alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
IN THE UNITED STATES COURT OF APPEALS

FOR THE FIFTH CIRCUIT

No. 19-60804

ANTHONY DWAYNE WILLIAMS, T’ESHKA RENYELL YOUNG,

 Petitioners - Appellants

v.

COMMISSIONER OF INTERNAL REVENUE, 

 Respondent - Appellee

Appeal from the United States Tax Court

Tax Court Case No. 26670-17L

 Tax Court Case No. 26671-17L

Before WIENER, HAYNES, and COSTA, Circuit Judges.

PER CURIAM:*

Ignoring the Sixteenth Amendment, appellants argue that an income tax 

on their wages is unconstitutional. What we said years ago in rejecting the 

appeal of a tax protestor still rings true: “We perceive no need to refute these 

arguments with somber reasoning and copious citation of precedent; to do so 

might suggest that these arguments have some colorable merit.” Crain v. 

Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984). Moreover, appellants were 

not allowed to challenge their underlying tax liability in the collection due 

* Pursuant to 5TH CIR. R. 47.5, the court has determined that this opinion should not 

be published and is not precedent except under the limited circumstances set forth in 5TH 

CIR. R. 47.5.4.

United States Court of Appeals

Fifth Circuit

FILED

April 16, 2020

Lyle W. Cayce

Clerk

 Case: 19-60804 Document: 00515385036 Page: 1 Date Filed: 04/16/2020
No. 19-60804

2

process hearing because they had previously received notices of deficiency for 

the tax years at issue but did not dispute that tax liability. I.R.C. § 

6330(c)(2)(B). Although Anthony Williams could challenge the imposition of 

his frivolous-return penalty in the due process hearing—he did not receive a 

deficiency notice for that penalty or otherwise have an earlier opportunity to 

contest, that penalty was proper. See I.R.C. § 6702(a), 2(A) (allowing a penalty 

of $5,000 if the person files an incorrect return “based on a position which the 

Secretary has identified as frivolous”). As we noted at the outset, Williams’s 

position that he did not receive wages because he was a “non-federal worker” 

paid by a private employer is frivolous. And the Commissioner has recognized 

it as such. IRS Notice 2010-33(III)(7) (citing Revenue Ruling 2006-18).

AFFIRMED. 

 Case: 19-60804 Document: 00515385036 Page: 2 Date Filed: 04/16/2020
Editorial Note on Part 409
Editorial Note: Nomenclature changes to part 409 appear at 62 FR 46037, Aug. 29, 1997.

§ 409.15 Services furnished by an intern or a resident-in-training. Medical or surgical services provided by an intern or a resident-in-training are included as “inpatient hospital or inpatient CAH services” if they are provided— ( a ) By an intern or a resident-in-training under a teaching program approved by the Council on Medical Education of the American Medical Association, or the Bureau of Professional Education of the American Osteopathic Association;
( b ) By an intern or a resident-in-training in the field of dentistry under a teaching program approved by the Council on Dental Education of the American Dental Association; or
( c ) By an intern or a resident-in-training in the field of podiatry under a teaching program approved by the Council on Podiatry Education of the American Podiatry Association.
[48 FR 12541, Mar. 25, 1983, as amended at 58 FR 30666, May 26, 1993]
# C_2005170EN.01000101.xml

| 9.7.2005 | EN | Official Journal of the European Union | C 170/1 |
| --- | --- | --- | --- |

9.7.2005

EN

Official Journal of the European Union

C 170/1

---

Euro exchange rates (1)

1

8 July 2005

(2005/C 170/01)

1 euro=

1 euro

| | Currency | Exchange rate |
| --- | --- | --- |
| USD | US dollar | 1,1904 |
| JPY | Japanese yen | 133,84 |
| DKK | Danish krone | 7,4546 |
| GBP | Pound sterling | 0,68630 |
| SEK | Swedish krona | 9,4296 |
| CHF | Swiss franc | 1,5530 |
| ISK | Iceland króna | 78,51 |
| NOK | Norwegian krone | 7,8755 |
| BGN | Bulgarian lev | 1,9558 |
| CYP | Cyprus pound | 0,5736 |
| CZK | Czech koruna | 30,248 |
| EEK | Estonian kroon | 15,6466 |
| HUF | Hungarian forint | 247,82 |
| LTL | Lithuanian litas | 3,4528 |
| LVL | Latvian lats | 0,6959 |
| MTL | Maltese lira | 0,4293 |
| PLN | Polish zloty | 4,0726 |
| RON | Romanian leu | 3,5828 |
| SIT | Slovenian tolar | 239,48 |
| SKK | Slovak koruna | 38,941 |
| TRY | Turkish lira | 1,6050 |
| AUD | Australian dollar | 1,6089 |
| CAD | Canadian dollar | 1,4607 |
| HKD | Hong Kong dollar | 9,2551 |
| NZD | New Zealand dollar | 1,7725 |
| SGD | Singapore dollar | 2,0289 |
| KRW | South Korean won | 1 255,75 |
| ZAR | South African rand | 8,2439 |
| CNY | Chinese yuan renminbi | 9,8523 |
| HRK | Croatian kuna | 7,3170 |
| IDR | Indonesian rupiah | 11 669,49 |
| MYR | Malaysian ringgit | 4,524 |
| PHP | Philippine peso | 66,752 |
| RUB | Russian rouble | 34,3150 |
| THB | Thai baht | 50,161 |

