EA Exam Lite
Part 2
Businesses – II
1
Topic 1
Corporations:
Formation
Under Sec. 351
2
1A Sec. 351 Transfers – Basics



Sec. 351 – No gain on formation if:
 Transfer consists solely of property
 Exchanged solely for corporate stock
 Contributing shareholder(s) in control (at least
80% of voting and outstanding stock)
Nonqualified – Bonds, certain preferred stock
(redemption rights, dividend tied to int. rates)
Sec. 351 Result – No gain, basis carryovers
3
1B Sec. 351 Transfers –
Services

Contribution of Services – Contributing
S/H taxed, shares not counted for 80%
Property Transferred With Services –
Shares issued for services counted in 80%
test if FMV prop. >10% total transferred
(but SH still taxed on services income)

Question 1

4
1C Sec. 351 Transfers –
Gain/Loss (No Boot Rec’d)



If All 3 Conditions Met – (1) No gain or
loss, (2) basis of stock is basis of property,
(3) corporation’s basis in property is S/H’s
basis
If All 3 Conditions Not Met – Exchange
taxable, FMV as basis for corp & S/H
Question 2
5
1D Sec. 351 Gain/Loss –
With Boot Received




Boot – Any non-stock property received by
the shareholder (cash, property, bonds)
Loss – Never recognized when boot rec’d
Gain – Recognize lesser of realized acct’g.
gain or boot received
Question 3
6
1E Sec. 351 Transfers –
Liabilities Assumed



Sec. 357 – Liabilities assumed by corp not
treated as boot received for gain (but are
for basis purposes—see below)
If Liabilities > Basis of Prop Transferred –
Excess must be reported as gain to
prevent a negative basis—see below
Question 4
7
1F Sec. 351 – Basis of Stock
to Shareholders

Shareholder’s Basis of Stock Received:






Adjusted Basis of Property Transferred
+ Gain Recognized for Tax Purposes
- Boot Received (Including Liabilities)
- Loss Recognized (Rare)
Parallels – In computation to the Method 1
basis rules for like-kind exchanges
Question 5
8
1G Sec. 351 – Basis of
Property to Corporation

Corporation’s Basis in Property Rec’d.:





Adjusted Basis of Property to Transferor
+ Gain Recognized (Taxable) by Transferor
Importance of Liabilities – If gain is not
recognized by shareholder, no step up in
basis for corporation
Figure 1
Question 6
9
1H Sec. 351 – Holding
Period Issues

Sec. 351 – Provides for a “tacking” of
holding periods:


SH Basis in Stock – Includes holding period of
contributed property
Corp Basis in Property – Includes holding
period of property of the transferor SH
10
Topic 2
The Corporate
Dividends Received
and Charitable
Deductions
11
2A Importance of Corporate
Tax Format - Example
Gross margin
Gross dividends received (10% int.)
Capital gains (no losses)
Other income
Gross income
Operating expenses
Income before charitable ded.
Charitable ($42,000, but 10% limit)
Div. received ded. ($20,000 x .70)
Taxable income
$420,000
20,000
30,000
30,000
$500,000
( 200,000)
$300,000
( 30,000)
( 14,000)
$256,000
12
2B Dividends Rec’d. Deduction
– In General


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DRD – A pct. deduction allowed to corps for
dividends received (70%, 80%, 100%)
Foreign Dividends – Do not qualify (Cr.)
Debt-Finan. Portfolio Stk – DRD reduced
DRD Not Available – For REITS, exempt corps,
stock held < 46 days during 90-day pd. around
ex-dividend ( <91 of 180 days for preferred),
short sale stock
Special Limits – SBICS, Reg. Inv. Companies
13
2C Dividends Rec’d.
Deduction – General Rule

DRD – In general, following percentages
of dividends received are deductible:





70% (if interest in payor < 20%)
80% (if interest in payor =>20% but < 80%)
100% (controlled sub interest => 80%)
Taxable Income Limit – May apply (see
tests below)
Question 7
14
2D Corp DRD: Limitation
and Exception



