OpenLLM-France/wikimedia huggingface dataset:
# Cowden v. Commissioner

Cowden v. Commissioner, 289 F.2d 20 (5th Cir. 1961), outlined the factors used to determine whether something received is a cash equivalent, in other words, whether something received is taxable when it was received or when it was assigned. The court observed two main doctrines in determining when something is taxable. The court relied on the doctrines of constructive receipt and cash equivalence while reiterating that substance rather than form should control income tax laws.

## Background

The taxpayers made a contract for oil and gas royalty payments with "bonuses" payable in two subsequent years. They next signed these contracts over to a bank reporting the amounts received as long term capital gains. The Commissioner disagreed as to their designation making them taxable as capital gains.

### Procedural history

The Commissioner found the “bonus” payments to be taxable at the time they were created and assigned to the extent of their fair market value subject to depletion, computed by applying a four percent discount.
The Tax Court found the "bonus" payments to be taxable at their full face value in the year of the agreement and at ordinary income rates (no depletion). The taxpayer appeals this judgment.

## Decision

Previous case law seemed to imply that only obligations represented by negotiable instruments were cash equivalent. The court rejects this argument, that no obligation can be found to be a cash equivalent unless there is a negotiable instrument, as too unrealistic and formalistic. In addition, the court found that a promissory note is not necessarily a cash equivalent. The court then identified the following factors to consider when deciding if something is a cash equivalent:
* unconditional promise to pay;
* promisor is solvent when the note is delivered;
* assignable;
* not subject to set-off;
* readily marketable; and
* not too risky
When you have a negotiable instrument, you look at the above factors to determine if it is a cash equivalent. If the instrument IS a cash equivalent then it is taxable as if cash were received by the taxpayer instead of an obligation.
The court remanded the case to determine whether the “bonus” obligations were cash equivalents and therefore taxable in the year they were assigned.
# Happy World (TV series)

Happy World (Chinese: 多多富贵多多情) is a Singaporean Chinese-language drama series. The series stars Li Nanxing, Aileen Tan, Zeng Huifen and Cao Jianping. It revolves around three families who live and work in an amusement park.

## Cast

* Li Nanxing as Wang Baiwan
* Aileen Tan as Zhen Meili
* Zeng Huifen as Yang Baoyi
* Cao Jianping
* Fang Hui
* Tony Kim
* Ang Puay Heng
* Song Lihua
* Zhang Jinhua
* Chen Meng
* Zeng Sipei
* Tang Miaoling
* Zeng Yaofeng
* Zhu Li
* Steven Woon
* Tan Mui Kwang
* Anson Khoo
* Wu Qiuyi
* Lin Jinchi
* Huang Qingqi
* Yang Tianfu
* Richard Low as Tang Jinju
* Dai Peng
* Zhong Shurong
* Li Yinzhu as Xiao Tongluo's mother
* Wu Chen
* Xie Shaoguang
* Wang Songshen
* Tiow Im Tan
* Liang Weidong
* Weng Ruiyun
* Liang Baozhu
* Bai Yan
* Zeng Xi'an
* Lan Qinran
* Cai Shiling
* Yang Weiguang
* Tang Wentao
* Li Jianhan
* Chen Zhiguang
* Zhuo Mingshun
* Zhu Houren
* Edmund Chen

## Reception

The series received a positive review in the Lianhe Zaobao.
# Eurhaphidophora

Eurhaphidophora is a genus of camel crickets in the monotypic tribe Rhaphidophorini. Species can be found in: China, Indo-China and Peninsular Malaysia.

## Species

The Orthoptera Species File lists:
* Eurhaphidophora ampla Gorochov, 2010
* Eurhaphidophora angusta Gorochov, 2010
* Eurhaphidophora apicoexcisa Dawwrueng, Gorochov, Pinkaew & Vitheepradit, 2023
* Eurhaphidophora bispina Gorochov, 2010
* Eurhaphidophora bona Gorochov, 2012
* Eurhaphidophora curvata Lu, Huang & Bian, 2022
* Eurhaphidophora fossa Lu, Huang & Bian, 2022
* Eurhaphidophora laosi Gorochov, 2010
* Eurhaphidophora nataliae Gorochov, 1999 - type species
* Eurhaphidophora orlovi Gorochov, 2010
* Eurhaphidophora pawangkhananti Dawwrueng, Gorochov & Suwannapoom, 2020
* Eurhaphidophora rotundata Gorochov, 2010
* Eurhaphidophora tarasovi Gorochov, 2010
* Eurhaphidophora truncata Bian & Shi, 2016
* Eurhaphidophora visibilis Gorochov, 2010
# Equestrian events at the 1987 Pan American Games

Equestrian competitions were contested by participating nations at the 1987 Pan American Games.

