OpenLLM-France/wikimedia huggingface dataset:
# Fairfield Plaza, Inc. v. Commissioner

Fairfield Plaza, Inc. v. Commissioner, 39 T.C. 706 (1963) was a case before the United States Tax Court discussing timing alternatives in taxing the return of capital.

## Background
### Facts

The taxpayer purchased a piece of land, divided it into two tracts, and made certain improvements.
The taxpayer sold both of the tracts of land in different years and allocated his basis between the two tracts based upon area. The taxpayer also allocated certain amounts that had been placed into escrow between the two tracts. The amounts in escrow were for improvements to the tract that was sold last.

### Tax return

The IRS determined that the taxpayer improperly allocated these allocations in its tax return.

#### Issues

The taxpayer challenged the IRS's determination, claiming that the IRS erroneously determined the proper allocation of his basis between the two tracts of land and that the IRS erroneously allocated the amounts that were placed in escrow for improvements between the two tracts of land.

## Opinion of the court

The court affirmed, finding that the allocation of basis was not proper within the meaning of Treas. Reg. § 1.61-6, reasoning that:
* the relative values of the two tracts were different
* the tract that was sold last was of a greater value
* the taxpayer was not entitled to allocate the amounts placed into escrow between the two tracts of land. The court reasoned that the amounts in question were used for improvements to the tract that was sold last.
# Tyrannus (disambiguation)

Tyrannus is a genus of large insect-eating birds, commonly known as kingbirds.
Tyrannus may also refer to:
* Tyrannus, an owner of a lecture hall at Ephesus, mentioned in the biblical Acts of the Apostles (19:9)
* Tyrannus (comics), a fictional character who is a supervillain in Marvel Comics' The Incredible Hulk
* Tyrannus, a fictitious gladiator in the 2005 TV series Empire
* Tyrannus, a son of Pterelaus, king of the Taphians, in Greek mythology
* Tyrannus, a 5th-century bishop of Germanicopolis in Isauria, Asia Minor
* Darth Tyranus, a Sith Lord and a former Jedi in the prequel Star Wars trilogies, better known as Count Dooku
# John V Sarugoyo

John IV Sarugoyo was the Maphrian of the East of the Syriac Orthodox Church, from 1164 until his death in 1189.

## Biography

From 1180 to 1204, the church suffered from division as Theodore Bar Wahbun, Karim Bar Masih, and their supporters attempted to usurp the patriarchal office from the patriarch Michael I Rabo. Having been forced to flee Mardin, Theodore and Karim travelled to the Monastery of Mar Mattai near Mosul to attempt to convince John to support his claim to the patriarchal office, but he refused.
Theodore and Karim travelled throughout Upper Mesopotamia as they attempted to gather supporters and later arranged to meet with dignitaries of Michael I Rabo in Dara. Upon learning that the usurpers were in Dara, John and several bishops travelled there, captured, and brought them before the patriarch in the Monastery of Mar Barsoum near Melitene. They later escaped the monastery and continued to disrupt the church beyond John's death in 1189 and Karim later had himself ordained as maphrian without the authorisation of Michael I, and assumed the name Dionysius.
# Jiang Heping

Senior Editor Jiang Heping (Chinese: 江和平; pinyin: Jiāng Hépíng) is a prominent executive at China Central Television (CCTV), the state broadcaster of the People's Republic of China. He is responsible for sport coverage in his roles as Executive Director of the CCTV Sports Programming Centre and Controller of CCTV-5, its national sports channel, and played a key role in the broadcasting of the 2008 Summer Olympics in Beijing.

## Career

Senior Editor Jiang was born on January 7, 1963, in Tongchen, Anhui province. Jiang studied English language and international journalism at Shanghai International Studies University. He graduated in July 1987. Jiang is a member of the Chinese Communist Party. He was assigned to work at CCTV's International News Division, rising to become deputy editor and editor from 1990 to 1996. He introduced new programming, including the division's first live news bulletins. In February 1996 he was appointed deputy director of the News Department, and was permitted to take an MA in Journalism at the University of Wales, Cardiff from September 1996 to September 1997, funded by the British government. He moved to become deputy director of the Foreign Language News Department in 1998, and was promoted to director in May 2000. In this role, he oversaw the launch of CCTV-9. In April 2003, he became deputy head of CCTV's Overseas Service and Controller of CCTV-9. He oversaw a relaunch of this channel, the launch of a new French/Spanish channel (CCTV-E&F) and increased availability of CCTV services in North America (Great Wall TV).
In May 2005, he became deputy director and acting director of the CCTV Sports Programming Centre. Six months later his appointment as director was confirmed, and in July 2006 he took over direct responsibility for CCTV-5. During the 2006 football World Cup, he was involved in the Huang Jianxiang controversy. Since then, he has been reshaping the channel in preparation for the 2008 Summer Olympics.

