April 04, 2013

Hudson Institute: "The Charitable Deduction in American Political Thought"

Hudson Institute

The Hudson Institute's Bradley Center for Philanthropy and Civic Renewal presents in Washington, DC on Tuesday, April 16th a lunchtime discussion on the charitable contribution deduction.  Registration and further details available online.  Here is the agenda:

Program and Panel

11:30 a.m.
Registration, lunch buffet

12:00 p.m.
Introduction by Bradley Center Director William Schambra

12:10
Panel discussion
Stanley Katz, Professor of Public and International Affairs at Princeton University
Rob Reich, Associate Professor at Stanford University
Alex Reid, Counsel in Morgan Lewis’s Tax Practice

1:10
Question-and-answer session

1:30
Adjournment

LHM

April 4, 2013 in Conferences | Permalink | Comments (0) | TrackBack

April 03, 2013

Urban Institute Hosts "Charity and Government: Tax Reform and Beyond"

Urban instituteThe Urban Institute will be hosting in Washington, DC on Monday, April 15th a conference titled Charity and Government: Tax Reform and Beyond.  Registration is required.  The conference is co-sponsored by the Urban Institute's Center on Nonprofits and Philanthropy and the Alliance for Charitable Reform.

Here is the agenda and the presenters:

9:30am-10:40am
Session One: As an Independent Sector, Is Charity a Substitute, Complement, Adversary, or Something Else for Government?

Moderator: Eugene Tempel, Indiana University
Speakers: Adam Parachin, University of Western Ontario, Eugene Steuerle, Urban Institute, Joseph Thorndike, Tax Analysts, University of Virginia

10:40am-11:50am
Session Two: What Is the Definition of Charity, and Who Decides How to Define It?

Moderator: John Tyler, Kauffman Foundation
Speakers: Bradford Gray, Urban Institute, Daniel Halperin, Harvard Law School, Alex Reid, of counsel, Morgan Lewis, Marion Fremont-Smith, Hauser Center for Nonprofit Organizations, Harvard University

11:50am-12:20pm: Lunch

12:20pm-1:30pm
Session Three: Philanthropy’s Relationship to Current Policy Debate

Moderator: Elizabeth Boris, Urban Institute
Speakers: Arthur Brooks, American Enterprise Institute, Joanne Florino, Philanthropy Roundtable, William Galston, Brookings Institution, Pat Read, consultant

LHM

April 3, 2013 in Conferences | Permalink | Comments (0) | TrackBack

February 15, 2013

Columbia Law School Hosts Conference on The Future of State Charities Regulation

Columbia Law SchoolI was fortunate enough to be invited to present at a conference hosted by Columbia Law School's Charities Law Project last week.  Featuring presentations and draft papers (available on the conference website) from a who's who list of charity law experts from the academy, state AG offices and other agencies, and private practice, the conference provided an incredible opportunity to consider and discuss emerging issues in the regulation of charities.  Topics covered included:

The conference organizers also gathered an extensive set of additional resources that will be helpful to anyone interested in the conference topics.

LHM

February 15, 2013 in Conferences, Paper Presentations and Seminars | Permalink | Comments (0) | TrackBack

December 28, 2012

Critical Tax Conference (Hastings) Call for Papers

UC Hastings has issued a call for papers for the 16th Critical Tax Theory Conference, which will be held in April 2013.  For more information, see the TaxProf blog post about the call.

LHM

December 28, 2012 in Conferences | Permalink | Comments (0) | TrackBack

September 28, 2012

Emerging Issues in Social Enterprise Conference (Regent University Law Review)

Symposium2012 (1)

Regent University Law Review is hosting a symposium on Emerging Issues in Social Enterprise on Saturday, October 6th, in Virginia Beach, Virginia.  Panelists include Dana Brakman Reiser (Brooklyn), Cassady V. Brewer (Georgia State), Lyman P.Q. Johnson (Washington & Lee/University of St. Thomas), and Marcia Narine (Missouri-Kansas).  Here is the full description of the event:

For private profit and for the public good. Social enterprise attempts to harness the power of the for-profit market to achieve social and environmental ends. In the wake of the recent financial crisis, interest in social enterprise has increased exponentially. Over the last four years, 18 states (including Maryland, North Carolina, and Virginia) have passed statutes allowing the formation of benefit corporations, benefit limited liability companies, low-profit limited liability companies (L3Cs), social purpose corporations, and flexible purpose corporations. While the population of these entities is growing, the mere existence of these business formations is hotly-debated within the corporate law community

Practitioners, professors, students, and business owners are encouraged to attend this exciting event that promises to be an informative and helpful exploration of the developing issues related to social enterprise entities.