## Events

| Event | Gold | Silver | Bronze |
| Individual dressage details | Christilot Hanson-Boylen Canada | Martina Pracht Canada | Margarita Nava Mexico |
| Team dressage details | Canada | United States | Mexico |
| Individual jumping details | Ian Millar Canada | Rodney Jenkins United States | Alberto Valdés, Jr. Mexico |
| Team jumping details | Canada | United States | Mexico |
| Individual three day details | Mike Huber United States | Emily MacGowan United States | Peter Gray Bermuda |
| Team three day details | United States | Canada | Chile |

### Medal table

| Rank | Nation | Gold | Silver | Bronze | Total |
| 1 | Canada | 4 | 2 | 0 | 6 |
| 2 | United States | 2 | 4 | 0 | 6 |
| 3 | Mexico | 0 | 0 | 4 | 4 |
| 4 | Bermuda | 0 | 0 | 1 | 1 |
| 4 | Chile | 0 | 0 | 1 | 1 |
| Totals (5 entries) | Totals (5 entries) | 6 | 6 | 6 | 18 |
# Highgate Platform railway station

Highgate Platform railway station served schoolchildren in the isolated area of Highgate between Keswick and Penrith, in the historical area of Cumberland, England, from 1908 to 1929 on the Cockermouth, Keswick and Penrith Railway.

## History

The station was opened on 17 August 1908 by the Cockermouth, Keswick and Penrith Railway. It was located in a sparsely populated area about 3 miles (5 km) east of the village of Threlkeld and 2 miles (3 km) west of Troutbeck. It was on both sides of the bridge at Highgate Close. It was not intended for general public use, thus London and North Western Railway did not display the name signs on the platforms. Nearby was Highgate signal box, which opened before the station in 1892. Non-school use trains occasionally called at the station; social trips and a honeymoon trip were examples. The bus service introduced in 1928 rendered this station obsolete and it closed at the end of the December term in the following year, although official closure took place on 1 January 1929.
The word "Platform" was used as the Scottish equivalent of "Halt" and that was presumably its meaning here.
# Donje Vranovce

Donje Vranovce is a village in the municipality of Lebane, Serbia. According to the 2002 census, the village has a population of 331 people.
# Auditorio Nacional

Auditorio Nacional may refer to:
* Auditorio Nacional (Mexico), Mexico City
** Metro Auditorio, a Metro station
* National Auditorium of Music (Auditorio Nacional de Música), Madrid, Spain
* National Auditorium of Sodre (Auditorio Nacional de Sodre), Uruguay
* Auditório Nacional, Cape Verde
# Bisukharka

Bisukharka is a village and municipality in Gulmi District in the Lumbini Zone of central Nepal. At the time of the 1991 Nepal census it had a population of 2656 persons living in 499 individual households.
# Aatida Amaase

Aati amaase (Tulu:ಆಟಿ ಅಮಾಸೆ) it is also called as Aati Amavese, Ashada Amavase, Aati Amavasye, Deevige Karkataka Amavasya or Bhimana Amavasya. It is celebrated in the Aati month of the tulu calendar in Tulunadu region on the new moon day. Aati is the fourth month of the oldest traditional Indian solar calendar. On this auspicious day tulunadu people drink Paaleda Kashaya which is bitter in taste. It cleans the digestive tracts systems and is said to have loads of medicinal power to fight diseases. Therefore, people advised to have paaleda kashaya on an empty stomach. Tuluva being the worshipers of Mother Nature, show gratitude towards this divine tree.

## Paale ketteda kashaya

Tulunadu people drink ‘Paale ketteda kashaya’, a bitter Ayurvedic decoction to mark Aati Amavasya day, in the households. The Paale mara(Tulu Language) or Saptaparni in Sanskrit, Halemara in Kannada, botanically known as Alstonia scholaris is also known as Devil tree in English.

