Irs memo 201504011.
index will be initiated each year.
Irs memo 201504011 is a Partner and Jan 15, 2025 · 1 This memorandum clarifies and updates advice provided in Generic Legal Advice Memorandum AM 2007-007 (AM 2007-007), which was issued by the Office of Associate Chief Counsel, International (INTL) in 2007, as described infra notes 4, 9, and 45. , Peyton v. As a result, the IRS determined that the items that can be included in COGS for a cannabis reseller are §1. The wellness program provides health screening and other health benefits such Chief Counsel (CC) notices are directives that provide interim guidance, furnish temporary procedures, describe changes in litigating positions, or announce administrative information. See section 3306(b) and (c). Employees electing to participate in the wellness program pay a required employee contribution by salary reduction through a section 125 cafeteria plan. 471 as these regulations existed when Sec. Employees electing to participate in the wellness plan pay an employee contribution by salary reduction through a § 125 cafeteria plan (and therefore the Mar 14, 2025 · This Chief Counsel Advice memorandum addresses the deductibility of theft losses under Internal Revenue Code (“Code”) § 165 for five hypothetical taxpayers (Taxpayers 1 through 5) who were victims of various scams in 2024. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax & Accounting)CC:ITA This Chief Counsel Advice responds to your request for non-taxpayer specific advice regarding the allowance of theft losses under Internal Revenue Code (“Code”) § 165 for victims of certain scams. Nov 27, 2015 · Last January, the IRS released Chief Counsel Memorandum 201504011, which sheds some interesting new light on what expenses a seller of marijuana businesses may and may not deduct, but in order to Apr 21, 2015 · The IRS was largely silent on the issues until 2011 when the DOJ issued another memo (downloads as a pdf) apparently reversing course. Designed for Answer Engine Legal advice signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers. They convey legal interpretations or positions of the Office of Chief Counsel regarding existing or former revenue provisions. 2003-146; Franklin v. The experienced tax professionals at Rex Halverson & Associates understand the tax issues facing owners of marijuana-based businesses, and we’re here to help you understand the laws and your tax compliance obligations. Memo. Id. QuickStart Guide to Accounting for Cost of Goods Sold IRS Chief Counsel Advice Memorandum Jan 24, 2015 · On Friday, the IRS released Chief Counsel Memorandum 201504011, which sheds some interesting new light on what expenses a seller of marijuana businesses may and may not deduct, but in order Jan 26, 2015 · In this memo the IRS addressed 2 issues: First, how do marijuana dispensaries which are from a federal law perspective trafficking in a controlled substance determine their cost of goods sold (COGS) for the purposes of IRC §280E of the Internal Revenue Code? Jan 23, 2015 · The IRS, in Chief Counsel Memorandum 201504011, decided that a class of taxpayers is effectively “exempt” from the provisions of IRC §263A. This memorandum addresses several common 72K subscribers in the IRS community. Situation 2. As Co-Directors of the IRS 2. The memo offers important clarification on when and how taxpayers may claim a theft loss deduction. The Office of Chief Counsel issued a memorandum (ILM 201504011) January 23, "Taxpayers Trafficking in a Schedule 1 or Schedule II Controlled Substance -- Capitalization of Inventoriable Costs," to explain the question, Hawkins noted, though she added that the issues raised in the memo are "very hard, if you're not immersed in accounting methods and inventory methodology and cost of goods sold. The wellness program provides health screening and other health benefits such index will be initiated each year. For purposes of this memorandum, these arrangements are known as Rollovers as Business Startups, or ROBS. Get help with your taxes from experts and fellow taxpayers. In addition, there shall be allowed as a deduction State and local, and foreign, taxes not described in the preceding sentence which are paid or accrued within the taxable year in carrying on a trade or business or an activity described in section 212 (relating to expenses for production of income). When S 280E was enacted in 1982, an inventoriable cost referred to any costs that could be capitalized to Internal Revenue Service Memorandum Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. May 26, 2015 · As an increasing number of states have permitted the use of marijuana for medical and recreational uses,1 questions have arisen about the federal income tax consequences for businesses that sell marijuana and their buyers. This report discusses the current federal tax treatment in brief for both the sellers of marijuana and their buyers. Most taxpayers aren’t asking to capitalize costs to inventory and would rather immediately deduct them, with the In 1981, the Tax Court allowed an illegal business to recover the cost of the controlled substances (i. HoutsmaAssociate Area Counsel (Small Business/Self-Employed)CC:SB:5:Den:2from : W. Stay ahead of the curve with news and updates. 