Our Symposium will include two morning panels featuring four distinguished academics who will present papers on the benefits, disadvantages, and implications of social enterprise entities. After their presentations, these panelists will engage in a moderated discussion, followed by a question and answer time with the audience.

In the afternoon workshop, several legal practitioners and business owners will share their experience working in the field of social enterprise and will offer practical advice on working with these new corporate entities. Additionally, this workshop will provide an overview of the various forms of social enterprise entities, and will address the Virginia-specific start-up procedures and liability implications.

LHM

 

September 28, 2012 in Conferences | Permalink | Comments (0) | TrackBack

August 20, 2012

Churches, Money and Tax Exemption

An article posted in today's Chicago Tribune digital edition (free subscription required), which appears to have originally come from the Economist, is a very interesting look at the finances and financial management of the Catholic Church in America.   Using data from bankruptcy filings by dioceses that faced large damage awards over sexual abuse, the article paints a picture of financial mismanagement, if not skulduggery.  One paragraph sort of sums it up:

The picture that emerges is not flattering. The church’s finances look poorly co-ordinated considering (or perhaps because of) their complexity. The management of money is often sloppy. And some parts of the church have indulged in ungainly financial contortions in some cases--it is alleged--both to divert funds away from uses intended by donors and to frustrate creditors with legitimate claims, including its own nuns and priests. The dioceses that have filed for bankruptcy may not be typical of the church as a whole. But given the overall lack of openness there is no way of knowing to what extent they are outliers. 

The last sentence is, I think, particularly important.  Churches do not have to file a Form 990 or an application for exemption on Form 1023.  We know virtually nothing about how they manage their money, yet we grant tax exemption virtually automatically to any entity calling itself a church.  

Others have questioned whether churches should receive tax exemption at all (I happen to be in the camp that says "no," provided they get an unlimited deduction for what I would classify as charitable expenditures, which would not include building expenses/maintenance/pastor and staff salaries, etc. - but I realize this is an issue on which reasonable people can and should disagree).   But I view this story as less about the merits of exemption than the merits of financial disclosure by exempt charities.   Churches need to file a 990 like everyone else.  We need disinfecting sunlight on their financial operations, particularly when folks starting hiding behind God as the rationale for their actions, many of which end up being very un-god-like.  And for those of you who might claim that subjecting churches to information filing on a 990 is a violation of the free exercise clause . . . well, I'd like to see that case litigated.

JDC

 

August 20, 2012 in Conferences | Permalink | Comments (0) | TrackBack

August 02, 2012

Columbia Law School Charities Project Releases Two New Webinars for Public Viewing

The Columbia Law School Charities Project has released two new webinars for public viewing: “The IRS and Charities Regulation: A Primer,” and “Social Enterprise and Hybrid Corporate Forms: Emerging State Regulatory Perspectives and Responses.”  According to the Charities Project, the webinars are designed to help inform the nonprofit sector, regulators, practitioners and academics about topical issues at the intersection of state regulation and the charitable sector.

VEJ 
 

August 2, 2012 in Church and State, Conferences, Current Affairs | Permalink | Comments (0) | TrackBack

June 18, 2012

Law, Society & Taxation Nonprofit Panel & Papers

The Law and Society Association's 2012 International Meeting in Honolulu earlier this month featured the following panel and additional papers relating to nonprofits:

LHM

June 18, 2012 in Conferences, Paper Presentations and Seminars | Permalink | Comments (0) | TrackBack

Call for Papers from Columbia Law School Charities Law Project

The Charities Regulation and Oversight Project, which is part of the National State Attorneys General Program at Columbia Law School, has issued a call for papers for its February 2013 conference "The Future of State Charities Regulation".  Here are the details:

The Charities Regulation and Oversight Project of the National State Attorneys General Program at Columbia Law School will host the 2013 Charities Regulation Policy Conference: “The Future of State Charities Regulation and Enforcement”, to be held on February 7th & 8th, 2013, at Columbia Law School in New York City. The 2013 conference will be the third major policy conference at Columbia Law School devoted to issues regarding state regulation, oversight and enforcement of the charitable and nonprofit sector. Developed in partnership with the National Attorneys General Training and Research Institute, the conference will address the complex issues surrounding the current status, and the future trajectory of, state regulation of the charitable sector.
 