### The Kashaya (decoction) preparation

Traditionally, people of tulunadu used to clean the surroundings of paale mara the previous day of new moon day and tie the tree with rope dry banana leaves and keep a stone under the tree. So, they can identify the paale mara easily in the early morning and pray with the tree, "Hey divine Tree, you fill with the entire medicinal aspects tomorrow. Please bless with good health after having your bark/skin". It also has divine status in this region. On aati amaase day, (the next day) before sunrise the bark/skin of the paale mara should be collected with the help of a stone and decoction prepared from it. The special care should be taken in the identification of the tree. Very outer skin(black coloured) is removed and inner white part is crushed by adding a little water, to make kashaya. The tree bark is grinded by using a stone. And this ayurvedic concoction is prepared by mixing ingredients of pepper, turmeric, ajwain, garlic, and seeds into it. And scorch a pebble or iron bar and place in the decoction. After oblation to god and finally people intake the Kashaya. It tastes highly bitter, because it has ensemble medicinal contents. This juice is called Paaleda kashaya.
After intake of Kashaya, there is a habit of eating roasted cashews, pappads and Shendige, menthe and coconut rice.

## Aati Agel

On amavase day evening tulu people make " Guru karnvereg Agel". Agel is a system of arranging meals to our ancestors. It is a kind of religious belief of tuluvas. All the members of the family are gathered together to prepare the Agel. They usually prepare and serve neer dosa, chicken curry and country alcohol to offer the demi spirits, deities and departed forefathers of tulu people.

## proverb

* Proverb in Tulu "aati aned popini, sona kudred popini" which means aati travels slowly with no work at home like riding on an Elephant, and sona travels as fast as if riding on a horse!
# Mandy Sanghera

Mandy Sanghera is an international human rights activist. Since 1990, she has been supporting victims and survivors of honour-based violence and cultural abuse such as female genital mutilation, forced marriages, faith-based abuse, and witchcraft.

## Activism and humanitarian work

As a human rights activist, Sanghera has worked in various areas focusing on cultural abuse and crimes. She has been involved in documentaries on themes such as witchcraft, forced marriages, incest, female genital mutilation, and “honour” killings.
Sanghera was involved in writing the guidelines on disability and HBV for the Forced Marriages Unit. Until 2018, she worked with the European Parliament on forced marriages, preparing a report based on the information from the 28 European Union Member States and the selected associated countries, and will be involved in the Goddard Child Abuse Inquiry. Sanghera is an ambassador and adviser for several charities and social groups such as Psychreg, and has supported over 200 disabled adults who have been forced into marriage. She was one of a panel of speakers at the United States House of Representatives and spoke about honour-based violence and cultural abuse. Sanghera was on the team that worked on the "My Marriage My Choice" project at the University of Nottingham.
# Anisleidy Galindo

Anisleidy Galindo (born 21 September 1989) is a Cuban basketball player for Pinar del Río and the Cuban national team, where she participated at the 2014 FIBA World Championship.
She was a member of the team which competed for Cuba at the 2015 Pan American Games, winning a bronze medal.
# Afghanistan and the World Bank

Afghanistan is a World Bank Group member country. It has received financial support from the organization since 2002. The World Bank provides loans and grants to support its development and reconstruction efforts. The bank aims to help Afghanistan with matters such as poverty reduction, infrastructure development, education, and governance. Afghanistan collaborates with the World Bank on various policy initiatives and reforms to promote economic growth and stability.

## Projects
### Health Emergency Response (HER) w/UNICEF and WHO

* The HER project ensures that national coverage of basic health services continues for the Afghan people. It sustains local basic health service providers such that basic health services continue across the country covering 70% of the total population. There were over $216.8m in contracts signed for health care services for the project duration. 623K children have received vaccinations and over 3.6 million infants received nutrition services.

### Emergency Food Security (EFSP)w/ FAO

* EFSP seeds agricultural inputs, watershed management and cash for work for farming communities. It sustains local farmers' associations and disburses $50 million worth of seeds for 300k farmers, reaching 2.1 million people. 20 micro irrigation scheme designs have been completed. 54 watershed sub-projects to create job opportunities through cash-for-work activities for more than 280,000 beneficiaries were under way as of 2022.

### Community Resilience Livelihoods (CRL) w/UNOPS

* CRP provides cash for improved access to basic services. It focuses on women and vulnerable populations. It sustains critical community institutions for service delivery. Consultations and cash-for-work activities started in 1,000 rural communities in 48 districts and 17 provinces.Six urban labor-intensive work projects with a pipeline of 175 projects.

### Emergency Education Response in Afghanistan (EERA) W/ UNICEF

* EERA works with community-based education institutions to provide learning opportunities. 250 community based education classes were established to enable secondary education for girls after the government banned girls from school. Six small innovative grassroot level block grants are supported.