23, 2015, the IRS Office of Chief Counsel issued Chief Counsel Advice (CCA) 201504011 to clarify that although deductions may not be claimed for trafficking marijuana, the CCA allows a cost-of-sales deduction for indirect Apr 24, 2025 · On March 14, 2025, the IRS Office of Chief Counsel (Chief Counsel) released advice memorandum number 202511015, addressing the deductibility of theft losses under IRC § 165 for scam victims. In Year 13, Foundation Manager 1 approached the Foundation’s tax return preparer and administrative services provider (Return Preparer), regarding his plan to purchase all of the remaining equity in Company 2. Each ruling, technical advice memorandum, or Chief Counsel advice contained in this publication is directed only to the taxpayer who requested it or with respect to whom it is issued. states allowing the sale of cannabis grows, owners of cannabis businesses face the question as to which business expenses are deductible for federal income tax purposes. Internal Revenue Bulletin The Internal Revenue Bulletin (IRB) is the authoritative instrument of the IRS for announcing all substantive rulings necessary to promote a uniform application of tax law. g. Aug 1, 2022 · As the number of U. Jan 10, 2024 · Understand how cannabis companies can benefit from depreciation on tax returns. Federal Income Tax Withholding Section 3402(a) of the Code, relating to U. Jun 24, 2025 · This guide provides information on federal tax law and identifies pertinent print and online resources available through the NYU Law Library. 1. 471-11. Section 6511(a) provides that, in general, a claim for credit or refund of an overpayment of any income tax in respect of which tax the taxpayer is required to file a return shall be filed by the taxpayer within three years from the time the return was filed or two years from the time the tax was paid, whichever of such periods expires the later. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax Commissioner, T. 251, provides guidance on the section 162(l) deduction for 2-percent S corporation shareholder-employees. When a written opinion is provided, a copy should be retained for association with any related matter, subsequently proposed deficiency notice, or docketed case. e. 2006-84. Applied literally, §280E severely penalizes taxpayers that traffic in a Schedule I or Schedule II controlled substance but don’t use an inventory method for the controlled substance. But it turns out not to be a win for these taxpayers. Sep 14, 2020 · The 280E “guidance” generally refers back to their 2015 Memorandum, see (Chief Counsel Advice 201504011 released 1/23/2015) wherein the IRS advised section 280E-affected taxpayers must calculate their cost of goods sold pursuant to Internal Revenue Code section 471 and the associated Treasury Regulations. C. Transcription of Internal Revenue Service Memorandum - IRS tax forms 1 Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax & Accounting)CC:ITA Internal Revenue Service Memorandum Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. A 2-percent shareholder-employee in an S corporation, who otherwise meets the requirements of section 162 (l), is eligible for the deduction under section 162 (l) if the plan providing the medical care coverage for the 2-percent shareholder-employee is The Freedom of Information Act (FOIA) Library provides a comprehensive list of documents and other information available electronically on IRS. A request for a TAM generally stems from an examination of a taxpayer's return, a consideration of a taxpayer's claim for a refund or credit, or any other May 29, 2025 · A technical advice memorandum, or TAM, is guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director, appeals, in response to technical or procedural questions that develop during a proceeding. On Jan. The IRS Chief Counsel released this memorandum in January 2015 in order to respond to questions the IRS was receiving from practitioners. Section 6110(k)(3) of the Internal Revenue Code provides that letter rulings, technical advice memorandums, and Chief Counsel advice may not be used or cited as precedent. 10 It also discussed that its Examination and Appeals section could require a taxpayer to change from a method of accounting that did index will be initiated each year. " See, e. ISSUE Is a benefit paid under an employer-provided self-funded health plan included in income and wages if the average amounts received by the employees for participating in a health-related activity predictably exceed the after-tax contributions by the employees? ISSUES Whether, under the circumstances described below, the hypothetical willing buyer and willing seller of shares in a company would consider a pending merger for purposes of valuing stock for gift tax purposes. The document, however, was too inscrutable for most people to use it, Hawkins said (16 DTR K-1, 1/26/15). 471-3 (c) and 1. . Dec 27, 2024 · Private letter rulings (PLRs), technical advice memoranda (TAMs) and field service advice memoranda (FSAs) are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and/or Internal Revenue Service officials. 