## Publications

* Jiang Heping (2005). "Window on China and the World: CCTV-9". In Sucharita S. Eashwar (ed.). Asia Media Summit 2005: Promoting Peace and Prosperity in a Globalised World (PDF). Asia-Pacific Institute for Broadcasting Development. ISBN 983-41053-3-9. Archived from the original (PDF) on 2007-11-29. Retrieved 2007-09-13.
# Jimmie Dorsey (sport shooter)

Jimmie Dorsey (born August 28, 1940) is an American former sports shooter. He competed in the 50 metre pistol event at the 1972 Summer Olympics.
# Sabatia

Sabatia, the rose gentians, is a genus of about 20 species of flowering plants in the family Gentianaceae, native to eastern and central North America (Nova Scotia west to Wisconsin and New Mexico, and south to Florida and Texas), Central America, and the Caribbean.
They are annual or perennial herbaceous plants growing to 10–130 cm tall, with opposite leaves. The flowers are produced in large cymes at the top of the stems; the flower corolla has 5–12 lobes, colored pink or white, with a contrasting central yellow 'eye'. The fruit is a capsule containing numerous small seeds.

## Selected species

Source: USDA, Arkansas Native Plant Society
* Sabatia angularis
* Sabatia arenicola
* Sabatia arkansana
* Sabatia bartramii
* Sabatia brachiata
* Sabatia brevifolia
* Sabatia calycina
* Sabatia campanulata
* Sabatia campestris
* Sabatia capitata
* Sabatia difformis
* Sabatia dodecandra
* Sabatia formosa
* Sabatia gentianoides
* Sabatia grandiflora
* Sabatia kennedyana
* Sabatia macrophylla
* Sabatia quadrangula
* Sabatia stellaris

## Cultivation and uses

Several species are cultivated as ornamental plants in gardens.
# Jim Fouché

Jacobus Johannes "Jim" Fouché, DMS (6 June 1898 – 23 September 1980), also known as J. J. Fouché, was a South African politician who served as the second state president of South Africa from 1968 to 1975.

## Early life

He was born in the Boer republic of the Orange Free State in 1898 (which became a British colony in 1902 and a province of the Union of South Africa in 1910) and matriculated at Paarl Boys' High School.

## Education

His higher education was at Victoria College, Stellenbosch and would obtain his Honours degree and a D.Phil at Stellenbosch University in 1966.

## Career

Fouché was a successful farmer. A staunch republican, he was a member of the National Party for many years, first being elected to the House of Assembly as MP for Smithfield from 1941 to 1950, and as MP for Bloemfontein West between 1960 and 1968.
Fouché served as Administrator of the Orange Free State from 1950 to 1959, and was then promoted to the Cabinet, where he served as Minister of Defence from 14 December 1959 to 1 April 1966 and as Minister of Agricultural Technical Services and Water Affairs from 1966 to 1968. He was elected State President in place of Ebenhaezer Dönges (who had been elected, but died before he could take office), and served as ceremonial head of state from 1968 to 1975. He was the only State President to complete a full term in office.

## Family

Fouché married Letta Rhoda ('Lettie') McDonald, a fellow white woman of Anglo-African descent and Scots extraction.

## Depiction on coins

He is depicted on the following coins of the South African rand;
1976 1/2 Cent to 50 Cents.

## Honours

He was awarded the South African Decoration for Meritorious Services and the Paraguayan National Order of Merit. Fouché was also a honorary colonel of Regiment President Steyn.
# Lissotesta conoidea

Lissotesta conoidea is a species of minute sea snail, a marine gastropod mollusc, unassigned in the superfamily Seguenzioidea.