Currency

Exchange rate

USD

US dollar

1,1904

JPY

Japanese yen

133,84

DKK

Danish krone

7,4546

GBP

Pound sterling

0,68630

SEK

Swedish krona

9,4296

CHF

Swiss franc

1,5530

ISK

Iceland króna

78,51

NOK

Norwegian krone

7,8755

BGN

Bulgarian lev

1,9558

CYP

Cyprus pound

0,5736

CZK

Czech koruna

30,248

EEK

Estonian kroon

15,6466

HUF

Hungarian forint

247,82

LTL

Lithuanian litas

3,4528

LVL

Latvian lats

0,6959

MTL

Maltese lira

0,4293

PLN

Polish zloty

4,0726

RON

Romanian leu

3,5828

SIT

Slovenian tolar

239,48

SKK

Slovak koruna

38,941

TRY

Turkish lira

1,6050

AUD

Australian dollar

1,6089

CAD

Canadian dollar

1,4607

HKD

Hong Kong dollar

9,2551

NZD

New Zealand dollar

1,7725

SGD

Singapore dollar

2,0289

KRW

South Korean won

1 255,75

ZAR

South African rand

8,2439

CNY

Chinese yuan renminbi

9,8523

HRK

Croatian kuna

7,3170

IDR

Indonesian rupiah

11 669,49

MYR

Malaysian ringgit

4,524

PHP

Philippine peso

66,752

RUB

Russian rouble

34,3150

THB

Thai baht

50,161

---

(1)

1

Source: reference exchange rate published by the ECB.

Source:

---
# C_2006011EN.01000101.xml

| 17.1.2006 | EN | Official Journal of the European Union | C 11/1 |
| --- | --- | --- | --- |

17.1.2006

EN

Official Journal of the European Union

C 11/1

---

Euro exchange rates (1)

1

16 January 2006

(2006/C 11/01)

1 euro=

1 euro

| | Currency | Exchange rate |
| --- | --- | --- |
| USD | US dollar | 1,2112 |
| JPY | Japanese yen | 139,23 |
| DKK | Danish krone | 7,4613 |
| GBP | Pound sterling | 0,68545 |
| SEK | Swedish krona | 9,3293 |
| CHF | Swiss franc | 1,5497 |
| ISK | Iceland króna | 74,14 |
| NOK | Norwegian krone | 8,0490 |
| BGN | Bulgarian lev | 1,9558 |
| CYP | Cyprus pound | 0,5737 |
| CZK | Czech koruna | 28,796 |
| EEK | Estonian kroon | 15,6466 |
| HUF | Hungarian forint | 250,32 |
| LTL | Lithuanian litas | 3,4528 |
| LVL | Latvian lats | 0,6959 |
| MTL | Maltese lira | 0,4293 |
| PLN | Polish zloty | 3,8093 |
| RON | Romanian leu | 3,6352 |
| SIT | Slovenian tolar | 239,51 |
| SKK | Slovak koruna | 37,477 |
| TRY | Turkish lira | 1,6148 |
| AUD | Australian dollar | 1,6066 |
| CAD | Canadian dollar | 1,4055 |
| HKD | Hong Kong dollar | 9,3912 |
| NZD | New Zealand dollar | 1,7340 |
| SGD | Singapore dollar | 1,9792 |
| KRW | South Korean won | 1 189,94 |
| ZAR | South African rand | 7,2575 |
| CNY | Chinese yuan renminbi | 9,7711 |
| HRK | Croatian kuna | 7,3798 |
| IDR | Indonesian rupiah | 11 476,12 |
| MYR | Malaysian ringgit | 4,536 |
| PHP | Philippine peso | 63,673 |
| RUB | Russian rouble | 34,2590 |
| THB | Thai baht | 48,054 |

