Case Assignment Study Example | Topics and Well Written Essays - 1000 words - 1

Task - Case Study Example A portion of the types of viciousness happen because of the impact of medications which may drive the specialist to assault his coworkers. A laborer may feel that a portion of the arrangements presented in the work place undermine his vocation. Down measuring the association or a compensation diminishing may bring about a rough assault by a specialist. A few laborers may result to viciousness after delayed disappointment in the work environment. ID of fierce conduct in the work environment is pivotal to the activities of the association. The laborers and the executives have the commitment to recognize possible dangers in the work environment. Favorable work space will improve profitability and empower the association to save money on cost identified with vicious frequencies in the work environment (DeCenzo, Robbins and Verhulst, 2010). The wellbeing and security Act gives the businesses the obligation to recognize and dispose of the considerable number of treats to the association. Savage conduct among the laborers represents a huge danger to the association along these lines the administration ought to recognize and wipe out any wellspring of brutal conduct in the working environment. The worker has the obligation to guarantee that his own security in the working environment. The laborers are continually collaborating in this manner distinguished brutal conduct ought to be accounted for to the administration for guaranteed activity. The laborers and business are similarly answerable for viciousness in the work environment. Laborers reserve the option to report any rates that may result to savagery. The management’s obligation is to act capably to guarantee that the savagery doesn't influence the activities of the association. The contextual investigation reports that a portion of the laborers recognized McDermott when they heard the updates on the occurrence at Edgewater Technology. McDermott had arranged his ambush to devastate the company’s picture (Waring and Glendon, 2001). McDermott’s outrage was because of the compensation decline the organization was going to

Gods Plan free essay sample

Luke 14 refrain 12 says this, â€Å"When you give a supper or a meal, don't welcome your companions or your siblings or your family members or rich neighbors, in case they additionally welcome you consequently and you be reimbursed. Be that as it may, when you give a dining experience, welcome poor people, the disabled, the weak, the blind.† I like to consider book of scriptures the authority â€Å"manual for life.† In this manual God sets the standard for us. He shows us exercises through the duration of Jesus and as Christians we realize that they generally will be reality. In any case, now and then it is significant for us to learn exercises through our very own understanding. I took the expressions of Luke and comprehended them to be what God asks of me. In any case, not until 3 years prior did I really comprehend or live this educating. My closest companion in grade school was a medically introverted kid named Brian. He was extremely kind and never judged. We will compose a custom article test on Divine beings Plan or then again any comparable subject explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page He cherished baseball and playing the cello. He was so capable, yet he was unique and I knew it. I really treasured each second we spent together and I committed an error when I entered center school. I let Brian just become a face to go in the corridors, not on the grounds that I didn’t love him any longer but since it wasn’t advantageous for me to have a companion who continually required my guide. That was narrow minded of me, egotistical. I not, at this point even idea about being companions with individuals that were unique in relation to me since I had such a large number of companions that were the equivalent. I did what was best for me. This was before I knew God’s plan for me. Sophomore year, my auditorium class put on an act called â€Å"The Jellybean Conspiracy.† This show was an emblematic presentation lecturing that we are all jellybeans in the incredible large container of life and however we are for the most part various shapes and hues we are actually no different. The greater part the cast in this show were extraordinary requirements understudies. The show was an exercise for the crowd as well as an exercise for me. Individuals I once observed as being so not the same as I ended up being one in the equivalent. I genuinely had a momentous bond with this cast. After the show finished, I didn’t let my companionship with my new companions blur. On thursdays, I work with the mentally unbalanced class. Together, we move, mess around, make up handshakes, and simply make some extraordinary memories with each other. I wind up having lunch with my companions. At times we play outside when the climate is decent. These individuals who society iso lates us from, turned into the individuals I call my closest companions today. Despite the fact that occasionally it isn’t simple and I experience difficulty understanding why my companions do certain things, I end up associating with them. Not every person can interface with understudies with incapacities. Fortunately, God favored me with a blessing and I intend to utilize my blessing to make new companions as well as ideally to change lives. At prom this year, I left the move floor to go get some water. I saw Brian with his guide moving in the corner. After not seeing Brian for a long time, I required a reconnection with my youth closest companion. Incredibly, he recalled my name helping me how extraordinary to remember a companion he truly was. I snatched him and maneuvered him into the move floor. He dazzled the group with his wild moves and toward the night's end, he had more fans than any other time in recent memory. I am appreciative to such an extent that I had the option to reconnect with my companion in the wake of having a difference in heart as well as a difference at the top of the priority list, because of a little exhibition I did with my ad lib class. Today I am the organizer of the Buddy Program at my school. This program urges the companionships like those of the ones I have been fortunate enough to have, for different understudies. I would now be able to take the expressions of Luke and get them, yet live them. I no longer discover individuals not quite the same as me â€Å"un-friendable.† The blessing that my companions with incapacities have given to me is so incredible and by a wide margin the best exercise I have ever learned. These kids have completely changed me and I intend to utilize my instruction at Villanova to change theirs.