## Distribution

This marine species occurs off New Zealand.
# List of Bangladeshi films of 2001

This is a list of Bangladeshi films that were released in 2001.

## Releases

| Opening | Title | Director | Cast | Genre | Notes |
| | Lalsalu | Tanvir Mokammel | Raisul Islam Asad, Tauquir Ahmed, Mehbooba Mahnoor Chandni, Chitralekha Guho, Rawshan Jamil, Aly Zaker | Drama | Shasur Bari Jindabad (Riaz, Shabnur) |
| 1 January | Mone Pore Tomake | Montazur Rahman Akbar | Riza, Riya Sen, A.T.M. Shamsuzzaman, Humayun Faridi, Dildar | Romance, drama | |
| 10 March | Milon Hobe Koto Dine | Jakir Hossain Raju | Riaz, Shabnur, Alamgir, Amal Bose | Romance, drama | |
| 20 July | Chairman | Montazur Rahman Akbar | Ilias Kanchan, Rituparna Sengupta | Action | |
| 19 August | Nishwase Tumi Biswase Tumi | Jakir Hossain Raju | Riaz, Shabnur, Purnima, Bulbul Ahmed | Romance | |
| 19 August | Mayer Samman | Gazi Jahangir | Riaz, Purnima, Anwara | Drama | |
| 19 August | Kothin Bastob | Montazur Rahman Akbar | Riaz, Keya, Razzak, Amin Khan, Nasrin | Action | |
| 19 August | Eri Naam Dosti: Ties Never Die | Sayedur Rahman Saeed | Riaz, Shabnur, Aliraj, Nasir Khan | Action, romance, drama | |
| 24 August | Rongbaz Badshah | Montazur Rahman Akbar | Amit Hasan | Action | |
# List of Bangladeshi films of 2005

This is a list of Bangladeshi films that were released in 2005.

## Releases

| Opening | Title | Director | Cast | Genre | Notes |
| 14 May | Agun Amar Naam | Swapon Chowdhury | Masum Parvez Rubel, Poly, Misha Showdagor, Shahidul Islam Shacchu | Action | |
| 3 June | Banglar Bagh | Ahmed Nasir | Masum Parvez Rubel, Poly, Rehana Joly Misha Showdagor | Action | |
| 3 June | Hajar Bachhor Dhore | Kohinur Akter Suchanda | Riaz, Shashi, Shahnoor, Shuchonda ATM Shamsuzzaman | Drama | Based on Zahir Raihan's novel of the same title |
| 1 July | Amar Shopno Tumi | Hasibul Islam Mizan | Shakib Khan, Shabnur, Ferdous, Abul Hayat, A.T.M. Shamsuzzaman | Romance | |
| 29 July | City Terror | M A Rahim | Manna, Popy, Shakib Khan | Action | |
| 4 October | Kal Sokale | Amzad Hossain | Shabnur, Ferdous Ahmed, Apu Biswas Parveen Sultana Diti | Drama | |
| 4 October | Molla Barir Bou | Salauddin Lavlu | Riaz, Shabnur, Moushumi, ATM Shamsuzzaman, Khairul Alam Sabuj | Comedy, drama | |
| 4 October | Momtaz | Uttam Akash | Momtaz Begum, Humayun Faridi, Helal Khan, Anwara, Prabir Mitra | Drama | |
| 4 November | Taka: The Ultimate Magic | Shahidul Islam Khokon | Riaz, Purnima, Sohel Rana, Humayun Faridi | Action | |
| 15 November | Shyamol Chhaya | Humayun Ahmed | Humayun Faridi, Riaz, Meher Afroz Shaon | Drama, war, history | Based on Bangladesh Liberation War |
| | Bishakto Chokh: The Blue Eye | Masum Parvez Rubel | Riaz, Shahara, Rubel | Action | |
| | Chotto Ektu Bhalobasha | G. Sarker | Riaz, Purnima | Romance | |
| | Bhalobasha Bhalobasha | Mohammad Hannan | Riaz, Shabnur | Romance | |
| | Dhakaiya Pola Barishaler Maiya | Uttam Akash | Shakib Khan, Shabnur, Humayun Faridi | Romance, comedy | |
| | Somadhi | | Shakib Khan, Shabnur, Amin Khan, Jillur Rahman, Anwara | Romance | |
| | Bhalobashar Dushmon' | Wakil Ahmed | Shakib Khan, Shabnur | Romance | |
| | Ek Buk Jala | Shahin Sumon | Shakib Khan, Suveccha | Romance | |
# Tök