### NSO Capacity Building W/ UNDP

* This oroject strengthens the capacities of selected NGOs and COs involved in providing basic services for the most vulnerable. This was a challenging sector given IT's restrictions on NGOs/CSOs.
# Epidendrum latilabre

Epidendrum latilabre is a species of orchid of the genus Epidendrum which occurs naturally in French Guiana, Peru and Brazil. The diploid chromosome number of E. latilabre has been determined as 2n = 40.
# Brett Whiteley Travelling Art Scholarship

The Brett Whiteley Travelling Art Scholarship is an Australian annual art award in honour of the painter Brett Whiteley. The scholarship is administered by the Art Gallery of New South Wales.
Whiteley died in 1992. In 1999, his mother Beryl Whiteley (1917 – 2010) made funds available to establish a scholarship in his memory. The inspiration for the scholarship was the profound effect of international travel and study experienced by Brett as a result of winning the Italian Travelling Art Scholarship at the age of 20.
The Brett Whiteley Travelling Art Scholarship is open to Australian artists aged between 20 and 30. The winner receives A$25,000 and a three-month residency at the Cite Internationale des Arts in Paris.
In 2004, Beryl Whiteley was awarded the Medal of the Order of Australia (OAM) for her service as a benefactor to the visual arts through the creation and endowment of the scholarship. Brett Whiteley himself was appointed an Officer (AO) of the order a year before his death.
In recent years, Brett Whiteley's ex-wife Wendy Whiteley has presented the prizes.
Beryl Whiteley died on 1 April 2010, aged 93.

## Winners of the Brett Whiteley Travelling Art Scholarship

* 1999: Alice Byrne, Newtown shed
* 2000: Marcus Wills, Parable of the sower
* 2001: Petrea Fellows, Treescape
* 2002: Ben Quilty, Elwood Park
* 2003: Karlee Rawkins, Bitch in India
* 2004: Alan Jones (artist), Figure # 11
* 2005: Wayde Owen, Californian Quail
* 2006: Samuel Wade, Grey Day at Central
* 2007: Nathan Hawkes, Icebergs
* 2008: Amber Wallace, Untitled landscape
* 2009: Nicole Kelly, Figure in landscape
* 2010: Belem Lett
* 2011: Becky Gibson
* 2012: Mitch Cairns
* 2013: Tim Phillips
* 2014: James Francis Drinkwater
* 2015: Tom Polo
* 2016: Lucy O'Doherty
* 2017: Sally Anderson, Dilling's Bromeliads with Gullfoss Falls
* 2018: Natasha Walsh, Dear Frida
* 2020: Emily Grace Imeson, Home Amongst Giants Study
* 2021: Mia Boe, Mia and Eliza Fraser
* 2022: Bill Hawkins, Butterfly brut
* 2023: Mark Maurangi Carrol, Psalm (part-1)
# George Egerton (Royal Navy officer)

Admiral Sir George Le Clerc Egerton KCB (17 October 1852 – 30 March 1940) was a senior Royal Navy officer from the Egerton family who rose to become Second Sea Lord.

## Naval career

Egerton joined the Royal Navy in 1866. He served on the Arctic Expedition of 1875–76. In 1893 he was promoted to captain and appointed a naval attaché before serving with the Naval Brigade in Mombasa in 1895, and he was chief of staff for the Benin Expedition of 1897.
By early 1900 he was in command of the pre-dreadnought battleship HMS Majestic, serving as flagship to Vice-Admiral Sir Harry Rawson, commander-in-chief of the Channel Fleet. In June 1901 he was transferred to the President for service as assistant director of torpedoes at the Admiralty, a position he left the following February when he transferred to the torpedo school ship Vernon.
He was appointed second-in-command of the Atlantic Fleet in 1906: Egerton flew his flag on HMS Victorious, with Captain Robert Scott as his flag captain. He became commander-in-chief, Cape of Good Hope Station in 1908 and Second Sea Lord in 1911. He served in World War I as Commander-in-Chief, Plymouth. He had previously served as aide-de-camp to King Edward VII, and retired in 1916.

## Family

A grandson of The Rev Sir Philip Grey-Egerton, 9th Bt, he married, first, in 1882, Frances Emily Gladstone; they had two sons and a daughter, including Rear-Admiral Brian Egerton (1886–1973). He married, second, Margaret Stella Maunsell, in 1932.
# Black Dog Publishing

Black Dog Publishing is a British publishing company specialising in illustrated non-fiction books on contemporary culture. Topics covered by Black Dog include architecture, art, craft, design, environment, fashion, film, music and photography.

