's perceptiveness is used as a device to remember what has happened in Twelfth Night without becoming too involved in the play and not seeing the bigger perspective. Sir Andrew is revealed as even more ignorant than Sir Toby has already portrayed him as Feste uses his skills at juggling words to make up new words, which seem real and genuine to Sir Andrew. Feste uses his role as the fool to poke fun at Sir Andrew and sets him up for further humiliation later on because Sir Andrew stores the words Feste uses in his memory and later uses them in any context to try and convince everyone of his intelligence. As Twelfth Night is a play all about foolery and based on the Feast of Fools it is fitting that Feste should make fun of the lesser characters of the play, which somehow make the audience laugh at them as well. Feste is the centre of amusement and merriment in every situation, providing the entertainment for the others and he does this in many ways. Sir Toby enjoys Feste making fun of Sir Andrew and Feste knows this so he does it to please Sir Toby and Sir Andrew being the person he is doesn't realise this and pays Feste as well. Feste demonstrates his cunning in managing to get money out of two people for different reasons. In Act 4 Feste reveals he is ready to become part of the play and take an active role. The others have tricked Malvolio agrees to dress up as Sir Topas, a curate. He thoroughly enjoys his new role as he is making Malvolio madder and without Malvolio in the way he is more important to his mistress, Olivia. In his role as Sir Topas he is more appealing to Sir Toby as Sir Toby hates Malvolio for his puritan-like ways. Feste's disguise convinces Malvolio that Feste is a real curate and Feste undermines his own character being reluctant to join in and always being himself he is now pretending to be something he is not although he is adapting to this new role he is putting on a different face, which he has never done before. Feste reveals one of his flaws through his disguise when he does not know where is a safe place to stop teasing Malvolio and juggling words. In this way he goes over the top with his role and needs someone to keep him in check but has no one to do this for him. Feste's final song seems to be a perfect ending to Twelfth Night. While this song contains many silly words and phrases designed to make people laugh, it does have a serious side to it that suggest that love and marriage are not the only things in life and that there is not always a happy ending. The song goes through the life cycle from a â€Å"little tiny boy† and reverts all the way back around again to when the â€Å"world begun†. It seems to be about Feste's life in particular and his choice to become a fool. He is saying that becoming a fool was his only way to survive because he could not have succeeded any other way. Shakespeare uses Feste as someone to reflect and a way to end the play fittingly. In Twelfth Night, the fools are the ones that control the comedy and humour in the play. They assist in the make believe game and fool around with characters who â€Å"evade reality or rather realize a dream†. This makes Feste a pivotal character in Twelfth Night as without him many other things could have happened and a lot less humour and jokes would have occurred.

The need for reform in criminal law - Free Essay Example

Sample details Pages: 12 Words: 3465 Downloads: 8 Date added: 2017/06/26 Category Law Essay Type Argumentative essay Topics: Crime Essay Criminal Law Essay Did you like this example? The criminal law on omissions is confusing and does not fit easily with the requirement that both actus reus and mens rea must be present to establish a criminal offence. This area of law is in need of reform. Discuss with reference to the relevant law. A fundamental principle of the criminal law is that the prosecution must prove, for all crimes, beyond all reasonable doubt, that the defendant committed both the actus reus and the mens rea (except crimes of strict liability). Don’t waste time! Our writers will create an original "The need for reform in criminal law" essay for you Create order The actus reus, or à ¢Ã¢â€š ¬Ã‹Å"guilty