Analysis of Campbell v Mirror Group Newspapers judgment Essay

Examination of Campbell v Mirror Group Newspapers judgment - Essay Example In the last judgment the House of Lords noticed the expressions of Lord Wolf in A v B and C when he stated, ‘for our part we would see that the way that an individual has accomplished unmistakable quality on the open stage doesn't imply that his private life can be uncovered by the media. We don't perceive any reason why it ought to fundamentally be in the open intrigue that a person who has been received as a good example, without looking for this qualification, ought to be shown to have feet of clay.’1 The realities of the case are vital for an obvious comprehension of this declaration. Following the production of articles with going with photos exhibiting model Naomi Campbell’s treatment and participation at Narcotic’s Anonymous gatherings, Campbell recorded an objection in the High Court for harms for intrusion of security. The High Court found in support of her. On offer to the Court of Appeal the High Court’s judgment was turned around and the Court of Appeal found that on the realities, ‘that since Ms Campbell had pursued exposure and made a special effort to advance a medication free media picture, the Mirror was qualified for set everything on the right track, independent of the techniques it used to reveal the story. The Appeal Court makes a decision about concluded that treatment didn't fit the bill for legitimate insurance similarly as treatment by a specialist, and that production of the subtleties of Ms Campbells treatment was important to loa n the story credibility.’2 On advance to the House of Lords, the Court of Appeal’s discoveries were dismissed and the High Court’s administering was maintained. The House validated its discoveries by finding some kind of harmony among protection and opportunity of articulation as contained in Articles 8 and 10 of the European Convention on Human Rights. 3 Master Hope, in conveying his assessment for the House of Lords said of the Court of Appeal’s discoveries, ‘they

