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Cypen & Cypen
December 5, 2019

Stephen H. Cypen, Esq., Editor

The IRS has updated its revenue ruling on the use of standard mileage rates to reflect changes made by the Tax Cuts and Jobs Act (TCJA). Prior to this update, the rules for using standard mileage rates and fixed and variable rate (FAVR) allowances--mileage allowances that use a flat rate or stated schedule combining periodic fixed and variable rate payments--were set out in Revenue Procedure 2010-51. For taxable years after 2017 and before 2026, however, the TCJA suspended miscellaneous itemized deductions, and limited moving expense deductions and the exclusion for moving expense reimbursements to certain moves by members of the Armed Forces. Those TCJA changes have been explained and incorporated into other IRS guidance, including a supplement to the announcement of 2018 mileage rates, the 2019 mileage rate announcement, and Publications 15-B (Employer’s Tax Guide to Fringe Benefits), but they were not reflected in Revenue Procedure 2010-51, the IRS’s principal guidance on the use of standard rates to substantiate the value of business use of an automobile. Revenue Procedure 2019-46, modifies and supersedes Revenue Procedure 2010-51 in its entirety. The changes remove obsolete material, acknowledge the suspension of miscellaneous itemized deductions, and update examples to reflect more recent, higher mileage rates. The updated revenue procedure also clarifies the circumstances in which standard mileage rates may continue to be used by certain individuals for their business expenses because those expenses reduce their adjusted gross income (i.e., they are exclusions or “above-the-line” deductions). These individuals include qualifying performing artists, fee-basis state or local government officials, educators, and Armed Forces reservists. Provisions regarding the use of standard mileage rates for charitable and medical deductions, and setting the rules for computing FAVR allowances, are essentially unchanged. The revised discussion of moving expense deductions affirms that use of the standard mileage rate for claiming a moving expense deduction under Code ยง 217 is limited during the suspension period to members of the Armed Forces on active duty moving pursuant to a military order and incident to a permanent change of station. And a new provision warns that payment arrangements will fail to satisfy the accountable plan rules if payments are made regardless of whether an employee incurs (or is reasonably expected to incur) deductible business expenses or other, bona fide, nondeductible expenses. The updated revenue procedure is effective November 14, 2019, but the TCJA changes that it explains are effective for taxable years beginning after 2017 and before 2026.
EBIA Comment:
The suspensions of miscellaneous itemized deductions, moving expense deductions, and exclusions for moving expense reimbursements have already taken effect and been explained by the IRS multiple times. Revenue Procedure 2010-51, however, was the IRS’s authoritative pre-TCJA description of the rules governing mileage rates and had to be updated. While the update seems to add little to what we already knew about the TCJA’s impact, it does add an interesting reminder about schemes to recharacterize income as nontaxable business expense reimbursements. The IRS has previously warned that such schemes generally fail because reimbursements resulting from recharacterization of income fail the business connection requirement under the accountable plan rules. The IRS appears to have inserted this new warning to discourage employers from using recharacterization to help employees avoid the TCJA’s adverse tax consequences. For more information, see EBIA’s Fringe Benefits manual at Sections II.B.1.a (“What Is the Difference Between an Exclusion and a Deduction”), II.E (“Employee Business Expense Reimbursements”), IV.F (“Employer Reimbursements for Business Use of an Employee’s Car”), XVII.D (“What Expenses Can Be Qualified Moving Expenses”), and XXI (“Travel Expense Reimbursements”). See also EBIA’s Cafeteria Plans manual at Section XX.L.8.b (“Mileage Rate for Traveling to Obtain Medical Care”).
EBIA Staff, Rev. Proc. 2019-46 (Nov. 14, 2019), Thomson Reuters, November 27, 2019.
Clients can take advantage of 2017 Tax Act’s increased exemption amount without worrying about law’s sunset.