actà ¢Ã¢â€š ¬Ã¢â€ž ¢ for most crimes, will involve the physical act of committing the crime, such as using physical force to commit grievous bodily harm upon another person. The mens rea of a crime involves the mental element. Some crimes require specific intent, such as murder. Other crimes, such as criminal damage can be proven by a lesser state of mind, such as recklessness. The introduction should also introduce the concept of omission. [Researcherà ¢Ã¢â€š ¬Ã¢â€ž ¢s comment: The introduction NEEDS to introduce the concept of criminal liability, ie, mens rea and actus reus as it is specifically referred to in the question, which is why I have placed this here. The next logical step is then to discuss how the concept of omissions fits in. You canà ¢Ã¢â€š ¬Ã¢â€ž ¢t begin to discuss omissions until this has been dealt with.] Thus, it can be established that for the most part, the law recognises the guilty conduct of the offender in the f orm of a physical act. The essential question arises, when does the law recognise an omission to act as criminally culpable? Should the law go as far as to punish those who fail to play the good Samaritan to the individual in peril, or simply enforce a responsibility to act where there is a clear duty of care to another individual? Shouldnà ¢Ã¢â€š ¬Ã¢â€ž ¢t this be included as the introduction given that it introduces the concept of omissions [Researcherà ¢Ã¢â€š ¬Ã¢â€ž ¢s comment: dealt with above]. The law seems to favour the latter. In R v Miller[1] it was stated: à ¢Ã¢â€š ¬Ã…“Unless a statute specifically so provides, or à ¢Ã¢â€š ¬Ã‚ ¦ the common law imposes a duty upon one person to act in a particular way towards another à ¢Ã¢â€š ¬Ã‚ ¦ a mere omission to act [cannot lead to criminal liability].à ¢Ã¢â€š ¬Ã‚  An example of an offence created by statute for an omission to act, would be a failure to produce a specimen of breath under the Road Traffic Act 1988, sectio n 6(4) where a police officer has reasonable suspicion to request such a specimen. Further, a statutory offence also dealt with by the Road Traffic Act, is the failure to wear a seat belt whilst driving. One could argue that this is in fact a positive act. Although the failure to wear a seat belt is in fact an omission, in order to be guilty of such offence, the defendant must also commit the physical act of driving. Thus, there can be no offence for the omission to act without the positive act of driving. This is a good demonstration of some of the difficulties and inadequacies of the law on omissions. The common law has developed a number of categories in which a duty of care arises between certain individuals. A failure to act in such circumstances can lead to criminal culpability. The first of such categories is where a special relationship exists between the individuals. Such relationship can be between a parent and child. In the case of Downes[2] a father who belonged to a religious sect who believed in the power of prayer rather than orthodox medicine was convicted of manslaughter when he failed to call a doctor for his sick child who later died. Such duty is now imposed by statute.[3] A further example of such duty can be found in the case of Gibbins and Proctor.[4] (no explanation of case in footnotes) [Researcherà ¢Ã¢â€š ¬Ã¢â€ž ¢s comment: Explanation of cases is not always needed. It is much the same situation as the case just mentioned. This is placed here simply for further authority of this point. Further, footnotes should be for reference only.] An individual who has a duty under a contract will also be liable under the criminal law for a failure to act. In R v Pittwood[5]a gatekeeper who forgot to shut the gate on a railway crossing which resulted in the death of a person hit by a passing train was found to owe a duty in law. Where an individual assumes responsibility for another, a later failure to act could lead to criminal liabilit y. In the case of Stone and Dobinson[6] the defendants were held liable for their failure to fulfil a duty of care to Stoneà ¢Ã¢â€š ¬Ã¢â€ž ¢s sister who came to live with the defendants. The sister became extremely ill and the defendants hopelessly tried to help her, but were