Tök is a village in Pest county, Hungary. It is located 30 km from Budapest, on the edge of the Zsámbék basin.
# Tülallar

Tülallar (also, Tulalar, Tülalar, and Tulallar) is a village and municipality in the Goygol Rayon of Azerbaijan. It has a population of 207.
# Saccharopine dehydrogenase (NADP+, L-lysine-forming)

In enzymology, a saccharopine dehydrogenase (NADP+, L-lysine-forming) (EC 1.5.1.8) is an enzyme that catalyzes the chemical reaction
    N$_6$-(L-1,3-dicarboxypropyl)-L-lysine + NADP$^+$ + H$_2$O $\rightleftharpoons$ L-lysine + 2-oxoglutarate + NADPH + H$^+$
The 3 substrates of this enzyme are N6-(L-1,3-dicarboxypropyl)-L-lysine, NADP$^+$, and H$_2$O, whereas its 4 products are L-lysine, 2-oxoglutarate, NADPH, and H$^+$.
This enzyme belongs to the family of oxidoreductases, specifically those acting on the CH-NH group of donors with NAD+ or NADP+ as acceptor. The systematic name of this enzyme class is N6-(L-1,3-dicarboxypropyl)-L-lysine:NADP+ oxidoreductase (L-lysine-forming). Other names in common use include lysine-2-oxoglutarate reductase, lysine-ketoglutarate reductase, L-lysine-alpha-ketoglutarate reductase, lysine:alpha-ketoglutarate:TPNH oxidoreductase, (epsilon-N-[gultaryl-2]-L-lysine forming), saccharopine (nicotinamide adenine dinucleotide phosphate,, lysine-forming) dehydrogenase, 6-N-(L-1,3-dicarboxypropyl)-L-lysine:NADP+ oxidoreductase, and (L-lysine-forming). This enzyme participates in lysine biosynthesis and lysine degradation.
# John Robertson (footballer, born 1974)

John Robertson (born 8 January 1974) is an English former footballer who played professionally for Wigan Athletic and Lincoln City. He also played for a number of non-league clubs, including Southport, Stalybridge Celtic, Leigh RMI, Lancaster City, and Runcorn.

## Honours
### Club
#### Leigh RMI

* Lancashire FA Challenge Trophy (1): 2002−03
# John Robertson (pastoralist)

John Robertson (ca.1808–1880) was a Scottish-born pastoralist in Australia, remembered today for his mansion Struan House, south of Naracoorte, South Australia.

## History

Robertson was born in 1808 or 1809 in Dunachton, Invernesshire, the son of John Robertson and Mary "May" Robertson (née McBain).
He emigrated to Australia, arriving in Hobart in 1831 and moving to Sydney in 1838 on the Saint George with his brothers William and Duncan, Duncan's wife Ann and their three children.
He and brother William settled on a property they called Struan Station in Victoria on the River Wannon in the vicinity of modern Coleraine and Merino. It was around then he acquired the nickname "Poorman Robertson", perhaps from his appearance which contrasted sharply with that of Henty, a rival landholder in Portland, Victoria. In 1852 their elder brother Angus joined them and took over management of Struan. William settled on another of their properties Wando Vale, and John moved to Mosquito Creek near Naracoorte, on an area variously known as Mosquito Plains and Robertsons Plains, where he built a succession of three homes, culminating in the magnificent Struan House in 1875. He purchased further land at Wrattonbully and Elderslie, totalling over 500,000 ha.
Struan House and some 500ha of its original property is now owned by South Australian Department of Agriculture as its regional headquarters.