New final regulations released by the Internal Revenue Service on Nov. 22, 2019 are welcome news for high-net-worth clients who make large gifts using their increased estate/gift tax exemption now but die in a year when the exemption is lower. The new regulations make clear that gifts made within the increased exemption amount used before the client’s death won’t be “clawed back” into the client’s estate. In response to Internal Revenue Code Section 2001(g)(2), enacted as part of the Tax Cuts and Jobs Act (2017 Tax Act), in which the Secretary of the Treasury was directed to prescribe regulations to carry out IRC Section 2001(g) with respect to the difference between the basic exclusion amount applicable at the time of a decedent’s death and the basic exclusion amount applicable with respect to any gifts made by the decedent, the Secretary issued Proposed Regulations Section 20.2010-1(c). Treasury Regulations Section 20.2010-1(c) ensures that, if a decedent uses the increased basic exclusion amount for gifts made while the 2017 Tax Act was in effect and dies after the sunset of the 2017 Tax Act (currently scheduled for Jan. 1, 2026), such decedent won’t be treated, on such decedent’s estate tax return, as having made adjusted taxable gifts solely because the increase in the basic exclusion amount effectuated by the 2017 Tax Act was eliminated.

Mechanism Used by IRS
The mechanism by which Treas. Regs. Section 20.2010-1(c) achieves this result is to provide that, if the total credits that were used in computing a decedent’s gift tax on post-1976 gifts, within the meaning of Section 2001(b)(2), is greater than the applicable credit amount used, pursuant to IRC Section 2010(a), to compute the estate tax on the decedent’s estate, the credit that can in that circumstance be used to compute the estate tax is deemed to be the total credits that were used in computing the decedent’s gift tax. Unlike Prop. Regs. Section 20.2010-1(c), Treas. Regs. Section 20.2010-1(c) explains how the deceased spousal unused exclusion (DSUE) amount interacts with the basic exclusion amount to produce the intended “no clawback” result. Treas. Reg. Section 20.2010-1(c)(1)(ii) and Example 4, taken together, make several important points clear. First, when a surviving spouse makes taxable gifts, any DSUE amount that was available to him is deemed to have been applied to those gifts before his basic exclusion amount was so applied. Second, if that surviving spouse dies after the sunset of the 2017 Tax Act, the DSUE amount applied to those gifts isn’t reduced. Third, if both the DSUE amount and the surviving spouse’s basic exclusion amount were applied to those gifts, in calculating the amount of the credit available in computing the surviving spouse’s estate tax, the undiminished DSUE amount is removed. Fourth, the total credits that were used in computing the surviving spouse’s gift tax based on that intact DSUE amount, plus the credit determined by applying the general “no clawback” rule of Treas. Regs. Section 20.2010-1(c), are available to offset the surviving spouse’s estate tax liability.
Welcome Development
Although, surprisingly, it took a year to bring this relatively small regulatory project to a conclusion, it’s a welcome development. In particular, the IRS’ treatment of the DSUE amount in the “no clawback” context is good news.  It’s somewhat disappointing that the IRS declined to address whether GST exemption allocated before sunset of the 2017 Tax Act would, like the basic exclusion amount and the DSUE amount applied in computing the gift tax on post-1976 gifts, remain in place without reduction. It seems significant, though, that, in the preamble to the final regulation, after observing that the GST exemption amount is defined by reference to the basic exclusion amount, the IRS stated: “There is nothing in the statute that would indicate that the sunset of the increased [basic exclusion amount] would have any impact on allocations of the GST exemption available during the increased [basic exclusion amount] period.”
Charles A. Redd, WealthManagement.com, November 26, 2019.
With more than 100 lawsuits filed against the fiduciaries of defined contribution retirement plans for breach of their responsibilities, litigation has plagued the retirement plan industry for the past decade. While the issues of these suits are varied and complex, most focus on actions taken or not taken that may have limited the potential growth of retirement plan participants’ account balances. Over the past few months, we launched an in-depth exploration into the claims of these lawsuits, highlighting the issues, the litigation outcomes and the key take-aways for retirement plan sponsors. Below is a recap of our Fiduciary Breach Lawsuit Series.

Active Versus Passive Investments
In many of the lawsuits filed against the fiduciaries of defined contribution retirement plans, there have been claims that the plan sponsor included one or more investments in the plan lineup that underperformed the particular benchmark for the fund’s asset class. While passive investments seek to mirror the asset class index holdings, active managers try to surpass the index, net of fees. In practice, consistently beating the benchmark is a challenge that many managers fail to overcome. Actively managed funds also cost more than index options in the same asset class, due to the research and analysis required of actively-managed fund managers. This results in some active managers underperforming their asset class benchmark while charging higher fees to participants. Some of the fiduciary breach lawsuits state that the manager failed to competently select the underlying holdings, which cost the participants potential for investment return, and that participants are not receiving any value for these higher fees. Thus, the claims argue that fiduciaries should have used passive investment options instead of active ones in the plan. However, based on the outcomes of the litigation surrounding this issue, it seems clear that plan fiduciaries can include actively-managed investment options in their plans. There is nothing in the ERISA regulations that requires a plan to include any index investment options, or to select passive funds instead of active options in any particular asset class. However, it will likely help lessen the chances of being sued on this issue if there are at least some index funds included in the investment lineup. In addition, it will be helpful for plan fiduciaries to be able to demonstrate that the retirement plan committee periodically debates the merits of active versus passive investments, particularly as it considers changes to any of the plan options. As long as there is a reasonable basis for the ultimate investment selection, and the foundation for that decision is documented, the committee should be protected. To learn more about this issue, please click here.