not able to do so. Despite their hopeless efforts, they still failed to meet the duty of care that they had assumed by becoming carers. The conduct of an individual may also give rise to a duty to act in certain circumstances. For example, in R v Miller[7] the defendant had fallen asleep in the squat where he was living with a lit cigarette. The mattress in his room caught fire and instead of taking action to extinguish it, he simply got up and moved to another room. He was held to have created a duty of care from his own dangerous conduct and by failing to take any action to prevent the fire spreading, even by merely calling the fire brigade, he was in breach of that duty and convicted of arson under the C riminal Damage Act 1971. Thus, an individual who creates a dangerous situation should be held to have a duty in law to rectify that situation and the law clearly states that this is the case. Although these five categories are clearly established in law, they are not indicative. In Khan and Khan[8] two drug dealers appealed from convictions of manslaughter as a result of supplying the deceased with heroin and failing to summon medical assistance when she went into a coma. The convictions were quashed by the Court of Appeal, where Swinton Thomas LJ stated: à ¢Ã¢â€š ¬Ã…“To extend the duty to summon medical assistance to a drug dealer who supplies heroin to a person who subsequently dies on the facts of this case would undoubtedly enlarge the class of person to whom, on previous authority, such a duty may be owed.à ¢Ã¢â€š ¬Ã‚  These quotations are to long particularly as there seems to be no analysis supplementing them. [Reseaercherà ¢Ã¢â€š ¬Ã¢â€ž ¢s comment: The analysis i s contained below. This is a clear explanation of when the law should extend a duty of care which is why I placed it here. It is also part of the public policy argument] Essentially, the issue of imposing a duty of care is one of public policy. In circumstances where the court feels that policy should dictate a duty of care in the circumstances, then this will require the imposition of such duty. Moreover, English law is based on a common law system that allows predictability through a system of precedent. For judges to simply extend the duty of care in cases where they see fit, would be to completely ignore such authority and clearly a bad path for the law to tread. As a matter of comparison, when examining the principles of causation, the common sense approach of the à ¢Ã¢â€š ¬Ã‹Å"but forà ¢Ã¢â€š ¬Ã¢â€ž ¢ test provides a clear starting point to establish causation. However, in order for the causal link to be established at law, there must be a proximate cause. As a matter of fact, such à ¢Ã¢â€š ¬Ã‹Å"proximate causeà ¢Ã¢â€š ¬Ã¢â€ž ¢ (where did this quote come from? [Not a quote, ità ¢Ã¢â€š ¬Ã¢â€ž ¢s a term referred to heavily in the case law for causation.]) is not so easy to establish, and many academics have advocated that the à ¢Ã¢â€š ¬Ã‹Å"desiderata of cause, are not causal factors at all, but matters of legal policy.à ¢Ã¢â€š ¬Ã¢â€ž ¢[9] Smith comments: à ¢Ã¢â€š ¬Ã…“If that is the case, however, we have no causal ground for distinguishing acts from omissions based on the use of causal concepts in law, since proximate cause is about responsibility, and à ¢Ã¢â€š ¬Ã…“but-forà ¢Ã¢â€š ¬Ã‚  cause does not distinguish positive from negative factors in a causal field. Negative factors are causal factors just as positive factors are. Consequently, it is reasonable to conclude that nothing in the legal treatment of causation precludes omissions being considered causes in the law.