2021-26, the taxpayer claimed charitable contribution deductions but failed to attach qualified appraisals of the donated property to his tax returns. Nov 13, 2025 · The Chief Counsel for the Internal Revenue Service provides advice to the IRS Commissioner on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue laws, represents the IRS in litigation, and provides all other legal support needed by the IRS to carry out its mission of serving America’s taxpayers. It also exposes gaps in the current law that leave many taxpayers without meaningful relief. The memo (ILM 202114019), dated January 23 and released April 9, addresses the costs that a merchandise reseller may capitalize into inventory under section 471 without addressing the limitation on deductions applicable to state-legal marijuana businesses under section 280E. EXECUTIVESUMMARY A version of a qualified plan is being marketed as a means for prospective business owners to access accumulated tax-deferred retirement funds, without paying applicable distribution taxes, in order to cover new business start-up costs. LANDSCAPE In 2001, the Nevada Legislature decriminalized the sale and use of medical marijuana by passing Assembly Bill 453 (AB 453). Jul 18, 2025 · This post serves as a structured index of cannabis tax law, anchored in IRC §280E and its cascading effects on depreciation, amortization, inventory accounting, and cost recovery. We are aware that taxpayers have suffered losses from various scams perpetrated by unknown individuals operating domestically and internationally. Federal Income Tax Withholding (FITW), generally requires every employer making a payment of wages to deduct and withhold upon those wages a tax determined in accordance with prescribed tables or computational procedures. Transcription of Internal Revenue Service Memorandum 1 Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. It links to in-depth analyses of key Code sections—including §168 (k), §471 (a), and §197—as well as Treasury regulations, Tax Court rulings, and administrative guidance. es. Apr 18, 2008 · This memorandum responds to your request for assistance, which is a follow-up to the advice on the use of state tax data for compliance purposes that we provided by memorandum dated July 17, 2006. First to consider is the Service’s conclusion in Chief Counsel Memorandum Number 201504011 regarding Sec A IRS chief counsel advice memorandum (CCA 201504011) released in January said that some marijuana businesses could exclude the costs of goods sold for income. Jun 9, 2023 · In this memo, “nonprofit NIL collective” refers to an organization claiming tax exemption under section 501(c)(3) that develops paid name, image, and likeness opportunities for student-athletes, regardless of whether the organization engages in other purportedly exempt or nonexempt activities. May 6, 2020 · As noted above, there is currently no guidance from the IRS regarding this question and, we should assume, that the IRS will not acquiesce to the position that 471 (c) eliminates 280E. , Achieving a Better Life Experience (ABLE) Act of 2014, enacted on December 19, 2014, as part of The Tax Increase Prevention Act of 2014 (Pub. View more information about Written Determinations or Using IRS Forms, Instructions, Publications and Other Item Files. Jan 13, 2023 · The Tax Court found that the petitioner subjectively determined that its partnership interest was worthless and, to determine whether there were also objective indicia of worthlessness, examined whether the partnership interest had liquidating value or any potential future value. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax & Accounting)CC:ITA Nov 30, 2018 · In the decision, Judge Holmes endorses the reasoning in IRS Chief Counsel Advice Memorandum 201504011 (2015) regarding the interaction of Section 263A and Section 471 with respect to cannabis-related cost of goods sold (COGS) calculations. Sec. May 12, 2025 · IRS Written Determinations Internal Revenue Service Includes all types of Written Determinations, including Chief Counsel Advice, Technical Advice Memoranda, and Written Determinations. 280E does not disallow a marijuana business’s adjustments to gross receipts for COGS, but those write-offs are more limited than for other businesses [IRS Chief Counsel Memorandum, 201504011]. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax & Accounting)CC:ITA Jul 29, 2019 · Further, Chief Counsel Advice (CCA) 201504011 memo concluded that although marijuana-related businesses are permitted to determine COGS, they must do so using the S 280E as it was enacted in 1982 and S 471, which makes the provision for the use of inventories to determine business income. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax Transcription of Internal Revenue Service Memorandum 1 Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. Section 3402(a), relating to federal income tax withholding, generally requires every employer making a payment of wages to deduct and withhold upon those wages a tax determined in accordance with prescribed tables or computational procedures. IRS Written Determinations do not contain proprietary ("Official Use Only") information. L. A mortgage broker who is a broker of financial instruments is not in a real property brokerage trade or business within the meaning of § 469(c)(7)(C). Aug 1, 2018 · Practitioners are more likely now than ever to be asked to consult with clients that may either be considering or are currently involved, directly or indirectly, in a state-legal cannabis business. Feb 8, 2016 · On January 23, the IRS released Chief Counsel Memorandum 201504011, which sheds light on how taxpayers trafficking in controlled