Asset-Based Fees Versus Per-Participant Fees
Another claim asserted by plaintiffs in many of the lawsuits is that retirement plan fiduciaries allow recordkeepers to charge fees based on the assets in the plan, when they should charge a flat-dollar amount per participant. The argument behind this claim is that the cost for providing recordkeeping services to participants should be roughly the same, regardless of the amount of assets a participant has in his/her account. The overriding message from the litigation proceedings is that there is no right or wrong way to charge plan fees. Both asset-based fees and per-participant fee methods are used by many plans. The retirement plan committee should explore the options and understand how each method may impact their plan’s participants, documenting the decision and rationale behind it. Regardless of which method is selected, it is important for plan committees to regularly review plan fees and note growth over time. Conducting periodic fee benchmarking analyses will give plan fiduciaries a better sense of the competitiveness of their asset-based or per-participant fees, particularly when accounting for the value of the services provided. Finally, conducting a recordkeeper RFP periodically will also help gauge what other recordkeepers would charge to service the plan, and thus assist the plan sponsor in negotiating the most competitive fees. To learn more about fee allocation as a fiduciary breach lawsuit topic, click here.

Too Many Investment Options
A frequent issue cited in the lawsuits is that the retirement plan offers too many investment options. In the lawsuits where this issue has been identified, there has been a consistent claim that “Defendants provided a dizzying array of duplicative funds.”(1) In addition to causing confusion for participants, too many investment choices can lead to “analysis paralysis,” ultimately reducing participation. Also, since some investment managers offer a better pricing structure to retirement plans as more assets are allocated to their investments, the distribution of plan assets among a large number of investment options can mean that the plan and participants do not receive the benefit of these price breaks within the funds. While the lawsuit claims have largely failed to implicate the plan sponsor for imprudent oversight of the plan, they raise reasonable questions about whether or not having too many investment options could reduce participation or force the plan to use higher cost share classes of investments. If the plan sponsor’s objective is to provide employees with an opportunity to accumulate assets for retirement through a competitive program, limiting the number of investments to a reasonable range (typically, fewer than thirty) can enable participants to have a better understanding of their options and empower them to make thoughtful allocation decisions. To read more about this issue, click here.
Multiple Active Recordkeepers
Another common thread among the institutions sued over their retirement plans is that they had multiple recordkeepers available for active participant contributions. According to the lawsuits, having multiple providers allegedly led to significantly higher recordkeeping fees and subsequently lowered the account accumulations for the plan participants. In general, retirement plans may experience higher fees as a result of using multiple recordkeepers. In a single recordkeeper environment, the provider receives all the contributions to the plan. However, in a multiple vendor environment, neither vendor collects the full amount. Additionally, the vendor needs to send representatives onsite more often to sell its services, in order to convince participants to use its program. As a result, in a multi-vendor environment, each vendor must spend more resources to collect fewer contributions. This typically leads to the recordkeeper charging higher fees than if they were the exclusive provider. For the participant, having multiple recordkeepers servicing the plan adds to the decision-making process. In addition to deciding whether or not to participate, determining how much to contribute, and in which options to invest their assets, they must also choose from the available recordkeepers. Additional decision points can cause confusion and potentially lower participation. The claim that offering multiple recordkeepers for a retirement plan is a breach of fiduciary responsibilities has met with mixed results. There may be reasons why it is beneficial to offer more than one provider. If one provider is unable to deliver all the services sought by a plan sponsor, it may be necessary to contract with two or more recordkeepers. However, based on the results of these lawsuits, plan sponsors should closely examine their reasons for including more than one provider in their plan. Given the potential for higher fees to be charged by the recordkeepers when more than one is present, the plan sponsor must be able to explain how the multiple provider structure benefits participants, and should be able to demonstrate a regular review of these recordkeepers to show that a multiple provider arrangement remains necessary for the plan. Read the full piece by clicking here.
No Regular Recordkeeper RFPs