à ¢Ã¢â€š ¬Ã‚ [10] (quote to long, it should only capture the main points) [This quote explains the main points of my arguments below. It brings the aspect of causation into the argument and how, although not directly, the reasoning behind many of the omissions decisions, has been based on where the defendant has either à ¢Ã¢â€š ¬Ã‹Å"allowedà ¢Ã¢â€š ¬Ã¢â€ž ¢ something to happen, or à ¢Ã¢â€š ¬Ã‹Å"causedà ¢Ã¢â€š ¬Ã¢â€ž ¢ it to happen. The latter represents the majority of the omissions cases, where the conduct of the defendant has been more than simply à ¢Ã¢â€š ¬Ã‹Å"allowà ¢Ã¢â€š ¬Ã¢â€ž ¢ the act to happen. However, the discussion then goes on to say, in causal terms, there must at least be some difference otherwise we would not distinguish between acts and omissions. Thus, essentially, what the law is attempting to ascertain, is the difference between allowing situations to happen, and causing them to happen. (Good analysis) In this aspect, the courts have created a grey area with the analysis between acts and omissions. Airedale NH S Trust v Bland[11] involved a civil decision, where the healthcare team in charge of a patient in a persistent vegetative state (PVS), applied to the court for a declaration that it would be lawful to withdraw hydration and feeding. Essentially, the case was brought in order to establish the legality of such action and immunity from prosecution. The patient had been in his unconscious state for a considerable amount of time, with no prospect of recovery. He was being fed by naso-gastric tube. The healthcare team wanted to remove his feeding and hydration, which would eventually result in the death of the patient. The House of Lords concluded that to do so would be lawful. In arriving at their decision, their Lordships applied the acts and omissions doctrine. Under civil law, as there was no way of gaining Anthony Blandà ¢Ã¢â€š ¬Ã¢â€ž ¢s consent, the doctors could only treat him under the doctrine of necessity if it was in his best interests.[12] They had concluded that it was n ot in his best interests, and to carry on feeding him (regarded as à ¢Ã¢â€š ¬Ã‹Å"treatmentà ¢Ã¢â€š ¬Ã¢â€ž ¢) was a criminal and civil assault. Therefore, they had to remove such feeding. Thus, the cause of Anthonyà ¢Ã¢â€š ¬Ã¢â€ž ¢s death would not be the result of a physical act, but an omission. (Couldnà ¢Ã¢â€š ¬Ã¢â€ž ¢t the case be briefly discussed in the footnotes and rather more analysis and evaluation in the body) [This case is extremely relevant to the discussion, as are the points. I know a lot of detail has been spent on this case, but out of ALL the omissions cases, it raises some of the most interesting arguments and authoritative statements. The section also contains a good analysis of the decision. Both are incorporated, and it is necessary to explain the circumstances in order to critically analyse the case. Further, it carries greater weight for analysis of the doctrine. Not only does it show how public policy has discharged a duty of care, it also discusses how t he distinction between acts and omissions is difficult to make. None of the other cases have provoked such academic debate as this.] This approach is extremely controversial; as essentially, the removal of the naso-gastric tube involves a physical act, that will in fact, cause Anthony to die. In essence, this type of conduct falls under the category of à ¢Ã¢â€š ¬Ã‹Å"causingà ¢Ã¢â€š ¬Ã¢â€ž ¢ the death, rather than merely allowing it to happen. A distinction would be if Anthony were never placed on such feeding, his death would be a result of his mal-nutrition and his physical inability due to his physical inability to feed himself. By intervening and treating Anthony, the healthcare team had to then take physical action to allow him to die. Further, it would seem that the very reason their Lordships followed the reasoning they did, was a matter of policy. They were able to state that the healthcare team would not be guilty of any homicide offence because their duty of care was d ischarged by the fact that the treatment was not in his best interests. Therefore, in law they were under no duty to act and withdrawing treatment to allow Anthony to die was lawful. The discussion on Anthony seems to have become the main point of the essay, although some of the points are good, research should also focus on other similar or contrasting cases to make such points. [N.B. Discussed above] Interestingly, the analysis in Bland is quite inconsistent. Returning to the earlier case of Stone and Dobinson,[13] one could argue that in the same way, by intervening and accepting responsibility, the defendantà ¢Ã¢â€š ¬Ã¢â€ž ¢s in the case had voluntarily assumed a duty of care. Thus, in Bland, the same could be said, the doctorà ¢Ã¢â€š ¬Ã¢â€ž ¢s