Currency

Exchange rate

USD

US dollar

1,2112

JPY

Japanese yen

139,23

DKK

Danish krone

7,4613

GBP

Pound sterling

0,68545

SEK

Swedish krona

9,3293

CHF

Swiss franc

1,5497

ISK

Iceland króna

74,14

NOK

Norwegian krone

8,0490

BGN

Bulgarian lev

1,9558

CYP

Cyprus pound

0,5737

CZK

Czech koruna

28,796

EEK

Estonian kroon

15,6466

HUF

Hungarian forint

250,32

LTL

Lithuanian litas

3,4528

LVL

Latvian lats

0,6959

MTL

Maltese lira

0,4293

PLN

Polish zloty

3,8093

RON

Romanian leu

3,6352

SIT

Slovenian tolar

239,51

SKK

Slovak koruna

37,477

TRY

Turkish lira

1,6148

AUD

Australian dollar

1,6066

CAD

Canadian dollar

1,4055

HKD

Hong Kong dollar

9,3912

NZD

New Zealand dollar

1,7340

SGD

Singapore dollar

1,9792

KRW

South Korean won

1 189,94

ZAR

South African rand

7,2575

CNY

Chinese yuan renminbi

9,7711

HRK

Croatian kuna

7,3798

IDR

Indonesian rupiah

11 476,12

MYR

Malaysian ringgit

4,536

PHP

Philippine peso

63,673

RUB

Russian rouble

34,2590

THB

Thai baht

48,054

---

(1)

1

Source: reference exchange rate published by the ECB.

Source:

---
§ 412.112 Payments determined on a per case basis. A hospital is paid the following amounts on a per case basis: ( a ) The appropriate prospective payment rate for inpatient operating costs for each discharge as determined in accordance with subparts D, E, and G of this part.
( b ) Effective for cost reporting periods beginning on or after October 1, 1991, the appropriate prospective payment rate for capital-related costs for each discharge as determined in accordance with subpart M of this part.
( c ) The appropriate outlier payment amounts determined under subpart F of this part.
( d ) Additional payments for new medical services and technologies determined under subpart F of this part.
[56 FR 43448, Aug. 30, 1991, as amended at 57 FR 39824, Sept. 1, 1992; 68 FR 45470, Aug. 1, 2003]
EXHIBIT 31.1
**CERTIFICATIONS**
I, Robert R. Jones, III, President and CEO, certify that:
1. I have reviewed this annual report on Form 10-K of United Bancorporation ofAlabama, Inc.;
2. Based on my knowledge, this annual report does not contain any untruestatement of a material fact or omit to state a material fact necessary to makethe statements made, in light of the circumstances under which such statementswere made, not misleading with respect to the period covered by this annualreport;
3. Based on my knowledge, the financial statements, and other financialinformation included in this annual report, fairly present in all materialrespects the financial condition, results of operations and cash flows of theregistrant as of, and for, the periods presented in this annual report;
4. The registrant’s other certifying officers and I are responsible forestablishing and maintaining disclosure controls and procedures (as defined inExchange Act Rules 13a-15(e) and 15d-15(e)) and have:
     (a) Designed such disclosure controls and procedures, or caused suchdisclosure controls and procedures to be designed under our supervision,to ensure that material information relating to the registrant, includingits consolidated subsidiaries, is made known to us by others within thoseentities, particularly during the period in which this annual report isbeing prepared;
     (b) Evaluated the effectiveness of the registrant’s disclosurecontrols and procedures and presented in this annual report ourconclusions about the effectiveness of the disclosure controls andprocedures, as of the end of the period covered by this annual reportbased on such evaluation; and
     (c) Disclosed in this annual report any change in the registrant’sinternal control over financial reporting that occurred during theregistrant’s most recent fiscal quarter (the registrant’s fourth fiscalquarter in the case of an annual report) that has materially affected, oris reasonably likely to materially affect, the registrant’s internalcontrol over financial reporting; and
5. The registrant’s other certifying officers and I have disclosed, based onour most recent evaluation of internal control over financial reporting, to theregistrant’s auditors and the audit committee of the registrant’s board ofdirectors (or persons performing the equivalent functions):
     (a) All significant deficiencies in the design or operation ofinternal control over financial reporting which are reasonably likely toadversely affect the registrant’s ability to record, process, summarizeand report financial information; and
     (b) Any fraud, whether or not material, that involves management orother employees who have a significant role in the registrant’s internalcontrol over financial reporting.
Date: March 26, 2004
/s/ Robert R. Jones, IIIRobert R. Jones, III
EXHIBIT 32.1

