Terri Schehr Posted August 22, 2018 Share Posted August 22, 2018 1 minute ago, Northern Thunder said: The weirdest "thing" about "The Thing", is that they used the uniforms from each corps. The green Irish look from St. Patrick's, and the purple uniforms from the Thunderbolts made for quite a strange sight in 1973. It was indeed. Quote Link to comment Share on other sites More sharing options...
JimF-LowBari Posted August 22, 2018 Share Posted August 22, 2018 6 minutes ago, Northern Thunder said: The weirdest "thing" about "The Thing", is that they used the uniforms from each corps. The green Irish look from St. Patrick's, and the purple uniforms from the Thunderbolts made for quite a strange sight in 1973. We need a new History of Drum Corps book with color pictures Brian... never knew that color scheme whoa Quote Link to comment Share on other sites More sharing options...
WIS Posted August 22, 2018 Share Posted August 22, 2018 (edited) 2 hours ago, garfield said: Sorry, not much of this is correct. Roman most-certainly can own the assets and rent them cheap to the corps. If the corps folds, RB would be entitled to keep his asset and do with it as he pleases. If the asset is not titled in the name of the NP, there's not an AG in the country that will "seize" assets from the orgs founder and "give" them to some other entity. If Roman owns the equipment and leases it to the corps, he doesn't have to buy it back from the corps, he simply stops leasing it. The "self-dealing" rules (citation, please) don't require the owner give or lease rent-free anything at all. You are correct if Roman personally owns the equipment, but it certainly doesn't look like that is the case. I stand by my comments. Not going to get into a Pi@@ing match - I know the research below is for a foundation. The founder doesn't own assets titled to the non-profit organization. It would take quite an act for the AG to seize assets - that would only be if the assets were abandoned or the managers of the organization were not following law. In any event, if Pioneer goes under the remaining assets must be given to another 501(c)(3) under the IRC. They cannot just take their horns and go home. The Pioneer 2016 Form 990 reports a value for buildings, land and equipment of $446,636 before depreciation. Tried to copy/paste but couldn't. Land $127,036 (the land is right along the airport boundary not far from the landing strips - doubt it would be particularly valuable) Buildings $129,364 Equipment $136,051 Other $75,185 Below - I didn't research this for purposes of DCP - I just happen to be dealing with the same issue with another non-profit organization and had the research right on my desk. www.irs.gov A disqualified person is any person who was in a position to exercise substantial influence over the affairs of the applicable tax-exempt organization at any time during the lookback period. It is not necessary that the person actually exercise substantial influence, only that the person be in a position to do so. For this purpose, donors and donor advisors with respect to a donor advised fund are treated as disqualified persons with respect to transactions with the fund. Moreover, the entire amount involved paid to such persons is treated as an excess benefit. Finally, a person who is able to exercise substantial influence over a section 509(a)(3) supporting organization is a disqualified person not only with respect to that organization, but also with respect to the organization(s) the supporting organization is organized and operated to benefit. Family members of the disqualified person and entities controlled by the disqualified person are also disqualified persons. For this purpose, the term control is defined as owning more than 35 percent of the voting power of a corporation, more than 35 percent of the profits interest in a partnership, or more than 35 percent of the beneficial interest in a trust. Current Internal Revenue Code, SEC. 4946. DEFINITIONS AND SPECIAL RULES. Click to open document in a browser 4946(a) DISQUALIFIED PERSON.— 4946(b) FOUNDATION MANAGER.— For purposes of this subchapter, the term “foundation manager” means, with respect to any private foundation— 4946(b)(1) an officer, director, or trustee of a foundation (or an individual having powers or responsibilities similar to those of officers, directors, or trustees of the foundation), and 4946(b)(2) with respect to any act (or failure to act), the employees CCH Tax Research Consultant, EXEMPT: 24,200, Self-Dealing Defined Click to open document in a browser Self-dealing is prohibited act between private foundation and disqualified person. Act may be direct or indirect. No self-dealing exists if benefits to disqualified person are no greater than those received by general public. Continuing transaction may be treated as multiple acts of self-dealing. Self dealing is any of the following direct or indirect transactions between a private foundation and a disqualified person: any sale, exchange or leasing of property (see EXEMPT: 24,202.05 and EXEMPT: 24,202.10); the lending of money or other extension of credit (see EXEMPT: 24,202.15); the furnishing of goods, services, or facilities such as office space, automobiles, secretarial help, meals, libraries, laboratories, or parking lots (see EXEMPT: 24,202.20 and EXEMPT: 24,206.05); the payment of compensation or reimbursement of expenses (see EXEMPT: 24,202.25); the transfer or use of foundation assets or for the benefit of a disqualified person (see EXEMPT: 24,202.30); and agreements to make any payment of money or other property to a government official, other than to agree to employ the individual for any period after the termination of his government service if that person is terminating his government service within a 90-day period (see EXEMPT: 24,202.35). 1 It is immaterial whether the transaction results in a benefit or a detriment to the foundation. Self-dealing does not include a transaction between a private foundation and a disqualified person if the disqualified person status arises only as a result of the transaction. 2 Edited August 22, 2018 by WIS added to first sentence 2 Quote Link to comment Share on other sites More sharing options...