Should Assisted Suicide be an Option - Free Essay Example

Assisted suicide, also known as Euthanasia, is the painless killing of a patient suffering from a terminal painful disease/sickness which is performed with the assistance of a physician or doctor by being injected with lethal drugs causing a painless death. The problem is that patients and physicians cant agree on whether assisted suicide should be legal or not because majority believe that people deserve the right to decide on whether they want to consider assisted suicide, while others conclude that the legalization of assisted suicide will be the cause of widespread assisted suicide among the terminally ill. If the two opposing sides dont come to a compromise, then many terminally ill patients, who dont want to deal with the pain and thought of passing at any moment, cant do so by choosing assisted suicide. An agreement the two sides could agree coming to is asking the courts to situate boundaries on the reasonability for why a patient can consider assisted suicide. For one requirement, the terminally ill patient should be required to take a mental evaluation to help identify if they are stable to figure out if the patient is abusing assisted suicide. Another requirement would be, if the person is predicted to pass away in six months or less then, the patient should then be given this option. The third option being that the courts should make the final decision on whether or not the person is allowed to go commit the assisted suicide. The first compromise the two opposing sides could come to is doing a mental evaluation for the terminally ill patients who choose to do assisted suicide. The mental evaluation would happen before the patient goes through with the process of assisted suicide and would help with reducing the amount of vulnerable patients who go with assisted suicide by determining the true intentions of why the patient would choose to do so. For example, if a patient is rational enough to come to terms with their illness and has recognized the suffering their illness can bring, then this would be the ideal state of mind. However, if the patient is depressed and is not in the right state of mind to go through with assisted suicide, then they could not do so. This solution could help figure out which patients are the vulnerable and easily manipulated. This can also help reduce the widespread assisted suicide of the vulnerable, which is what most people are afraid of. Another solution that the two opposing sides could come to an agreement upon is if the person is predicted to pass in six months or less. This solution would work by diagnosing the patients with their illness or state and the amount of time they have to live. Once the patients figure out what their diagnosis is, then they can inform their doctor on whether or not they want consider assisted suicide as an option. This solution has already been implemented for states who have legalized assisted suicide. This solution will also be able to prevent the widespread use of assisted suicide. A final solution for the opposing sides to come to is to eliminate the doctors from the decision making process and let the courts handle the decision on whether or not a terminally ill patient is allowed to go through with assisted suicide. This solution could help with knowing the patients made the decision on their own and were not pressured into choosing assisted suicide by their doctor. This solution contributes to both sides by allowing assisted suicide and by helping the vulnerable patients make their own decisions so they are not manipulated or pressured into a decision that doesnt align with their personal choices. Taking the doctors out of the decision making process will help prevent that situation from happening by eliminating the bias the patient has towards the doctor and vice versa. For this solution to come into play though, it needs to be implemented as a law to prohibit doctors from having a say in whether or not a patient decides on assisted suicide. Having only th e courts decide on whether or not a patient can go with assisted suicide could help prevent manipulation of those who are indecisive. Even though the doctor is out of the decision making, it does not eliminate all manipulation. But, should still be considered a way to help eliminate most manipulated. Assisted suicide should be legal because it could help terminally ill patients be relieved of their terminal illness. Three solutions that could help the two opposing sides of assisted suicide come to an agreement is: a person should be provided with a mental evaluation for the patient who chooses this option so that the assisted suicide is not abused by people who can be treated, if the person is predicted to pass on in six months or earlier, they should be allowed this option, and the courts should decide whether or not a person is allowed to go through with assisted suicide. These are the three best solutions for the two sides to come to an agreement on because it favors both sides in multiple ways.

John Owen s Holy Spirit - 1235 Words

JOHN OWEN’S VINDICATION OF HOLY SPIRIT’S DEITY AND ITS BENEFITS FOR BELIEVERS Against the Socinians, John Owen vindicated the deity of the Holy Spirit, as well as his benefits for believers, within a Christological context. The Socinians were not the only opponents Owen dealt with, but they were notorious for their anti-Trinitarian views. On Owen’s theological engagement, Crawford Gribben assessed the Socinian threat as a gift to Owen for drawing â€Å"attention to the ambiguity of the boundaries of orthodoxy permitted by the state,† and that Owen â€Å"took advantage of the moral panic.† While it is true that Owen produced theological works in response to Socinianism, Owen regarded Socinianism as a major threat. The same applies to other†¦show more content†¦Before examining the doctrines of Socinian and those of Owen, however, it is important to consider the historical context of these theological controversies. Historical Context John Owen’s Context John Owen (1616-1683) was born in Stadhampton, near Oxford, to Henry Owen, a man of Puritan sympathies. After finishing local grammar school, Owen matriculated at Queen’s College, Oxford, in 1631. Owen achieved his Bachelor of Arts in 1632. He finished his Master of Arts studies in 1635 and ordained deacon. Then Owen engaged in a 7-year course for a Bachelor of Divinity. In 1642, Owen published A Display of Arminianism, the first among many of his works. Owen soon received much attention and was invited to preach before Parliament. In 1649, after the execution of Charles, Owen again preached to parliament. Here, Oliver Cromwell was present and chose Owen as his chaplain. Owen was then appointed Dean of Christ Church, Oxford, in 1651. In the following year, Owen became vice-chancellor and served until 1657. As a preacher who joined Cromwell’s revolution, Owen’s appointment was a symbolic victory over monarchy. In other words, the new appointments to key university positions were symbolic of the wider ambitions of the Cromwellian administration. As the â€Å"Oxford Reformer,† as Gribben put it, Owen promoted Calvinistic piety that transcended the political and cultural division of the university. In 1651, for example, Owen outlined the qualities of Calvinistic piety when heShow MoreRelatedTradition And Rules Of The Gospel Of Christ Essay1465 Words   |  6 Pagesrevelation of Jesus Christ by the Holy Spirit and accepted as a gift from God. Paul`s gospel stresses that God`s plan is for the development of a relationship with his creation and not in human`s ability to follow tradition and rules. The gospel of Christ is so much more than religious tradition handed on by human authority and Paul vehemently advised the Galatian church that his authority did not come from human hands but was coming directly from God. 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The Black Cat By Edgar Allan Poe - 1142 Words