CERTIFICATION PURSUANT TO

18 U.S.C. SECTION 1350

AS ADOPTED PURSUANT TO

SECTION 906
OF THE SARBANES-OXLEY ACT OF 2002

In connection with this quarterly report on Form 10-Q of Electro Scientific Industries, Inc. (the
Company) for the quarterly period ended September 27, 2008 as filed with the Securities and Exchange Commission on the date hereof (the Report), I, Nicholas Konidaris, President and Chief Executive Officer of the
Company, certify, pursuant to 18 U.S.C. § 1350, as adopted pursuant to § 906 of the Sarbanes-Oxley Act of 2002, that to the best of my knowledge:



|(1) | The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and
|--- | ---------------------------------------------------------------------------------------------------------------------



|(2) | The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company.
|--- | ----------------------------------------------------------------------------------------------------------------------------------------------------



|                                                        
|--------------------------------------------------------
|/s/ Nicholas Konidaris                                  
|Nicholas Konidaris President and Chief Executive
Officer

Dated: November 6, 2008

This certification is made solely for the purpose of 18 U.S.C. Section 1350, and not for any other purpose. A signed original of this written statement required by Section 906 has been provided to Electro Scientific Industries,
Inc. and will be retained by Electro Scientific Industries, Inc. and furnished to the Securities and Exchange Commission or its staff upon request.
#### § 800.246 Supply.

Solely for the purposes of column 2 of appendix A to this part, the term *supply* means to provide third-party physical or cyber security.
UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 02-7694
UNITED STATES OF AMERICA, Plaintiff - Appellee, versus NORVELL WEBSTER CRUMP, Defendant - Appellant. Appeal from the United States District Court for the Southern District of West Virginia, at Huntington. Robert J. Staker, Senior District Judge. (CR-94-101, CA-01-969) Submitted: February 4, 2003 Decided: March 12, 2003 Before WILKINS, Chief Judge, and TRAXLER and GREGORY, Circuit Judges. Affirmed by unpublished per curiam opinion. Norvell Webster Crump, Appellant Pro Se. Michael Lee Keller, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, West Virginia, for Appellee. Unpublished opinions are not binding precedent in this circuit. See Local Rule 36(c).2 PER CURIAM: Norvell Webster Crump appeals the district court’s order denying his motion for a reduction to his sentence under 18 U.S.C. § 3582(c)(2) (2000). We have reviewed the record and find no reversible error. Accordingly, we affirm on the reasoning of the district court. SeeUnited States v. Crump , Nos. CR-94-101; CA-01- 969 (S.D.W. Va. Oct. 21, 2002). We dispense w ith oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process.

AFFIRMED
# C_2006016EN.01002401.xml

| 21.1.2006 | EN | Official Journal of the European Union | C 16/24 |
| --- | --- | --- | --- |

21.1.2006

EN

Official Journal of the European Union

C 16/24

---

Pilot Project 2005-2006 European Programme for Critical Infrastructure Protection (EPCIP)

(2006/C 16/06)

The complete call for proposals is published on the JLS website at:

http://europa.eu.int/comm/justice_home/funding/epcip/funding_epcip_en.htm

Deadline for presentation of proposals: 10 March 2006.

---
Editorial Note on Part 413
Editorial Note: Nomenclature changes to part 413 appear at 76 FR 50537, August 22, 2014.

§ 413.149 Depreciation: Allowance for depreciation on assets financed with Federal or public funds. ( a ) *Principle.* Depreciation is allowed on assets financed with Hill-Burton or other Federal or public funds.
( b ) *Application.* Like other assets (including other donated depreciable assets), assets financed with Hill-Burton or other Federal or public funds become a part of the provider institution's plant and equipment to be used in furnishing services. It is the function of payment of depreciation to provide funds that make it possible to maintain the assets and preserve the capital employed in the production of services. Therefore, irrespective of the source of financing of an asset, if it is used in the providing of services for beneficiaries of the program, payment for depreciation of the asset is, in fact, a cost of the production of those services. Moreover, recognition of this cost is necessary to maintain productive capacity for the future. An incentive for funding of depreciation is provided in these principles by the provision that investment income on funded depreciation is not treated as a reduction of allowable interest expense under § 413.153(a).
No. 00-5852.

#### Murphy *v.*United States.

C. A. 5th Cir. Certiorari denied.
HomeOffice of the SpokespersonPress Releases...Designation of Arvan Cloud and Affiliates That Have Aided Internet Censorship in Iran

# 									Designation of Arvan Cloud and Affiliates That Have Aided Internet Censorship in Iran							

Press Statement

Antony J. Blinken, Secretary of State

June 2, 2023

Today, the United States is announcing additional sanctions in our effort to support the human rights and fundamental freedoms of the Iranian people, including the freedom of expression both online and offline including the freedom to access information via the Internet.