The 2013 conference is intended to promote dialogue among regulators, leaders from the sector, practitioners and academics regarding challenges confronting state regulation of the sector and to develop proposals for improvement.
 
Anticipated topics include the state/federal relationship; structure and funding of state charities officials; the fundamental role of states in governance issues; challenges and interest of the states in social mission/hybrid corporate organizations; the role of states in nonprofit healthcare; changing landscape of state-based charitable solicitation; jurisdiction over religious organizations; interstate and international jurisdiction; emerging issues surrounding advocacy and political activity by the sector. The Charities Project seeks a diverse range of perspectives for the conference; paper submissions are encouraged from practitioners, regulators, leaders from the sector itself and academics. Proposal abstracts, no more than one page in length, should be sent to charities@law.columbia.edu by July 13, 2012. Drafts for final papers for the conference should be approximately 5000 words.
 
Please contact Frances Laviscount Program Coordinator, at flavis@law.columbia.edu or 212-851-1061 with any questions regarding the conference or paper submissions.
LHM

June 18, 2012 in Conferences, Paper Presentations and Seminars | Permalink | Comments (0) | TrackBack

April 19, 2012

Correlation Between Nonprofit Governance and Tax-Exempt Compliance

In her remarks to the Georgetown University Law Center program on Representing and Managing Tax-Exempt Organizations, IRS Exempt Organizations Director Lois Lerner discussed the findings of an IRS study of its governance checksheet, which is comprised of a list of questions used by IRS agents to determine the governance practices of an exempt organization. In October 2009, IRS agents began completing the checksheet at the completion of every public charity examination.  The result is over 1300 checksheets that were examined as part of the study. 

The study's analysis found "a statistically significant correlation between questions related to some governance practices and tax compliance."  The correlative questions are, in Lerner's words: 

1.    Organizations with a written mission statement are more likely to be compliant;

2.    Organizations that always use comparability data when making compensation decisions are more likely to be compliant;

3.    Organizations with procedures in place for the proper use of charitable assets are more likely to be compliant; and

4.    Organizations where the 990 was reviewed by the entire board of directors are more likely to be compliant.  This is an important point and one I'd like to highlight.  It indicates that having your entire board engaged in what is being reported on the 990 is not only helpful, but it correlates to better compliance.

Lerner also stated that "[o]n the flip side, among the organizations we examined, we saw that those that said control was concentrated in one individual, or in a small, select group of individuals, were less likely to be tax compliant."

Diversion of Assets Initiative:  Lerner also announced a new audit initiative focusing on tax-exempts that divert their assets for their own use or for uses not in furtherance of their charitable purposes.  Lerner reported that approximately $170 million in assets were diverted in instances involving theft, embezzlement, or Ponzi schemes.  With respect to 82 organizations, civil or criminal charges were brought against the responsible party. The charges were typically pursued by the organizations themselves or local authorities, not the IRS. The IRS compiled this information from Forms 990 as well as the internet and other publicly-available information.

(For additional discussion:  Daily Tax Report)

NAM

April 19, 2012 in Conferences, Federal – Executive | Permalink | Comments (0) | TrackBack

Prompt Action by Nonprofit Board Members Key to Avoiding Fiduciary Liability

As reported by the Daily Tax Report, at a Georgetown University Law Center program yesterday on Nonprofit Governance, Missouri Attorney General Bob Carlson provided simple advice - nonprofit boards can avoid potential legal liability for a breach of fidicuary duties if their reaction to such breach "is quick and shows immediate action."  Carlson provided the example of a nonprofit executive director that failed to share financial information with the board of the directors, resulting in the board being completely unaware of the organization's near collapse.  Upon learning of the dire financial status of the organization, the board immediately fired the executive director, installed an interim director, “and essentially righted the ship on the fly, so the organization did not go under.”  Their prompt reaction, opined Carlson, prevented them from being sued.  Carlson stated that he typically gives Board members the opportunity to correct a fiduciary problem, and only pursues lawsuits if there is not a sufficient response. 