A bunch of stories have happy endings right? The prince gets the princess, main character survives eight shots to the torso, all happy endings. Edgar Allan Poe isn’t like that. Most of his characters are dark and insane. They have one last shred of sanity then they refuse to keep it and then they end up going insane, much like the characters in The Black Cat, The Raven, and A Tell-Tale Heart. All three the men reach insanity. In The Black Cat a man expresses his passion over all animals. He has a gorgeous black cat named Pluto,his prized possession. Years later this man has a horrible addiction to alcohol, which makes him get awful mood swings. When he gets angry he abuses his animals, and his wife. The only thing that he treats with†¦show more content†¦He is determined to kill this cat but the wife stands in the way. He ends up putting the axe in her head. He realizes that he will be charged with murder. He decides that he has to hide the body. The cellar was made of a plaster wall. He buries the body in there like a tomb. He goes to put the cat in the tomb and realizes that it is missing. Days after cops come to his home. They want to look at the property to see if she was murdered. The man shows them every place. Even the room where the body is hidden. He taps on the wall where her body is behind. Suddenly there is a tapping from the wall. The police move the man aside and investigate. Findi ng the body of the wife,and the black cat is sitting there on her. In The Raven there is a man who is insane from the beginning. He is mourning over the loss of his wife Lenore. This man is sitting and is falling asleep when there is tapping on his door. He gets up to answer the door and opens it to no one. He sits back down. Suddenly there is a rapping at window. He gets up and opens to window thinking it is the screen of the window. Rapidly this raven comes flying into the room and fly to his door. The raven just sat there sitting and looking at him. The man asks the raven it’s name. The raven simply replies Nevermore. The man tells the bird that he has to leave. The Raven replies Nevermore. The man sat down it a velvet chair. He looked intently at the bird. The bird seemed to be smiling. Again he replied Nevermore. The man