We are designating the Iran-based technology company known as “Arvan Cloud” for its role in the Iranian regime’s censorship of the Internet in Iran.  Arvan Cloud maintains a close, collaborative relationship with Iran’s Ministry of Intelligence and Security.

We are also designating the co-founders of Arvan Cloud, CEO Pouya Pirhosseinloo and technology lead Farhad Fatemi, as well as its affiliate, the Dubai-based Arvancloud Global Technologies L.L.C.

Today’s action is just one component in our multi-pronged strategy to support and preserve the free flow of information to the Iranian people in the face of the Iranian regime’s unprecedented campaign of Internet disruptions and censorship, part of a broader crackdown on dissent.

The United States will continue to support the development and operation of anti-censorship tools that millions of people around the world, including in Iran, use to stay connected online despite authoritarian efforts to disrupt their access to the global internet.  And we will continue to use all tools at our disposal to promote accountability for violations and abuses of human rights and actions that enable the mass suppression and censorship of the Iranian people.

*Today’s action is being taken pursuant to**Executive Order (E.O.) 13846**, which authorizes sanctions on persons who engage in censorship or other activities with respect to Iran.  This action does not affect the U.S. government’s continued support for the Iranian people’s ability to freely access information both offline and online such as through the provision of Internet communication tools to the people of Iran, including under**Iran General License D-2**.  Please also see**FAQ 1087**and**FAQ 1088**for any questions on the provision of cloud services for the Iranian people.*

Tags

Bureau of Democracy, Human Rights, and LaborBureau of Near Eastern AffairsHuman RightsIranOffice of the SpokespersonSanctionsThe Secretary of StateTechnology

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#### STATE of Louisiana ex rel., Morris Frank KING v. Frank C. BLACKBURN, Warden et al.

No. 67832.

Supreme Court of Louisiana.

Nov. 21, 1980.

In re Morris Frank King, applying for remedial writs. Parish of St. Bernard. Nos. 40-728, 40-729, and 40-730.

Denied.
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#### Barbara K. CLARKE, Appellant, v. Richard J. SANDERS, Appellee.

No. 77-1585.

District Court of Appeal of Florida, Fourth District.

Oct. 11, 1978.

Rehearing Denied Nov. 20, 1978.

Hugh M. Davenport of Smith, Davenport, Peek & Bloom, Jacksonville, for appellant.

Michael P. Falkowski of Parker, Conrad, Falkowski, Johnson & Owen, Orlando, for appellee.

DAUKSCH, Judge.

In this malpractice case the trial court erred in refusing to allow in evidence at trial the depositions of two doctors whose testimony was quite relevant to the issue of malpractice. The reason the trial court gave for disallowing the introduction of the depositions into evidence was the plaintiff’s failure to list the names of the doctors on a pretrial statement. We find error because there was no pretrial order requiring the parties to list witnesses on a pretrial statement1 and even if there was an order, the failure to list their names was not so prejudicial to the defendant so as to require such a strong sanction as disallowing the presentation of the evidence. The defendant was quite aware of the proposed evidence and the doctors’ testimony because their names were furnished on answers to interrogatories; *the defendant took the depositions of the doctors;*the plaintiff had listed the bills of the doctors as being items to be introduced in evidence at trial; after the mistrial the defendant was again furnished the names of the doctors in answers to interrogatories; and the defendant made specific references to these doctors and their testimony by deposition during his opening statements to the jury at trial.

The trial court has broad discretion in these matters. *County of Brevard v. Interstate Engineering Company,*224 So.2d *844786 (Fla. 4th DCA 1969). The aggrieved party must show he was prejudiced by the court's abuse of discretion. *County of Brevard v. Interstate Engineering Company, supra.*Here the plaintiff was prejudiced because the two excluded depositions were of two doctors who gave testimony that the accused doctor had committed the malpractice. It is common knowledge it is difficult to obtain expert testimony in professional malpractice cases and it is obvious malpractice can hardly be proved without such evidence, so to exclude it could often ring the death knell for the plaintiff’s case. We are aware the plaintiff presented three other expert witnesses but the evidence offered by these two was not merely cumulative.

The plaintiff also appeals the judgment and the order denying the requested new trial saying the evidence was insufficient to support the verdict. Because we reverse on other grounds we need not get to that.

REVERSED and REMANDED for new trial.

BERANEK, J., and GREEN, OLIVER L., Associate Judge, concur.

1

. There was a pretrial order for the first trial which was a mistrial but not for this re-trial.