## Details

The company was founded by Duncan McCorquodale in 1993. Its website claims it aspires to "take a daring, innovative approach to our titles". It has an emphasis on high production values.
Black Dog has published the Labels Unlimited and Edge Futures series, a series of books by Art on the Underground, the official London Eye book, and a book about the Riot Grrrl movement titled Riot Grrrl: Revolution Girl Style Now!, biographies of such figures as Charlemagne Palestine, Alvar Aalto, Colin St John Wilson, Tod Browning and Jean-Luc Godard. In 2007 Black Dog released Making Stuff for Kids, an instructional craft book for children, in collaboration with The Guardian newspaper.
Authors of Black Dog titles include Rob Young, Lydia Lunch, Bob and Roberta Smith, Carolee Schneemann, Phyllida Barlow, Beth Ditto, Peter Wollen, Suzanne Treister and Karen Knorr.
This company went into liquidation in January 2018 owing more than £700,000. The assets of Black Dog were acquired by St James’s House Media Group who now runs the company.
# Energy saving lamp

Energy saving lamps are sources of artificial light that employ advanced technology to reduce the amount of electricity used to generate light, relative to traditional filament-burning light bulbs.
Examples of energy saving lamps include:
* Fluorescent lamps; i.e. regular and compact
* LED lamp
* a Light-emitting electrochemical cell
* Magnetic induction lamps
# Anisocarpus madioides

Anisocarpus madioides (syn. Madia madioides) is a North American species of flowering plant in the family Asteraceae known by the common name woodland madia.

## Description

Anisocarpus madioides is a perennial herb growing up to about 75 centimeters in height, its stem coated in rough hairs and stalked resin glands. The lower leaves are up to 12 centimeters long, oppositely arranged, and fused around the stem at the bases. The upper leaves are much smaller and often alternately arranged. The inflorescence produces several flower heads on long peduncles, each with a rounded involucre of glandular phyllaries. The heads bear yellow ray florets up to a centimeter long and many disc florets. The fruit is an achene a few millimeters long, usually with a small pappus. Flowers bloom April to September.

## Distribution and habitat

Anisocarpus madioides is native to the west coast of North America on Vancouver Island in the Canadian Province of British Columbia and the US States of Washington, Oregon, and California. It is a plant of forest and woodland habitat. Most of the populations occur in the Cascades and in the Coast Ranges from Vancouver Island to San Luis Obispo County, but there are additional collections from the foothills of the northern Sierra Nevada and the Agua Tibia Mountains of San Diego County.
# Afghanistan at the 1951 Asian Games

Afghanistan participated in the 1951 Asian Games held in New Delhi, India from 4 to 11 March 1951. Athletes from Afghanistan failed to secure any medal spot in these Games.
# Anthony Browne

Anthony Browne may refer to:
* Anthony Browne (died 1506) (1443–1506), Standard Bearer of England, Governor of Queenborough Castle and Constable of Calais
* Anthony Browne (died 1548) (c. 1500–1548), English courtier, son of Sir Anthony, Standard Bearer
* Anthony Browne (judge) (1509–1567), judge and MP who founded Brentwood School, England
* Anthony Browne, 1st Viscount Montagu (1528–1592), son of Sir Anthony (died 1548)
* Anthony Browne (1552–1592), English Sheriff, son of 1st Viscount Montagu
* Anthony-Maria Browne, 2nd Viscount Montagu (1554–1629), son of Anthony (1552–1592)
* Anthony Montague Browne (1923–2013), aide to Winston Churchill in the last ten years of Churchill's life
* Anthony Browne (author) (born 1946), British writer and illustrator of children's books
* Anthony Browne (politician) (born 1967), British journalist, author, and Member of Parliament for South Cambridgeshire
# Nüydi

Nüydi (also, Nyugdi, Nyugdy, and Nyuydi) is a village and municipality in the Shamakhi Rayon of Azerbaijan. It has a population of 632.
# Auman

Auman is a surname. Notable people with the surname include:
* Dorothy Auman (died 1991), American potter
* Joseph M. Auman (1922–1942), American soldier
* William Auman (1838–1920), American general
# Faceless

Faceless may refer to:

## Films

* Faceless (1988 film), French slasher film
* Faceless (2007 film), Austrian/British science fiction film
* Faceless (2016 film), Canadian-Afghan action film

## Music

* Faceless (Godsmack album), 2003 album
* The Faceless, American death metal group
* Faceless (Buried in Verona album), 2014 album
* "Faceless" (EP), 1991 EP by Impetigo, or the title song
* "Faceless" (song), 2010 song by Red

## Literature

* Faceless, 2001 novel by Martina Cole
* Faceless, 2003 novel by Amma Darko