Along with IRS Exempt Organizations Director Lois Lerner, Carlson advised erring on the side of transparency, with both officials providing examples of items that nonprofits should considered posting to their websites:  financial statements, executive compensation, and the minutes of meetings.  He believes that more transparency ultimately leads to better fundraising ability, because donors often complain about their lack of knowledge with respect to the use of their donations.  Both Carlson and Lerner agreed that recruiting and retaining "engaged" board members is essential to smooth operations and avoidance of trouble.  In addition, board knowledge of its governance responsibilities leads to overall better decisionmaking.

NOTE:  Lerner advised that the IRS will release the preliminary results of its study of governance on April 19, 2012.

NAM

April 19, 2012 in Conferences, Federal – Executive, State – Executive | Permalink | Comments (0) | TrackBack

April 03, 2012

Social Enterprise Conference at Harvard

Those of you who follow the Social Enterprise movement will be happy to know that there was an interesting-looking SE conference last week sponsored by students at the Harvard Business School and the Harvard Kennedy School of Government.  Two quick observations. 

First, the existence of an SE conference does not fit with my somewaht distant memory of Harvard B-School students.  I remember them in the 1980s preening at the Boat House bar in Cambridge boasting about how wealthy they were going to be.  Things have changed, I guess.

Second, the conference website reports that it included "1,500 Engaged Attendees, 75 Innovative Speakers and Presenters, 40 Vibrant panels and Workshops, and 4 Thought-Provoking Keynotes."  Having perused the conference brochure, I can confirm that it seems to have been a dynamic gathering; however, such over-reliance on adjectives (and exclamation points!!) leaves the young social entrepreneurs open to additional razzing about the language they use and the charge that the whole movement is marketing rather than evolutionary change.

TAK

April 3, 2012 in Conferences, Current Affairs | Permalink | Comments (0) | TrackBack

October 13, 2011

Kentucky "Politics, Taxes, and the Pulpit" Conference

The University of Kentucky College of Law hosted yesterday a conference on the recent book Politics, Taxes, and the Pulpit: Provocative First Amendment Conflicts authored by Nina J. Crimm (St. John's) and Laurence H. Winer (Arizona State).  Commentators were Dean David A. Brennen, Joshua A. Douglas (Kentucky), Rev. Nancy Jo Kemper (Transylvania University) and Paul E. Salamanca (Kentucky).  The book is a comprehensive consideration of the constitutional and federal tax issues raised by religious leaders preaching politics from the pulpit and includes thought-provoking proposals for lessening the constitutional tensions in this area.

LHM

October 13, 2011 in Books, Church and State, Conferences | Permalink | Comments (0) | TrackBack

May 11, 2011

ABA Tax Section Meetings - Roundup

The Daily Tax Report reports on the Treasury, IRS, and Congressional staff representatives' updates on exempt organizations at the ABA Tax Section meetings in Washington, DC at the end of last week.

Program-Related Investments

Treasury attorney-adviser Ruth Madrigal provided updates on the guidance regarding program-related investments for private foundations under IRS §4944 (excise tax on jeopardy investments), stating that Treasury is considering "the double bottom line," "doing well by doing good," and "impact investing" as part of the guidance.  Program-related investments are being considered as a vehicle for redirecting charitable donations into communities.

Health Care

Guidance projects related to health care reform include the exemption of accountable care organizations and the provision of insurance thorugh exempt health care exchanges.

Remaining projects from the Pension Protection Act include Type III supporting organizations, §4943 excess business holding rules, and donor-advised funds.

Exempt Org-Related Legislation

A Senate Finance Committee staffer discussed proposed hearings on exempt organizations with respect to tax reform, including making permanent certain temporary provisions applying to exempts, a limitation on the amount of charitable donations a taxpayer can itemize, and a flat excise tax on private foundations (which is included in President Obama's 2012 proposed budget).

Joint Tax Committee tax legislative counsel, Gordon Clay, opined that the defintion of "charity" has been substantially broadened over the years, raising the question of whether "preferential treatment should be given to exempts that engage in the traditional helping the poor-type purposes."  In addition, the commerciality doctrine (exempts with a direct taxable counterpart) continues to rear its ugly head, raising the viability of exemption for organizations plagued with that problem.