A claim incorporated into several of the retirement plan lawsuits is that the plan sponsor did not conduct a regular competitive bidding process through a Request for Proposal (RFP) to obtain the most competitive recordkeeping and administrative services for the plan. An example of the specific language in the claim, which is repeated verbatim in many of the lawsuits, reads, “Defendants also failed to conduct a competitive bidding process for the Plan’s recordkeeping services. A competitive bidding process for the Plan’s recordkeeping services would have produced a reasonable recordkeeping fee for the Plan.” Among the issues we have examined thus far, the claim about fiduciaries failing in their duty of prudence by not conducting RFPs has had the most success for plaintiffs, proceeding past the motion to dismiss more than 70% of the time. While ERISA does not specify the need to conduct an RFP every certain number of years - or ever - the courts have generally acknowledged that competitive bidding processes are good mechanisms for plan sponsors to benchmark the plan and confirm whether or not the fees are appropriate for the services provided. In light of this, plan sponsors should consider conducting an RFP for their plan if one has not been done in the last several years, both to protect themselves from a fiduciary perspective, but also to ensure they are receiving value for their plan fees and delivering enhanced benefits to their participants. To read the article in its entirety, click here.
With the reach of litigation expanding to include organizations of different sizes across a variety of industries, plan sponsors should be cognizant of the issues raised by the lawsuits and stay abreast of developments. By carefully examining their plans, addressing any issues, and ensuring a proper, well-documented fiduciary process is in place, plan sponsors may be able to protect themselves from becoming the next retirement plan lawsuit target. Earl W. Allen, MBA, CEBS, Cammack Retirement, November 25, 2019.
More than 463,000 Floridians have enrolled for coverage in 2020. More are expected before the Dec. 15 deadline.
Florida is again surging ahead in Affordable Care Act sign ups, with nearly half a million people opting for coverage three weeks into the enrollment period. Since Nov. 1, when the period began, 463,066 Floridians have signed up for health insurance next year under the act, commonly known as Obamacare, according to the Center for Medicare and Medicaid Services. The agency tracks enrollment in the 39 states that use the federal exchange. Nationally, nearly 1.7 million Americans have signed up for Obamacare health plans that will cover them in 2020. Advocates of the program say they are confident Florida will once again lead the nation in open enrollment signs ups. The period ends Dec. 15. “For Florida, it’s working. There are people here who need health insurance, and this is their option,” said Jodi Ray, executive director of Florida Covering Kids & Families, a navigator program based at the University of South Florida. “We try to tell people that it’s worth taking a look and shopping around, because 93 percent of people who enroll qualify for tax credits," she said. "Eight-eight percent of people are able to select plans that cost as low as $75 a month.” The USF group used to be one of several in the state to receive federal funding for open enrollment marketing and consumer assistance. Last year, it became the state’s sole support service, and its budget was cut by 80 percent. Despite a dip in enrollment nationally, Florida saw record sign ups last year. Nearly 1.8 million people enrolled for 2019, the most of any of the 39 states that use the exchange. That was up over the 1.7 million Floridians who signed up the previous year. The state with the second-most sign ups so far this year is Texas with 229,167. Georgia is third with 105,653. During an outreach event early this month at USF in Tampa, Brittney Miller signed up for Affordable Care Act coverage for the second year in a row. Miller, 30, owns Skin Radiance Med Spa in Tampa. As a single mother, she said, it was hard to find affordable health insurance for herself, so she went without it for awhile. “After my divorce, I went a full year without any insurance, which is of course when I had a bunch of issues,” Miller said. “As my own boss, I don’t have any other options. I had to find a plan for myself.” That’s why she looked into the federal exchange. Last year was the first year she enrolled under the Affordable Care Act. Her 2019 plan was affordable and covered all her needs, she said. Miller was planning to re-enroll in the same plan when a navigator with USF showed her a few other options. “I was really happy with what I had last year, but my needs were slightly different this year,” she said. “I wanted vision, and found a plan that had that and more for a cheaper price.” She paid around $50 a month in premiums last year. Without subsidies, the plan was nearly $400 a month, which she said she wouldn’t be able to afford. “It can be a really overwhelming process to find a plan that fits your needs,” she said. “There are so many options out there and there is a deadline. It’s easy to get busy and put it off, but I try to tell as many people as I can that this is really good option.” Not everyone has managed to find an affordable plan. Nearly 2.7 Florida residents do not have health insurance. Many earn too much to qualify for a subsidized plan under the Affordable Care Act. In a recent survey of Florida adults, 56 percent said the primary reason they went uncovered was the cost. And 72 percent agreed that the U.S. health care care system “needs to change.” The results were released in September by Altarum, a nonprofit research and consulting group with support from the Robert Wood Johnson Foundation. At the recent USF event, John Kyle Rohde, 50, from Safety Harbor signed up for an Obamacare plan for the fifth year in a row. “Until they started the ACA, I never had health insurance in my life,” said Rohde, a musician who performs in beach bars and restaurants around Pinellas County. “I could never afford it.” He relied on walk-in clinics mostly for care, and paid cash out of his pocket. “I tried not to go to the ER, but a couple of times I had to. Those bills kill you,” Rohde said. He said he was surprised by how affordable the plans were when he first enrolled. His plan costs him about $120 a month with subsidies. “I think the stigma around Obamacare is silly," Rohde said. "I have family members who won’t check it out just because of that. It doesn’t hurt to check it out and see what you can get.”
Obamacare open enrollment