## Family

John Robertson married Susan Ann Tait Cetwill Fraser or Frazer from Inverness at Portland, Victoria in 1855. They had nine children.
# John Whitehead (explorer)

John Whitehead (30 June 1860 – 2 June 1899) was an English explorer, naturalist and professional collector of natural history specimens in Southeast Asia. He is the first documented person to reach the summit of Mount Kinabalu: this was in 1888, after annual attempts from 1885.
Whitehead was born in Colney Hatch Lane, Muswell Hill, Middlesex to Jeffery Whitehead, a stockbroker, and his wife Jane Ashton Tinker. After education at Elstree, Hertfordshire and the Edinburgh Institution he faced health problems and was sent to recuperate to Engadine in Switzerland in 1881 and then to warm Corsica in 1882 where he discovered a bird new to science, the Corsican nuthatch.
Whitehead travelled in Malacca, North Borneo, Java, and Palawan between 1885 and 1888, where he collected a number of zoological specimens new to science, including 45 new species of bird such as Whitehead's broadbill (Calyptomena whiteheadi), writing up his experiences in a book on his return. Between 1893 and 1896 he explored in the Philippines, again collecting many new species, including the Philippine eagle, the binomial name of which commemorates Whitehead's father Jeffery, who funded his expeditions.
Several species are named after Whitehead:
* Whitehead's woolly bat Kerivoula whiteheadi
* Harpy fruit bat Harpyionycteris whiteheadi
* Whitehead's spiny rat Maxomys whiteheadi
* Luzon striped rat Chrotomys whiteheadi
* Tufted pygmy squirrel Exilisciurus whiteheadi
* Luzon striped rat Chrotomys whiteheadi
* Whitehead's Borneo frog - Meristogenys whiteheadi
* White-winged magpie Urocissa whiteheadi
* Whitehead's broadbill Calyptomena whiteheadi
* Whitehead's trogon Harpactes whiteheadi
* Whitehead's spiderhunter Arachnothera juliae
* Spotted Wood-owl Strix seloputo, formerly Surnia whiteheadi
* Whitehead's swiftlet Collocalia whiteheadi
* Bornean stubtail Urosphena whiteheadi
* Chestnut-faced babbler Zosterornis whiteheadi
* Corsican nuthatch Sitta whiteheadi
* Hainan silver pheasant Lophura nycthemera whiteheadi
Whitehead intended to return to the Philippines in 1899, but was he was forced to alter his plans because of the Spanish–American War. He instead travelled to the island of Hainan, where he died of fever at port of Hoihow (Haikou).
# Jitka

Jitka is a Czech female given name. It is a nickname of the Hebrew name Judith, meaning He will be praised or woman of Judea. The old Czech form is Jutka, derived from the German name Jutta. The name day is celebrated on 5 December. Pronounced "YIT-kah".

## Famous bearers

* Jitka ze Svinibrodu (1003–1058), Czech princess
* Jitka Babická (born 1939), Czech figure skater
* Jitka Bartosová, Czech linguist
* Jitka Čechová (born 1947), Czech actress
* Judita Čeřovská (1929–2001), Czech jazz and swing singer
* Jitka Čvančarová (born 1978), Czech actress
* Jitka Harazimova (born 1975), Czech professional bodybuilder
* Jitka Janáčková (born 1973, Mladá Boleslav), a Czech-Czechoslovak sprint canoer
* Jitka Kocurová (born 1979), Czech actress and model
* Jitka Landová (born 1990) Czech Biathlete
* Jitka Legatová, a Czechoslovak slalom canoer
* Jitka Licenik, Czech-Canadian journalist
* Jitka Molavcová (born 1950), Czech actress and singer
* Jitka Němcová (born 1950), Czech director and university educator
* Jitka Obzinová (born 1964), Czech journalist
* Jitka Seitlová (born 1954), Czech politician
* Jitka Schneiderová (born 1973), Czech actress
* Jitka Smutná (born 1952), Czech actress
* Jitka Snížková (1924–1989), a Czech composer, music educator and musicologist
* Jitka Traplová, a Czechoslovak slalom canoer
* Jitka Válková (born 1991), a Czech beauty pageant contestant from Třebíč
* Jitka Válová (1922–2011), Czech painter
* Jitka Zelenková (born 1950), Czech pop singer
* Jitka Zelenohorská (born 1946), Czech actress
# Jo Dipple