duty of care arises from an agreement and an assumption for the treatment of the patient. In Bland, it was held that it was no longer in his best interests to carry on with the treatment. In Stone and Dobinson, the sister insisted th at she did not want help in anyway and the defendantà ¢Ã¢â€š ¬Ã¢â€ž ¢s were clearly intimidated by this. Yet liability for the latter was asserted, clearly again because of policy. The fact that withdrawing treatment would cause the death of Anthony, also brings into the discussion the mens rea requirement. Even if the death of Anthony was not directly intended, it was clearly a virtual certainty of their actions and therefore a jury could have inferred intention to cause death under the approach of Woollin.[14] This approach has been further exemplified by the Court of Appeal in the decision in Re A (Children)[15] where doctors separating conjoined twins foresaw the death of one twin as à ¢Ã¢â€š ¬Ã‹Å"virtually certainà ¢Ã¢â€š ¬Ã¢â€ž ¢ and therefore had intention for murder. The doctors in the case however, were not guilty of an offence. Yet again, the assertion is one of policy. The implications of holding doctors and healthcare professionals guilty of homicide offences is st riking and the courts have to accommodate such policy decisions in their reasoning. Further, the principle that both the actus reus and mens rea must be present in order to secure conviction also plays significance in these decisions. Coincidence of both aspects of a crime is essential. Yet in certain cases, on the face of it, such principles do not coincide. The driver in Fagan[16] who accidentally drove his car on to a policemanà ¢Ã¢â€š ¬Ã¢â€ž ¢s foot, was asked to move it off, delayed in doing so, and he was convicted of assaulting the police officer. Although at the time his car initially made contact with the officerà ¢Ã¢â€š ¬Ã¢â€ž ¢s foot, Fagan did not possess the necessary intent, his subsequent actions constituted a à ¢Ã¢â€š ¬Ã‹Å"continuing actà ¢Ã¢â€š ¬Ã¢â€ž ¢ where is this quote from? [Again, ità ¢Ã¢â€š ¬Ã¢â€ž ¢s not a quote, ità ¢Ã¢â€š ¬Ã¢â€ž ¢s a point referred to continuously in the law relating to coincidence of mens rea and actus reus] and therefore, the lat er refusal to move the car, because of the intent to assault, resulted in a coincidence of the necessary elements. Allen comments that if the same facts were to occur today, then Fagan would have been convicted under the duty principle in Miller.[17] However, even if the same situation was to arise and the principle in Miller applied, then the analysis would still require the conduct of the defendant to be treated as a continuing series of events, whether acts or omissions. The difference with the latter being that an omission to act in itself brings into play a series of events that in certain situations, can be prevented. In essence, the main issue is that the law on omissions is both confusing and centered on policy. Policy interprets the boundaries of the legal duty to impose legal culpability for an omission to act. Clearly, in circumstances where policy dictates that a duty to act, or not to act, should arise, then the law will follow such approach. However, should the law go as far as to impose a general duty to act in a situations which at least something can be done to prevent a potentially fatal outcome. Thus, the member of the public who is walking on the riverside, and sees a young girl drowning, but is afraid herself to help as she cannot swim. What should she do, walk on by? Or is she expected to take a step further and attempt to rescue the girl? Well, in essence, the law could require neither. Even if the passer by were able to call for further help, or throw the life buoy to try and save the girl, this would surely discharge her duty of care, if the law were to impose such duty. French law imposes such a duty.