  • Ends Dec. 15.
  • Even if you’ve already enrolled in a marketplace plan, it’s important to update personal information to ensure the best tax credit and premium prices.
  • Book appointments for in-person, virtual or phone assistance with Covering Florida by calling 877-813-9115 or visit coveringflorida.org.
  • The Family Healthcare Foundation will host face-to-face appointments at the St. Petersburg Library and the Hunt Center in Tampa every Saturday during open enrollment. For more information call 877-813-9115 or (813) 995-1066. Appointments can be scheduled online at Familyhealthcarefdn.org/enroll.

Justine Griffin, Medical Reporter, Tampa Bay Times, November 22, 2019.
The Internal Revenue Service recently awarded more than $9.8 million in Tax Counseling for the Elderly (TCE) grants to organizations that provide free federal tax return preparation. This year, the IRS awarded grants to 27 TCE applicants from across the nation (PDF). The TCE grants cover one year. The IRS received 37 applications requesting $11.7 million. The TCE program, established in 1978, provides tax counseling and return preparation nationwide to people who are 60 or older. Volunteers receive training and technical assistance. The IRS forms partnerships with a wide variety of organizations across the country to develop TCE programs. Community partners include non-profit agencies, faith-based organizations and community centers. The IRS provides tax law training, certification and oversight to equip these organizations to prepare accurate returns. For information on applying for the TCE program, visit the TCE webpage. For details on becoming a TCE volunteer, visit IRS Tax Volunteers. IR-2019-188, IRS.gov, November 22, 2019.
To build a more effective set of solutions for the spending down of retirement plan assets, plan sponsors must first come to understand what their participants are doing today. In a recent conversation with PLANSPONSOR, Peg Knox, chief operating officer of the Defined Contribution Institutional Investment Association (DCIIA), highlighted a new series of white papers her organization has published on the topic of building a better “retirement tier.” By “retirement tier,” Knox and DCIIA are referring to a range of products, solutions, tools and services, all designed in coordination to allow a defined contribution (DC) plan sponsor to broaden the plan’s goal from one wholly focused on savings to one that also accommodates and supports participants who are near, entering, or in retirement. Knox said she is particularly proud of the actionable items included in the white paper series, such as a set of form letters plan sponsors can send to their recordkeepers to start generating useful information about retirees’ and near-retirees’ behaviors. DCIIA has also put together a downloadable set of data spreadsheets that plan sponsors can hand directly to their recordkeepers to learn the key information that is needed to build the retirement tier. According to DCIIA, these spreadsheets can be used to generate a “money out” report, a withdrawal options review, and a plan demographics review. According to Knox, plan sponsors looking to build a retirement tier can start in one of two places. “Some plan sponsors will want to start by reviewing the options and services that are currently part of their plan to understand how, and to what degree, they already support the retirement tier concept,” Knox explained. “Others may choose to begin by looking at the bigger picture, broadly defining objectives for how to best serve this group of participants who are near, at, and in retirement.” To be successful in this area, ultimately plan sponsors will need to do both, at least to some degree. “Just analyzing what your participants are doing can be so informative,” Knox said. “Even if you only offer a lump sum today, it’s still important to know whether your plan population is rolling into an IRA or whether they are cashing out. This is the foundation you can use to make decision about the retirement tier.” Knox advised that, from the very beginning, plan sponsors need to decide if they even want retirees in their plan. “It’s going to come down to every individual employer as matter of philosophy and practicality,” Knox said. “Increasingly, I think, most large plan sponsors want employees to stay, but I don’t know if all of them feel like they should be advertising this to participants. Some sponsors consciously choose to be more neutral about what retirees should do, even though they understand the benefits of keeping people in the plan.” DCIIA’s white papers urge plan sponsors to re-evaluate