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(1) General Rule – 70-80-100% of dividend
(2) Limitation – DRD limited to 70% or 80% of
taxable income (operating loss plus gross
dividend), if less than general rule
(3) Exception – If full DRD (70%/80% of gross
div) creates or adds to an NOL, full DRD allowed
Figure 2
Questions 8 and 9
15
2E Corporate Charitable
Deduction – General



General Deduction – Cash plus FMV of
non-inventory property given to charity
10% Taxable Income Limit – May apply
(see below); unused carryover for 5 yrs.
Authorized Contribution – By Board of
Directors before end of year deductible if
paid by due date of return (2½ months)
16
2F Corporate Charitable
Deduction – Limits



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Deduction Limit – 10% of taxable income before
(1) charitable, (2) div. received deduction, (3)
capital loss or NOL carryback (not carryforward)
Property Contributions – Limits if ord. inc. prop.
Unused – Carry over for 5 years (current first)
Inventory – Deduction usually limited to cost,
but allowed cost + 50% of appreciation (limited
to 2X cost) deduction for (1) Care of the ill,
needy, or infants or (2) Univ. scientific purposes
Question 10
17
Topic 3
Corporations: Other
Deductions
18
3A Compensation & Fringe
Benefits



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Paid With Property – Recognize gain/loss on
apprec./deprec. in value, then deduct FMV
Pay With Own Stock – No gain or loss, deduct
FMV of stock
IRS- May reallocate comp if tax avoidance
Fringe Benefits – Most deductible, regardless of
excludability by recipient
Question 11
19
3B Miscellaneous Corporate
Deductions


Worthless Affiliated Co. Stock – Ordinary
loss allowed if corporation owns at least
an 80% interest
Domestic Activities Production Deduction –
6% of lesser of (1) qualified production
activities income or (2) taxable income for
the year (AGI for individual); limited to
50% of W-2 wages
20
3C Corporate Net Operating
Losses


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NOL Computation – NOL deduction, capital loss
and charitable carryovers not allowed in
computing an NOL
Dividends Received Deduction – May limit NOL
Casualty or Theft Loss – Increases NOL
Current-Year NOL – 2-year c/b and 20-year c/f
Election – Available to forego carryback; must
use same for AMT (irrevocable when made);
carryovers used up on FIFO basis
Questions 12 and 13
21
3D Corporate Passive Losses



Regular C Corps – Not subject to the passive
loss limitations
Personal Service Corporations (PSCs) and
Closely-Held Corps (CHCs) – Are subject to
passive loss limitations
CHCs – May offset passive or active income with
passive losses (PSCs cannot)
22
3E Qualifying Organizational &
Startup



Organizational Costs – Licenses, drafting
documents, registration fees (but not costs of
printing and issuing stock certificates); Sec. 248
permits expensing & amortization (below)
Startup Costs – Bringing the bus. to the point of
daily operations (training, adv.), but not
deductible interest, taxes, or R&E; Sec. 195
permits expensing & amortization (below)
Elective Expensing & Amortization - $5,000 max.
expensing, phaseout $1 for $1 beginning at
$50,000, 180-mo. amort. of remaining costs)
23
3F Org. & Startup Costs –
Making the Election



Election – For either made by filing Form 4562
and separate detailed statements listing qualified
costs; irrevocable election
Valid Election – If filed by due date of return
(plus extensions), or by amending first return
w/i 6 months of due date (plus extensions)
No Election – No cost recovery until business is
liquidated; costs presumably have unlimited life
24
3G Org. & Startup Costs –
Computing Deduction


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Either Cost – Must be paid or incurred
within the first year of doing business
Amortization Period – Begins in the first
month that the company is open for bus.
Change in Amort. Period – Is not allowed
Figure 3
Question 14
25
Part 4
Corp. Capital
Transactions &
Related Party
Rules
26
4A Corp. Capital Netting –
Similarities to Individual