[18] Surely, this is not so overreaching as to take away civil liberties? Every individual is entitled to the right and respect to a private life under Article 8 of the European Convention on Human Rights and Fundamental Freedoms, implemented into domestic law through the Human Rights Act 1998. However, it is unlikely that if in troduction of such duty was implemented, that one could argue that such duty was in breach of fundamental civil liberties. One would hope, for the most part, that a passer by would in fact raise an alarm, or attempt to help, but this is clearly a question of conscience and not legal duty. One option would be to follow the example of France. However, this would require a radical change to the omissions doctrine as demonstrated under English Law. One would further have to consider the scope of such duty. Would it be sufficient to describe it as a duty to rescue, as is the case in France?[19] This however, would have to be moderated, in that a duty to rescue could not impose a duty upon one person, to rescue another, in circumstances where the rescuer would be in danger, or even possibly face a hostile situation. This would surely be in breach of an individualà ¢Ã¢â€š ¬Ã¢â€ž ¢s civil liberties under the Human Rights Act 1998. One thing that is certainly clear is that the judicia ry would be extremely reluctant to implement such changes in the law. Criminal liability for such circumstances should be the subject of reform by the elected lawmakers; Parliament. One thing that should be clarified is the exact duty of care for an omission to act. One codified piece of legislation. In reality however, the case-by-case basis of the common law enables the judiciary flexibility to deal with situations as they arise and implement a duty of care when they see fit, and when policy so dictates. It also allows great flexibility in manipulating the law to coincide both elements of an offence, whether one chooses to approach the subject on the basis of acts or omissions. What the present law seems to allow, is room to impose a duty when the court sees fit, and where the court feels the defendant has done more than simply à ¢Ã¢â€š ¬Ã‹Å"allowà ¢Ã¢â€š ¬Ã¢â€ž ¢ the circumstances to occur, but can be said to have à ¢Ã¢â€š ¬Ã‹Å"causedà ¢Ã¢â€š ¬Ã¢â€ž ¢ such circumstances. S uggestions for reforms are required, not simply in the conclusion but also in the areas of law where there appears to be error or confusion in the law and there is an obvious requirement, or even contrastingly where there doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t appear to be a need for reform. Since that would appear to fully answer the question. Thank You. Bibliography Allen, M.J., à ¢Ã¢â€š ¬Ã‹Å"Textbook on Criminal Lawà ¢Ã¢â€š ¬Ã¢â€ž ¢ (5th Edition, 1999), Blackstone Press, London (there is a newer edition) [I am aware that there is a newer addition, however, I have used up to date books as well as this one] Clarkson and Keating, à ¢Ã¢â€š ¬Ã‹Å"Criminal Lawà ¢Ã¢â€š ¬Ã¢â€ž ¢ (5th edn, 2003), Sweet Maxwell, London Goff, à ¢Ã¢â€š ¬Ã‹Å"The Mental Element in the Crime of Murderà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1988) 104 L.Q.R. 30 Gross, H., à ¢Ã¢â€š ¬Ã‹Å"A Note on Omissionsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (184) 4 LS 308 (cant seem to find this? Afraid I only have this in paper format) Smith and Hogan, à ¢Ã¢â€š ¬Ã‹Å"Criminal Lawà ¢Ã¢â€š ¬Ã¢â€ž ¢ (10th edn, 2002) Butterworths, London Smith, P., à ¢Ã¢â€š ¬Ã‹Å"Legal Liability and Criminal Omissionsà ¢Ã¢â€š ¬Ã¢â€ž ¢, Buffalo Criminal Law Review [2001] Vol. 5:69 Wilson, W. à ¢Ã¢â€š ¬Ã‹Å"Doctrinal Rationality after Woollinà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1999) 62 M.L.R 448 1 Footnotes [1] [1983] 1 All ER 978 [2] (1875) 13 Cox 111 [3] Children and Young Persons Act 1933, section 1(2)(a) [4] (1918) 13 Cr App R 134 [5] (1902) 19 TLR 37 [6] [1977] 1 QB 354 [7] supra, note 1. [8] [1998] Crim LR 830 [9] Smith, P., à ¢Ã¢â€š ¬Ã‹Å"Legal Liability and Criminal Omissionsà ¢Ã¢â€š ¬Ã¢â€ž ¢, Buffalo Criminal Law Review [2001] Vol. 5:69 [10] Ibid [11] [1993] AC 789 [12] Re F [1989] 2 AC 1 [13] Supra, note 6. [14] [1998] 3 WLR 382 [15] [2000] 4 All ER 961 [16] [1969] 1 QB 439 [17] Allen, M.J., Textbook on Criminal Law, 1999:44 [18] Article 223-6 of the French Penal Code; A. Ashworth, E. Steiner, à ¢Ã¢â€š ¬Ã‹Å"Criminal Liability For Omissions, the French Experienceà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1990) 10 Legal Studies 153 [19] A. Ashworth, E. Steiner, Ibid