their plan’s documents through the lens of participants nearing the end of their active working years, specifically its distribution or “money out” options, to see how the plan’s near-retirees and retirees can access their money. As Knox explained, part of assessing the money out options is to evaluate how participants’ money can leave the plan in the first place. Another key step is to evaluate a plan’s demographics, to see not only how many participants might benefit from a retirement tier’s offerings, but also how near to retirement many of them are, and to take a macro look at the company’s recent retirement patterns. “Again, much of this work can be generated by your service providers and should not require extensive heavy lifting on the plan sponsor’s behalf,” Knox said. In terms of questions sponsors should ask of themselves, the following should be considered, according to DCIIA: “Whom do you want your plan’s retirement tier to help, and why? Do you want to encourage participants who separate from service due to retirement to stay in the plan? How much time and expense do you really want to focus on the tier? Are you open to helping participants, and their spouses, beyond just offering liquid investment options? For example, are you open to advice solutions? Are you open to products with guarantees? Are you open to adding a periodic withdrawal service?” Only once a plan sponsor has determined what they want their role to be in helping participants who are near or in retirement can the employer move on to identifying what additional products, tools or services should be a part of the plan’s retirement tier. “There is no one option that will meet the needs of every participant in this cohort, since participants’ needs vary greatly in retirement,” Knox warned. By starting with existing service providers, Knox explained, a sponsor may identify relatively easy initial steps to take--as simple as leveraging tools and products that your service providers already offer. From here, a plan sponsor might reasonably do a gap analysis of what further options and services to add to the plan’s retirement tier, compared with what can already be leveraged from those offered by existing service providers. John Manganaro, Plansponsor, November 22, 2019.
U.S. corporate pension plan buyout sales totaled $7.7 billion in the third quarter, a LIMRA Secure Retirement Institute sales survey found. The amount for the quarter was up 22% from the third quarter of 2018, when buyout sales totaled $6.3 billion. Pension plan buyout sales for the first nine months of 2019 totaled $16.7 billion, up 5% from the $15.9 billion in sales during the same period in 2018. The first and second quarters of 2019 saw $4.8 billion and $4.2 billion, respectively, in pension plan buyout sales. "This quarter marked the highest third-quarter sales for pension buyout products since we have been tracking this market” beginning in 1986, said Mark Paracer, assistant research director at the LIMRA Secure Retirement Institute, in a news release. "While there was a substantial contract reported this quarter, we also saw a high number of mid-sized contracts that drove the overall growth." Bristol-Myers Squibb Co., New York, completed the largest buyout during the third quarter, transferring $2.4 billion in pension plan liabilities to Athene Annuity and Life Co. to complete a full termination of the plan originally announced in December 2018. The survey reported a total of 111 new buyout contracts sold in the quarter ended Sept. 30, bringing the total for the first nine months of the year to 301 contracts. LIMRA reported 281 contracts sold in the first nine months of 2018. LIMRA surveyed the 17 financial services companies that provide all the group annuity contracts for U.S. corporate pension plans. Rob Kozlowski, Pension & Investments, November 21, 2019.
If you want to be successful, it's just this simple. Know what you are doing. Love what you are doing. And believe in what you are doing.
When everything seems to be going against you, remember that the airplane takes off against the wind, not with it. - Henry Ford
On this day in 1933, Prohibition ends in the U.S. when 21st Amendment to the U.S. Constitution ratified, 18th Amendment repealed (5:32 PM EST)

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Items in this Newsletter may be excerpts or summaries of original or secondary source material, and may have been reorganized for clarity and brevity. This Newsletter is general in nature and is not intended to provide specific legal or other advice.

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