Step 1 – Net all STs, determine ST result
Step 2 – Net all LTs, determine LT result
Step 3 – Compare sign of ST & LT results:



If same sign – Each enters income separately
If opposite sign – Net result enters income
Differences from Individuals – How the
final results enter ordinary income (next)
27
4B Corp. Capital Netting –
Differences From Individual

4 Differences – for Corps vs. Individuals:






No L/T capital gains preferential tax rate
No offset of capital losses against ordinary inc
Unused losses c/b 3 years and c/f 5 years
All unused capital loss carrybacks & carryforwards automatically short-term in nature
Figure 4
Questions 15 and 16
28
4C Sec. 267 Related Party
Rules for Corps

Two Deductions Disallowed by Sec. 267:




Loss on sale or exchange between related parties
Year-end accrual-basis deduction for payment to
cash-basis related party
Related Parties – Defined as family members
and controlled entities (direct or indirect)
Constructive Ownership (Attribution) – Indirect
double attribution through entities (p’ship
interest in corp in question), but not with others
29
4D Sec. 267 Disallowed
Losses on Sales




No Exceptions – To disallowance rules (e.g.,
family hostility ignored), but liquidating dist. OK
Disallowed Loss – May only reduce gain on
subsequent resale by the related party (cannot
create or add to loss)
Gain Reduction Rule – Does not affect basis or
holding period rules
Question 17
30
4E Sec. 267 Disallowed
Expense Accruals



Transactions Covered – Expense accrual by
accrual-basis corporation to a related cash-basis
shareholder/employee or business party
Tax Result – No deduction for expense until
included in the related party’s income
Sec. 267 Related Party Definition – Includes a
PSC and any cash-basis shareholder/employee
31
Topic 5
Corp. Earnings &
Profits (E&P)
Determinations
32
5A Adjusting Income to
Determine E&P





E&P – Represents a corporation’s ability to pay
dividend w/o impairing invested capital; includes
current & accumulated E&P
Adjustments – Convert taxable income to a
“wherewithal to pay” economic income (i.e., cap. loss, + DRD, - tax liability, - excess
contributions, + tax-exempt interest)
Other Adj. – Depreciation, inventory, installment
Figure 5
Question 18
33
5B Cash Distributions –
Effect on E&P


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Cash – Reduces E&P (taxable dividend if either
current [CEP] or accumulated E&P [AEP] exists);
then cost recovery, then capital gain (i.e., sale)
More Than One Dist. in the Year – Allocate CEP
pro rata to each dist., but apply AEP
chronologically to each
If CEP Negative and AEP Positive – Net on date
of dist. (a negative CEP allocated on daily basis)
Figure 6
Question 19
34
5C Property Distributions –
Effect on E&P

Two E&P Effects of Property Distribution:
 Unrealized gain on property increases E&P
 Larger of adjusted basis or FMV of property
decreases E&P
Net Effect of Rule – Reduce E&P by the adjusted
basis of the property
Liabilities Assumed by S/H – Increase E&P

Question 20
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
35
Topic 6
Corporate
Distributions
36
6A Classification of Cash
Distributions

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E&P Rules – Mirrored in determining the
tax status of distributions to shareholders
Shareholder – Taxed on dividend to extent
of his or her share of CEP & AEP, then
nontaxable recovery of capital, then
capital gain (as though stock is sold)
Review – E&P allocations (Topic 5)
Questions 21 and 22
37
6B Corporate Redemptions –
Dividend or Exchange

5 Ways for Capital Gain on Redemption:





Not essentially equivalent to dividend [facts & circumstances]
Disproportionate distribution (50% overall, 80% disprop. test)
Complete termination of interest (agree to stay out bus. 10 yr)
Partial liquidation (significant business contraction)
Pay estate taxes (FMV family stock > 35% estate)

Other Redemptions – Ordinary dividends
Effect on E&P – If div, reduce E&P; if CG, reduce E&P by
larger of (1) FMV distrib. or (2) E&P x % redeemed