Taxation - Theory - Practice and Law Modern Treaty Law

Question: Describe about the Taxation, Theory, Practice and Law for Modern Treaty Law. Answer: Case Study 1: Residence and Source Requirements As per the Case Study, Fred is a temporary resident of Australia who is a sub-category of resident and special rules apply to these residents. Basically, somebody who holds a temporary visa like a working holiday visa or the visa of an employer sponsored from abroad are defined as temporary residents. As per the Case Study, Fred comes to Australia who is a British corporation in the management consultancy and he wants to set up a branch there. For 12 months, he leased out a resident in Melbourne. He was accompanied by his wife though his sons do not accompany him because of their college. The behaviour of Fred in Australia was similar to that of the United Kingdom. Fred has rented out a family home but he has to ignore his foreign rent because he holds a temporary resident visa. Fred also earns his interest from his investments which he has in the France. Fred returns to the UK after 11 months after he arrived in the Australia. There are many other issues that a temporary resident has to consider. Temporary residents are subjected to capital gains tax (CGT) rules for the foreign residents. There are certain rules where the capital gains tax is a share or right which are obtained under the employee share scheme or have been a temporary resident. It means that a temporary resident is subjected to capital gains tax on Capital gains tax events happening to the taxable Australian property (McGee, 2011). The Migration Act 1958 states that a person holding a temporary visa is called a temporary resident. (Grewcock, 2011). According to the Social Security Act 1991, they are not temporary residents. (Thompson and Maginn, 2012). Fred is a temporary resident and is subjected to capitals gains tax in Australia on asset which are taxable Australian property. Fred ceases to be a temporary resident and so he will be subjected to the tax in Australia on his capital gains and worldwide income. Any capital losses or capital gains Fred has made in respect to the assets held in the United Kingdom will become a Subject to the capital gains tax in Australia and the cost base for the assets will be set in accordance to the market value of the assets (Burman, 2010). Fred will receive a credit in the foreign tax for any tax paid in the United Kingdom on the gains. When Fred departed Australia, he is able to cash in his superannuation balance. There are also additional sections of the tax returns that require to be completed in a year that Fred becomes a temporary resident and that year Fred would have to cease being a temporary resident. Lodgement obligations must be met and tax refund has to be made sure because Fred is entitled to a refund in the tax. Fred may also be exempt from paying the Medicare levy, which is 1.5% tax on Australian income. Case Study 2: Ordinary Income Californian Copper Syndicate Ltd v Harris (Surveyor of Tax) (1904) 5 TC 159 The principle guiding the court decisions in this congested are of taxation law of Australia and the Lord Justice Clerk articulated this in the Californian Copper Syndicate Limited v Harris. This is the case within New Zealand. The Income Tax was assessed with questions and this is a principle settled well. The owner who has an ordinary investment gets a greater price after choosing to realize the Income Tax. The values are enhanced and there was a profit for the accessibility to the Income Tax. It enhanced the values acquired from the conversation or the realization of the securities measuring where it is done is not the investment change but the act done carrying in and out of the business. The association of the person buying and selling of the securities or the land hypothetically in order to deal with such investment is because the business seeks to make gains. There is difficulty in defining the two classes of the cases and each case is considered in accordance with the facts, the sum of the profits which are mere enhancement in the value by the realisation of the security or the profit made in the business operations to carry out a scheme in order to make gains. A Delphic significance is given to the Californian Copper Syndicate Ltd v Harris for the oft citation of the truism. But there furnishes no criterion for the determination of such questions which is before the court in this case. The income is the business production. But it depends on the nature of the business and the relationship of the source which is profited by the business. Everything which the taxpayer gets is not necessarily the income. A significant aspect of the decision was the business activities of the taxpayer who served as the auditor of the company Rangatira Limited. The taxpayers capital funds was maintained by the directors policy and made sure that the dividend yield was that of the regular income stream. Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 In this case, when the law changed it represented the high water mark for non accessible receipts. In order to obtain the coal assets incorporation was done by the taxpayer in the New South Wales from a related company. The taxpayer has not been carrying out mining in any of these lands though it may be for a short period. In the past history, this land In the Newcastle area, there was further land where the coal was mined until it got exhausted. In a large way the land in the sub-division was sold by the firm. In the previous years, there were minor sales. There was forty five acres of land which was set aside for the Lambton town for the production of homes for miners. Roads called Russel Road was built in the subdivision where there was twenty four acres of land. The appellant commenced for pushing the sale of the land and gained expenditure in sub dining in order to make the land look attractive to the buyers. Railway stations as well as roads for 5,000 were constructed and publi c institutions received land like churches and schools there were land for the parks as well (Duncan, 2012). Newcastle Hospital bought a large area of land. In order to hold the gain, there were a number of statements of principles from decided cases requiring qualification. . Weights should not be attached to any circumstances that every year there had been large sales. Parts of the estate should be laid out with the sewers and the roads sold it in building lots and it is done for the owner. The Hudsons Bay will not apply to Scottish Australian Mining as there has to be a nature to purchase the land which merely turns property into money. It took two days to hear the Scottish Australian Mining Case as showed by the Commonwealth Law Report and the judgement was determined at the first instance. The information about the extended hearing of the cases is given by the dates which are not a part of the court case. The activities of the taxpayer were not enquired factually or there was a disagreement about the accounting or issues related to the case. The fact of treating the