substances, such as marijuana, determine costs of goods sold (also known as “COGS”), and if the IRS can require taxpayers trafficking in controlled substances to change their method of accounting for costs if the Jan 2, 2020 · The IRS acknowledges that Sec. Notwithstanding the preceding sentence, any tax (not described in the first sentence of this Jun 28, 2024 · In 2015, the IRS indicated it might be softening. An employer provides all employees, regardless of enrollment in other comprehensive health coverage, with the ability to enroll in coverage under a “wellness plan” that qualifies as an accident and health plan under § 106. That same year, the IRS played hardball, disallowing expenses Tax Reduction Letter rigorously documents sources and authority for every tax-saving strategy The IRS’s Chief Counsel Advice (CCA) 201504011 was provided to clarify the COGS deductions available to cannabis enterprises. 280E and 263A and a recent IRS Chief Counsel Advice ( CCA 201504011 ). We know the challenges and we’re here to help you stay compliant and protect you from undue harassment and penalties. A memorandum providing legal advice should be tailored to the needs of the recipient and Jul 1, 2015 · This article examines the unique income tax issues that are faced by regulated marijuana businesses and their CPAs. , amphetamines; cocaine; marijuana) obtained on consignment and also to claim certain business deductions (a portion of the rent he paid on his apartment which was his sole place of business, the cost of a small scale, packaging expenses Jan 26, 2015 · Marijuana Dispensary Income Tax Guidance Update: IRS Memo 201504011 01/26/2015 Internal Revenue Service Memorandum Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. As the popularity of cannabis increased, IRS Memorandum 201504011 took another look at the tax deduction question. An employer provides all employees, regardless of enrollment in other comprehensive health coverage, with certain benefits under a wellness program. So, let’s consider the arguments the IRS might make. The memorandum aims to determine if these taxpayers sustained a theft loss deductible in 2024, considering the specific facts of each scenario and the relevant tax law. Issues after June 2003 are available in both HTML and PDF formats; earlier Apr 12, 2016 · The IRS issued limited guidance under Chief Counsel Advice 201504011,9 which discusses how a taxpayer trafficking in a Schedule I or II substance would determine cost of goods sold for purposes of Section 280E. gov. Section 280E reads as follows: No deduction or credit shall be allowed for any amount paid or incurred during the taxable year in carrying on any trade or business if such trade or business (or the activities which comprise such trade or business) consists of trafficking in controlled substances (within the meaning of schedule I and II of t Dec 1, 2019 · IRS Chief Counsel Advice (CCA) memorandum 201504011, issued in December 2014, requires taxpayers trafficking in a Schedule I or II controlled substance to determine COGS using the applicable inventory costing regulations under Regs. at *28-29, *31-32. This memorandum from 2015 clarifies how to apply IRC 280E and the regulations under IRC 471 to a cannabis operator and is still relevant today. 1993-184; McHan v. Office of Chief Counsel Internal Revenue Service memorandum Number: 202436010 Release Date: 9/6/2024 CONCLUSION No, section 245A(a) does not allow a deduction to FC1 for the FC2 Dividend. index will be initiated each year. Apr 8, 2025 · The Internal Revenue Service reached a deal to share tax information about some immigrants without legal status, marking a major change in how tax records can be used. Situation 4. Most taxpayers aren’t asking to capitalize costs to inventory and would rather immediately deduct them, with the Jun 28, 2024 · In 2015, the IRS indicated it might be softening. B. In terms of authority, the various materials 1983 OMB Memorandum In 1983, OMB issued a Memorandum regarding “Treasury and OMB Implementation of Executive Order 12291” Waived all review procedures of tax regulations Rationale: tax regulations merely interpret the Code, so the cost of such regulations is really attributable to the underlying statute index will be initiated each year. Dec 17, 2018 · As a result, in 2015 the IRS ruled in Chief Counsel Memorandum 201504011 that a taxpayer in the marijuana industry, whether medicinal or recreational, may not use the provisions of Section 263A Sep 15, 2020 · In response to questions of how to compute Cost of Goods Sold for Taxpayers in the cannabis industry, the IRS published CCA 201504011 on January 23, 2015. Feb 8, 2010 · Although relatively routine and simple questions may be addressed orally or by email, legal advice should generally be provided by memorandum. Jun 28, 2022 · This is the IRS memo for summary judgment on the deduction disallowance. 