NAM 

May 11, 2011 in Conferences, Federal – Executive, Federal – Legislative | Permalink | Comments (0) | TrackBack

February 02, 2011

Senator Dick Durbin Challenges Nonprofit Higher Education to Be More Aggressive Against For-Profit Higher Education; And To Clean Their Own Houses While They Are At it!

    "And I’m not talking only about low-performing for-profit colleges. There are public colleges and private non-profit colleges that are also failing their students.  It is time for a serious conversation about the cost and quality of our higher education system.  It’s time to question why we allow some colleges to continue to take in new students when they only graduate 15 or 16 percent of students, year after year.  It’s time to question rising tuition and rising student loan debt when students aren’t seeing improvements in outcomes.  And it’s time for a serious conversation about a new study that found that nearly half of college students showed no significant improvement in critical thinking, complex reasoning and writing by the end of their sophomore years. And that one-third of students did not take a single course requiring even 40 pages of reading per week."

Bloomberg News reports today that in a speech before the National Association of Independent Colleges and Universities yesterday, Senator Dick Durbin challenged the nonprofit higher education community to resist efforts by for-profit higher education lobbyist to sidetrack legislative efforts aimed at for profit higher education.  

Durbin, an Illinois Democrat, has criticized for-profit institutions, saying they fail to prepare students for jobs and saddle them with debt. For-profit colleges such as Apollo Group Inc.’s University of Phoenix, DeVry Inc. and Washington Post Co.’s Kaplan University received 25 percent of Pell Grants, federal aid to students based on financial need. The maximum Pell Grant for the 2010-11 award year is $5,550.

Traditional, nonprofit Law schools and graduate schools are currently confronting accusations from everywhere that they produce too many J.D.'s and P.hD's, for too few jobs and too much debt.  Even further, law schools are everywhere engaged in soul searching regarding the extent to which they actually or adequately prepare graduates for the practice of law.  Prominent people within the legal academy are explicitly stating that law school is a losing investment.  So we should be careful in attributing failures to the for profit or nonprofit status of higher education. Here is a further excerpt from Durbin's speech (the full text of which is linked above):

For-profit colleges are the fastest-growing segment of higher education. In the last 10 years, enrollment at for-profit institutions has grown 225 percent.  For-profit colleges are also consuming a disproportionate share of federal financial aid dollars.  Think about this: Last year, the top three recipients of federal student aid -- the University of Phoenix, DeVry and Kaplan University – were all for-profit colleges. For-profit schools educate less than 10 percent of all college students, but receive 25 percent of all Pell grants.  They also educate 23 percent of all students attending college on the Post 9/11 GI Bill, but they account for 36 percent of the Post 9/11 GI Bill funds.  All told, for-profit colleges receive an average of 77 percent of their revenue from federal loans and grants. If you include funds from the new GI Bill and other military tuition programs, it’s more than 90 percent at some schools.  Let me be clear: There are many good for-profit colleges and they serve a vital purpose: supplying education and job training that helps people take the next step up the economic ladder.  Your institutions may even learn from for-profit colleges how to adapt education to better fit the way people live and work today, allowing students to study online and on their own schedule.

But there are also a lot of bad for-profit schools that are raking in huge amounts of federal dollars and leaving students poorly trained and over their heads in debt.  At some schools, students pay $20,000 to $30,000 for an associate’s degree only to learn that their credentials can’t help them find a job. They’re no more employable than they were before but now they’re deep in debt.  Here are some alarming numbers: For-profit colleges make up less than 10 percent of college students – but 44 percent of federal student loans defaults.

I have a brother who, after 20 something years in the Air Force, attended the University of Phoenix, got a degree in computer something or other and is now doing quite well.  His military service paid for his education so he does not have a bunch of student loans to repay.  Anyway, like Durbin I agree that there is a place for for-profit higher education and that federal subsidies are not necessarily wasted at those institutions.  But as it relates to nonprofit, tax exempt status, higher education does no service to the poor if they must mortgage their entire post graduate lives to receive the benefit of higher education.  The rules Durbin argues for regarding outcomes will inevitably and logically apply to the nonprofit higher education sector as well.