Question 23

38
6C Redemptions – Stock
Attribution Rules

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Attribution Rules – Apply with 50% & 80% tests
Sec. 318 – Attribute stock owned by spouse,
parents, children, grandchildren back to TP (but
NOT brothers and sisters)
ATR from an entity – To an owner possible, but
must be at least 50% total direct or indirect int.
ATR to an entity – From an owner for all shares
(for corporation, must exceed 50% int.)
Figure 7
Question 24
39
6D Corporate Partial
Liquidations

Sale or Exchange Treatment – Permitted
for partial liquidations; reported by:




Individuals (capital gain or loss)
Corporations (dividends, for 70%/80% DRD)
Required – A significant contraction of the
business enterprise
Examples - Liquidating a business line or
not replacing division destroyed by fire
40
6E Distributions of Property –
Gain/Loss to SH




Dividend Income – FMV property (limited to the
shareholder’s share of E&P); rules do not apply
to distribution of Co.’s own stock
Liability on Distributed Property – Amount
reduces income to S/H (and increases E&P)
Bargain Sale to S/H – Bargain element is taxed
as a dividend
Question 25
41
6F Property Distribution –
Gain/Loss to Distr. Corp



Corp – Recognizes gain/loss on
distribution as if sold; character depends
on asset (e.g., depreciation recapture
possibility)
Liability on Distributed Property – If the
liability > FMV property, the FMV is
presumed to be equal the liability
Question 26
42
Topic 7
S Corporations –
Key
Requirements
43
7A S Corps – Basic
Requirements


S Corp – Domestic, foreign operations OK , no
Domestic International Sales Company (DISC)
Basic Requirements for an S:


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100 S/H limit (“family” is one S/H—ancestors &
descendents of common ancestor and spouse); all
S/H as of beg. of year consent on Form 2553)
S/Hs only individuals, resident aliens & certain
trusts (QSST, if individual reports income)
One class of stock (voting/nonvoting OK)
Not part of affiliated group (may own % of C)
Question 27
44
7B S Corp Election –
Effective Date


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
Form 2553 – Election, consent of all S/H at the
beginning of the first S year
Election – Due by 15th day of 3rd month of year
that election is desired
1st Day of 1st Yr. – Earliest date S Corp. has: S/H,
assets, or begins business
If Filed After Due Date – Election effective for
next year (IRS may accept late application if
filed within 12 months, if reasonably explained)
Question 28
45
7C Termination of an S Election



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
Voluntary Termination – Requires consent of >
50% shares w/i 2 ½ mos., otherwise, next year
Involuntary Termination – Begin with disq. event
Disqualifying Events - > 100 S/H, ineligible S/H,
prohibited tax status, 2nd class of stock,
improper year, or fail passive income test for 3
consecutive years (see below)
5-Year Wait – To reelect, unless (1) termination
inadvertent (and IRS OKs), or (2) F&C IRS OKs
Question 29
46
7D S Corp Built-in Gains Tax

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Purpose – Prevent S election by C to avoid sale gain
Built-in Gain – FMV > basis of any asset at election
Application – Only post-86 elections by C corporations
35% Rate – For any gain within 10 yrs. election
NUBIG – (Potential gain) reported on 1120-S each year,
reduced as recognized (B/I loss may offset, if proven)
NOL & Cap. Loss C/Os – May reduce BIG, and any credit
carryover may reduce BIG tax
Question 30
47
7E S Corp LIFO Recapture Tax



LIFO Recapture Tax – If C using LIFO
converts to S status
Computation - Compute marginal tax on
excess of FIFO inventory over LIFO (as if
included in last C year income)
Reporting - Report as add’l tax over 4 year
period (beginning with last C Corp return)
48
7G Tax on Excessive Passive
Income of S