1983 OMB Memorandum In 1983, OMB issued a Memorandum regarding “Treasury and OMB Implementation of Executive Order 12291” Waived all review procedures of tax regulations Rationale: tax regulations merely interpret the Code, so the cost of such regulations is really attributable to the underlying statute (2) Yes, unless the taxpayer is properly using a non-inventory method to account for the Schedule I or Schedule II controlled substance pursuant to the Code, Regulations, or other published guidance. While ROBS would otherwise serve Notice 2008-1, 2008-1 C. In emails to the Return Preparer, Foundation Manager 1 raised concerns that purchasing additional Company 2 shares might cause Company 2 to become a disqualified person with respect to The Stephen Beck, Jr. Chief Counsel Advice (CCA) 201504011 As a result of these rulings, the IRS determined that marijuana-related businesses could claim certain COGS deductions. Jan 30, 2015 · On January 23, the IRS released Chief Counsel Memorandum 201504011, which sheds light on how taxpayers trafficking in controlled substances, such as marijuana, determine costs of goods sold (also known as “COGS”), and if the IRS can require taxpayers trafficking in controlled substances to change their method of accounting for costs if the taxpayer currently … Aug 1, 2018 · Practitioners are more likely now than ever to be asked to consult with clients that may either be considering or are currently involved, directly or indirectly, in a state-legal cannabis business. This dichotomy Did you receive an IRS notice or letter? Search for your notice or letter to learn what it means and what you should do. Jun 24, 2025 · "A technical advice memorandum, or TAM, is guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director, appeals, in response to technical or procedural questions that develop during a proceeding. Commissioner, T. 113-295), required the establishment of a voluntary program for TPPs to apply to the Internal Revenue Service (IRS) to become certified as a CPEO and added new Code sections 3511 index will be initiated each year. S. 471-3 (b) and for a cannabis producer, § 1. ILM 201525010 A recently released IRS legal memorandum appears to be intended to clarify inventory tax accounting principles for state-legal marijuana businesses despite not mentioning the restriction they face, according to practitioners. Coverage begins with 1999. IRS Private Rulings and Advice TaxNotes Filter by 'Legal Memorandums'. Many index will be initiated each year. AB 453 legalized the use of marijuana for “treatment of certain Fortunately, IRC §280E medical conditions,” in spite of the fact that marijuana remains illegal is tempered by other tax court case findings that can provide under federal law. Learn the rules, benefits, and how to implement this in your business. It is important to note that, pursuant to 26 USC 6110 (k) (3), such items cannot be used or cited as precedent. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax & Accounting)CC:ITA Transcription of Internal Revenue Service Memorandum 1 Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax IRS Interpretation Causes Reefer Madness By Michael Kosnitzky and Matt Kaden Michael Kosnitzky and Matt Kaden examine the tax treatment of expenses incurred in a legal (under state law) marijuana business. Internal Revenue Service Memorandum Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. Jan 19, 2015 · Back in June 2014 I blogged about the new IRS Regulations governing tangible personal property. May 12, 2025 · Chief Counsel Advice (CCA) are legal advisories written by the Chief Counsel's National Office to advise IRS personnel at all stages of case development. Find… Jul 23, 2021 · Harrison Smith and Justin Abold-LaBreche are improving IRS communication efforts. Section 6110(k)(3) of the Internal Revenue Code provides that letter rulings, technical advice memorandums, and Chief counsel advice may not be used or cited as precedent. Thomas McElroy, TechnicianReviewerOffice of Associate Chief Counsel (Income Tax & Accounting)CC:ITA ILM 201504011 Chief Counsel Memorandum states that when auditing a cash-basis marijuana facility, the IRS has the authority to permit the taxpayer to deduct from gross income its costs that w ould have been inventoriable had the taxpayer been on the accrual method. Thomas McElroy, TechnicianReviewerOffice of Associate Chief IRS guidance in Plain English This is a starting point for understanding some of the basic guidance issued by the IRS. The trust’s purported “asset protection” benefits, including whether state or federal courts will find that the terms of the trust provide protection from the claims of creditors including claims pertaining to federal tax debts. 280E was enacted. Apr 9, 2019 · In addition to these court cases, tax professionals can rely on IRS Chief Counsel Memorandum CCA 201504011. Though a medical marijuana business is illegal under federal law, it remains obligated to pay federal income tax on its taxable income because §61 (a) does not differentiate between income derived from legal sources and income derived from illegal sources. Included in their discussion are Code Secs. These regulations prompted a vigorous debate over the last 7 months between the most astute students of the US Tax Code as to what constitutes the need to file IRS Form 3115 – Change in Accounting Method for our business clients as a direct result of these new governing regulations. Select Technical Memoranda may also be available on free internet resources, like Legalbitstream. com. As the Internal Revenue Service Memorandum Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201504011 Release Date: 1/23/2015CC:ITA:6 LFNolanIIPOSTS-125750-13 , , , , , : December 10, 2014to: Matthew A. twlaytusvvdvptdhmzazhdwgaerurtvznojcecajhnhyuizfzjjnxcdsjvwqfyszbzimvgoiqvma