dkj

February 2, 2011 in Conferences | Permalink | Comments (0) | TrackBack

October 25, 2010

Governing Civil Society Symposium

Several regular contributors to this blog attended a symposium last Friday at Brooklyn Law School on Governing Civil Society: NGO Accountability, Legitimacy, and Influence.  Brooklyn's International Law Journal will be collecting and publishing the papers (next spring)?  My paper, "Wait! That's Not What We Meant by Civil Society: Questioning the NGO Orthodoxy in West Africa," described how Western efforts to engender civil society in several West African nations has produced unintended consequences as Islamic religious organizations have flooded into (and as often as not taken over) civil society.  One problem with the nascent civil society organizations promoted by the West is that they tend to be run by Western-oriented elites whose interests diverge from those of grassroots citizens and groups.  This is one of the reasons that Islamic organizations have had so much success.  The paper argues that there is not much that we (i.e., the U.S.) can or should do about the situation.  All of the papers were thought provoking, but I particularly enjoyed Gary Jenkins' remarks.  He pointed out that Western insistence on NGO best administrative practices might have the effect of exacerbating the elitism of host country NGOs, rendering them illegitimate in the eyes of the ordinary citizens. (Gary, sorry if I misstated your argument.)

TAK

October 25, 2010 in Conferences, Current Affairs, International | Permalink | Comments (0) | TrackBack

June 13, 2010

Junior Tax Scholars Workshop Exempt Organizations Papers

For the last two days I helped Notre Dame Law School host the fifth annual Junior Tax Scholars Workshop.  Among the papers presented by the attending, pre-tenure law school faculty were the following on exempt organizations topics.  Since these papers are works in progress, public copies are not yet available, but we can expect to see most if not all of them eventually in law reviews.

Miranda Perry Fleischer (University of Colorado), Equality of Opportunity and Charitable Giving  

Benjamin Leff (American), The Case Against For-Profit Charity: An Agency Cost Analysis 

Lloyd Hitoshi Mayer (Notre Dame), Charities and Lobbying: Institutional Rights in the Wake of Citizens United  

Phyllis Smith (Florida A&M), Benevolence v. Bureaucracy: The Impact of Over Regulation of Tax-Exempt Organizations 

Samuel Brunson (Loyola-Chicago), Rethinking Public Charities and Political Speech

LHM

June 13, 2010 in Conferences, Paper Presentations and Seminars | Permalink | Comments (0) | TrackBack

May 26, 2010

Law and Society Conference Nonprofit Papers

A list of "Law, Society, and Taxation" papers relating to taxation that will be presented at the Law and Society Conference in Chicago this weekend includes the following relating to nonprofit organizations:

LHM

May 26, 2010 in Conferences, Paper Presentations and Seminars | Permalink | Comments (0) | TrackBack

April 29, 2010

Abstracts in Response to Call for Papers Due Friday

The Association of American Law Schools Section on Nonprofit and Philanthropy Law has issued a call for papers in connection with the AALS 2011 Annual Meeting in San Francisco, California on “The Federalization of Nonprofit and Charity Law.”  Abstracts are due tomorrow, Friday, April 30, 2010.  Select submission details from the AALS website follow:

The abstract should be accompanied by a cover letter with the author’s name and contact information. The abstract itself must not contain any references that identify the author or the author’s school, but should note if the submitter is a junior faculty member who has been teaching for seven years or less. The submitting author is responsible for taking any steps necessary to redact ALL other self-identifying information.

Form and Length:

Initial submissions should be in the form of abstracts of 1,000 words or less and should note if the submitter is a junior faculty member, but not any other identifying information. Presenters will be chosen based on evaluation of the submitted abstracts.

Contact for submission and inquiries:


Nancy A. McLaughlin
Robert W. Swenson Professor of Law
Associate Dean for Faculty Research and Development
University of Utah SJ Quinney College of Law
332 South 1400 East, Room 101
Salt Lake City, Utah 84112
(801) 581-5944
mclaughlinn@law.utah.edu

JRB

April 29, 2010 in Conferences | Permalink | Comments (0) | TrackBack

April 27, 2010

Council on Foundations Holds Annual Conference

The 2010 annual conference of the Council on Foundations concludes today in Denver.  Plenary speakers at the conference include former Vice President Al Gore and Commissioner of Internal Revenue Douglas Shulman.  Commissioner Shulman’s prepared remarks have been published.    Read more about the conference by visiting the Chronicle of Philanthropy’s Conference Notebook.

JRB

April 27, 2010 in Conferences | Permalink | Comments (0) | TrackBack