substantially commercial exercise as a mere realisation is well explained here (Aust, 2013). FC of T v Whit fords Beach Pty Ltd (1982) 150 CLR A block of land was purchased by the taxpayer guaranteeing the shareholders. These shareholders were the proprietors of the fishing shacks which was accessible to the nearby beachfront. It was not intended to make profit by selling it. The sub divisional needs included road construction as well as installing sewers as well as other services needed. The scale and capture is not different from that occurring in the Scottish Australian Mining Co Ltd. Case. There was success in changing the mind of the firm for changing the purpose as well as the ownership and it reflected the associations and the articles. There is a doubt in this case as to the gains resulting from developing the subdivision as well as selling the land which is taxable and it has not been for the change in the ownership. There is a distinction between the net profits and the gross receipts and it has not risen according to the legislation of the United Kingdom or under the gains which was based on the tax systems but is essential in the Australian context as once the gross income is brought into the account. A statutory provision was pointed by the taxpayer relating to deductions allowable if the income which is accessible is unequal to the taxable income. The final court case in the Whitfords Beach Case was not addressed as it was on common grounds between parties including in the accessible income the taxpayer sold the material though the Gibbs CJ in the High Court said contrary to this. No detachment was there relevant from the other which established an apportionment to certain blocks which the best process involving the averaging was sold. Statham Anor v FC of T 89 ATC 4070 In order to make sure of assistance provided in determining the activities are of adventure or business or a nature concern of making a profit undertaking a scheme. Additional land is obtained to be added to the original parcel of the land. For the subdivision of land a rational strategy is required. The business company like the manager, letterhead or an office is required. In order to obtain subdivision, a borrowed fund is financed. In order to settle the sub-divisional costs an interest of money was borrowed and claimed as a business expense. The land required to be developed beyond the essential for securing the approval for subdivision. The building had also erected on the land. Examining the facts and the circumstances with respect to a particular case is essential. It needs a consideration of these factors and other factors which are relevant to be weighed as part of the process to reach the conclusion. Single factors will not determine the combination of the factors leading to the conclusion as the character of the activities. Casimaty v FC of T 97 ATC 5135 There are many factors in the Casimaty cases for making sure that assistance is provided for determining the activities are an adventure or business or a nature concern of making profit or scheme. The factors include changing the purpose of holding the land. Additional land is got from the original parcel of land. As an asset to business, the parcel of land is brought. A logical plan for the subdivision of land is required. There has been a business company like the letterhead, the office and the manager. The borrowed funds are financed by gaining the subdivision. The interest on the money borrowed for paying the sub-divisional cost was claiming as an expense of the business. A level for developing the land is beyond which is needed for securing the approval of the council for the subdivision. Mona Sand Pty Ltd v FC of T 88 ATC 4897 According to Mona Sand, land was bought for working on the sand on the land. When the land became ripe it was resumed for $500,000. The consequent gain was held by The Federal Court and was taxable under both 26(a) and 25(1) in spite of subdivisions and the resale which is leading purpose to underline the purchase. The rejection of the requirements for leading purpose to make gains by resale for the operation of the first limb of 26(a) no rationale was there in order to exclude such a requirement from 25(1) was preferred. The Court was assuming that it was not required. Thus whilst Mona Sand supported the stance of the Commissioner, it never provided a strong authority for the proposition. Cooling is a taxable nature to a lease incentive payment for procuring Inter Ella a solicitor of a company into a ten years lease agreement respecting to flooring of the building. For occupying the grounds, it is not the sole reason acquiring a commercial profit through leasing incentive was not a purpose which was significant. Crow v FC of T 88 ATC 4620 Various properties were brought under the Crow v FC of T 88 ATC 4620 and there was the subdivision of the sale of the parcel of land which involved in the transaction systematic and repetitive and there were characteristics of continuing business of developing the land. The court was satisfied about the taxpayer which was sold and bought the land for profit purpose. The activities of the taxpayer is answered properly the description to carry on the business of developing the land and the profits thereof constitute the income in accordance to the ordinary concepts. McCurry Anor v FC of T 98 ATC 4487 The taxpayer bought land on which there was an old building. The building was removed and three townhouses were constructed on the land. The townhouses were advertised for sale before the completion, however this was not successful. Subsequently, the taxpayers moved into two different townhouses and lived there for approximately one year art which time they were sold which resulted in a total net profit of approximately $150,000. A few years later, the taxpayer s bought a second block of land where they constructed units and then sold them. The Commissioner contended that the profits from the sale of the townhouses were assessable ordinarily as they resulted from a commercial profit making activity. The taxpayer argued that the sale of the townhouses was the mere realisation of a capital asset and therefore not ordinary income on the basis of the townhouses were used as residences and only sold because of difficulties in finance (Chetty, Looney and Kroft, 2009). The court held that t he sale of the townhouses was the ordinary income because the land was obtained for commercial purpose and a view in obtaining the profit from the sale. The purchase of the land and the townhouses was not for investment purpose and therefore not the realisation of a capital asset. Although the taxpayer lived in the properties of the land for a period of time the dominant purpose of the arrangement was the sale of the redeveloped property at a profit. References Aust, A., (2013). Modern treaty law and practice. Cambridge University Press. Barkoczy, S., Rider, C., Baring, J. and Bellamy, N., (2010). Australian Tax Casebook. CCH Australia Limited. Brigham, E.F. and Ehrhardt, M.C., (2013). 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