WIS Posted August 22, 2018 Share Posted August 22, 2018 1 hour ago, hostrauser said: It's a football field wedged between some railroad tracks and a bunch of industrial warehouses. The development potential of the site is zero. https://goo.gl/maps/Enqw1wf7f832 I know someone with land right next to them - they have no interest in the property for expansion. It is not a good site. Quote Link to comment Share on other sites More sharing options...
WIS Posted August 22, 2018 Share Posted August 22, 2018 56 minutes ago, JimF-LowBari said: I looked and thinking if any of the nearby trucking companies want to expand.... Down toward York, PA there are some mammoth high tech warehouses going up right of the interstate. Company would have room to build a new warehouse without having to knock one down first Answer - direct from one of the companies - is no. 1 Quote Link to comment Share on other sites More sharing options...
N.E. Brigand Posted August 22, 2018 Share Posted August 22, 2018 3 hours ago, xxxdcifanxxx said: I completely agree that Pioneer should be suspended. However, I do wonder how dci would react to corps with similar issues that are more important to their bottom line. If a top 6 group had member complaints like this I do not think dci would take the same action. It's really easy to suspend a corps that is bottom of the pack, not as easy when it's cadets, Cavaliers, phantom, etc. They would get probation. I guess we'll know whether or not you're right about this if there are a flurry of similar complaints online about one of the top corps. But this is the first instance to come to light since DCI adopted new policies in the spring following the Cadets debacle. And remember Cadets were put on probation, and I believe they would have been suspended had they not clearly demonstrated to DCI that they had addressed the issues. Firing the board and the CEO was a big part of that. Quote Link to comment Share on other sites More sharing options...
Ghost Posted August 22, 2018 Share Posted August 22, 2018 25 minutes ago, JimF-LowBari said: We need a new History of Drum Corps book with color pictures Brian... never knew that color scheme whoa Steve Vickers probably checks out DCP, so maybe he can reply to your suggestion. His first two volume's have to be collector items and I ain't selling 'em! Quote Link to comment Share on other sites More sharing options...
Brian Tuma Posted August 22, 2018 Share Posted August 22, 2018 1 hour ago, IllianaLancerContra said: IDK - off airport parking? car rental? Although it abuts the airport, it’s not convenient to the airport if that makes sense. Quote Link to comment Share on other sites More sharing options...
JimF-LowBari Posted August 22, 2018 Share Posted August 22, 2018 4 minutes ago, Ghost said: Steve Vickers probably checks out DCP, so maybe he can reply to your suggestion. His first two volume's have to be collector items and I ain't selling 'em! Mine are under lock and key too.. front door lock that is Quote Link to comment Share on other sites More sharing options...
ajlemm Posted August 22, 2018 Share Posted August 22, 2018 41 minutes ago, Terri Schehr said: It was indeed. Well that’s the thing, right? 1 Quote Link to comment Share on other sites More sharing options...
Recommended Posts
Join the conversation
You can post now and register later. If you have an account, sign in now to post with your account.