Joanna Shannon Dipple (born 5 June 1968) has been SVP Public Affairs at Live Nation Entertainment since 2017.
The granddaughter of Thomas Burdett Money-Coutts, 7th Baron Latymer she was educated at Benenden School and the University of East Anglia. First editing the Dear Jo letters page for the Daily Mirror from 1995 to 2000, she was then head of public affairs for Trinity Mirror from 2000 to 2006. She was then a special adviser at HM Treasury from 2006 to 2007, and a special adviser to Prime Minister Gordon Brown from 2007 to 2008. She worked at UK Music from 2008 to 2017, first at Director of Government Affairs, then subsequently as CEO.
# SS Umtali

Three steamships of Bullard, King & Co Ltd. were named Umtali:
* SS Umtali (1896), in service until 1925
* SS Umtali (1936), in service until 1957
* SS Umtali (1942), in service 1951–52
# Jon Paris

Jon Paris is a Canadian computer scientist, author, and speaker recognized as one of the top experts on the IBM i platform. In 1987, Jon, then an experienced consultant, was hired by IBM to develop COBOL compilers for the System/36 and System/38 minicomputers. From there, he transitioned into the RPG group, where he played a pivotal role in the development of the modern RPG language as well as other language and development tools, including CODE/400 and Visual Age for RPG. He has also been instrumental in the porting of Python, Ruby, and other languages to the IBM i platform, as well as being a leader in pushing the adoption of completely free RPG. He is also an advocate for PHP on i.

## Personal life

Paris is married to Susan Gantner.

## Awards

In 2011, Paris was named Power Systems Champion.
# List of Dahlia diseases

This article is a list of diseases of dahlia (Dahlia sp.).

## Bacterial diseases

Bacterial diseases :
| Bacterial wilt | Pseudomonas solanacearum |
| Crown gall | Agrobacterium tumefaciens |

## Fungal diseases

Fungal diseases :
| Flower blight | Botrytis cinerea |
| Leaf spot | Alternaria alternata |
| Powdery mildew | Erysiphe cichoracearum Erysiphe communis Erysiphe polygoni |
| Southern blight | Sclerotium rolfsii Athelia rolfsii [teleomorph] |
| Smut | Entyloma dahliae |
| Stem and tuber rot | Rhizoctonia solani Thanatephorus cucumeris [teleomorph] |
| Cottony stem rot | Sclerotinia sclerotiorum |
| Vascular wilt | Fusarium oxysporum Verticillium albo-atrum |

## Viral diseases

Viral diseases :
| Mosaic | Cucumber mosaic virus |
| Dahlia mosaic virus | Tomato spotted wilt virus |
| Ringspot | Impatiens necrotic spot virus |
# Joan McKowen

Joan Moreen McKowen (born Joan Moreen Scott, died 15 September 1992) was an Australian ice hockey figure, particularly known for her specialisation in post-game rehabilitation. She is commemorated by the Joan McKowen Memorial Trophy, currently awarded in the Australian Women's Ice Hockey League. She was a qualified remedial masseuse, complementing her husband Max who specialised in sports medicine, and toured the world with Australian National ice hockey teams.

## Personal life

Joan McKowen was born Joan Moreen Scott.
She was married to Maxwell John McKowen. On 5 July 1948 their engagement was announced.

## Ice hockey

Joan McKowen began her involvement in Australian ice hockey by tending to her son's own injuries and eventually volunteering to tend to the entire team's injuries. In 1982 she became a qualified remedial masseuse and then took part in post-game rehabilitation, complementing her husband Max who specialised in sports medicine, and toured the world with Australian National ice hockey teams. McKowen was the assistant for the 1986 Australian Youth Ice Hockey team that competed in the Oceania championships held in Adelaide, South Australia.

### Joan McKowen Memorial Trophy

After McKowen died on 15 September 1992, the Joan McKowen Memorial Trophy was created in her memory and used as the award for the national senior women's ice hockey tournament until 2009. In 2010 the trophy presented to the winners of the champions of the finals of the Australian Women's Ice Hockey League, a national league for the most elite level of senior women's ice hockey players in Australia.

### Joan McKowen IHA National Teams Honour Board

McKowen's family have maintained an Honour Board in her honour which contains every Ice Hockey Australia national team player and official who represented Australia at a world championship, dating back to the 1960 Squaw Valley Olympics. The sole intention of the board is to remind the athletes of all disciplines of the proud history of the sport of ice hockey in Australia.
* Ice hockey portal
* Australia portal
* Sports portal