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
Tax – Only if S passive investment income (PII)
> 25% gross receipts, & E&P exists from C yrs.
35% Rate – Applies to Excess Net Passive Inc.
(ENPI); cannot exceed C corporate tax for year
Tax – Reduces passive pass-thru to SH
If Taxed for 3 Consecutive Yrs. – Lose S status
as of 1st day of 4th year
Figure 8 (skim only; not likely on exam)
Question 31
49
Topic 8
S Corporations:
Taxable Income
& Distributions
50
8A S Corp – Determining
Ordinary Inc. & Special Items


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
Determination – Very similar to partnerships
Ordinary Income – Items could not vary in
treatment across individual S/H returns
Special Items – Could vary in treatment
Sec. 179 Max. – Allocate based on SH % owned
Salary to Owners – In S, not a guaranteed
payment, just an ordinary bus. deduction
Question 32
51
8B S Corps – Allocation of
Profits



Allocation – For S year ending in S/H year
Total to a S/H – total “per day/per share”
(weighted average)
Transfer during year – Transferee picks up
share from transfer date forward, or S/Hs
may agree to an accounting method
allocation of profits
52
8C Allocation of S Corp Losses
– No S/H Loans





Losses – Also allocated “per day/per
share”
Loss Limit – S/H basis + outstanding loans
If loss share > basis – Carry over excess
for possible future increases in basis
S Shareholder – May NOT increase basis
for share of liabilities
S/H Basis – Much like partnership (below)
53
8D Allocation of S Corp Losses
– With S/H Loans





Loss Shares – May offset qualified loans after
offsetting any S stock basis
Qualifying Loans – Must be owed directly to S/H,
and not just a guarantee
If S/H Pays on Guarantee – Amount paid creates
basis of loan (for loss absorption purposes)
Deductible loss – Reduces basis of S Corp
interest and/or basis of loan
Question 33
54
8E S Corp Distributions – In
General



Classifying Distribution – Depends on whether or
not S has “E&P” from either (1) prior years as a
C Corp, or (2) a prior nontaxable acquisition of a
C Corp
Distributions From E&P – Taxable, once the S
Corp exhausts AAA balance (see below)
S Shareholders – May consent to have all of a
distribution FIRST come from E&P (1099-DIV)
55
8F Classifying S Corp
Distributions of Cash


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
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If No E&P – Nontaxable basis recovery, then cap. gain
If E&P Exists – Depends on E&P & AAA balance
Accum. Adj. Acc’t. (AAA) - $0 + net income + (depl >
basis) – deductions – loss – depl deduct – nontax. distrib
Distributions – Assumed to come from, in order:
(1) AAA (nontaxable distribution up to stock basis),
(2) E&P (dividend—recall S/H may elect E&P first),
(3) OAA (other adj, acc’t of tax-exempt inc, nontaxable)
(4) Basis Reduction (of stock basis, nontaxable), and
(5) Capital Gain (taxable at capital gains rates)
Question 34
56
8G S Corp Distributions of
Property




S Corp – Must report gain/loss as though
property sold first (just like C Corp)
Difference – Gain is passed through to S/H
S/H – Generally not taxed on property
distribution unless E&P exists
If Dist. > Basis – S S/H must report capital
gain (no basis adjustment like p’ships)
57
8H Increases to S Corp
Shareholder Basis

Common Increases to S Shareholder Basis:
 Add’l contributions of cash, property,
services
 Distributive share of ordinary S income
 Distributive share of separately-stated
items
 Distributive share of tax-exempt income
 Distributive share of depletion in excess of
basis
58
8I Decreases to S Corp
Shareholder Basis

Common Decreases to Basis:
 Nontaxable distributions of cash or property
 Distributive share of ordinary losses (not <
$0)
 Distributive share of separately stated
items
 Distributive share of nonded., noncapital
 Distributive share of depletion (not > SH’s
share of basis)
59
8J Determining an S Corp
S/H’s Stock Basis


Basis – Can never be zero; if distribution
exceeds basis, gain is recognized for excess and
increases basis to $0
Loss Shares – Cannot decrease S stock basis
below zero; deduction limited to basis plus loans
(carryover to future years for possible basis
increases)
60
Topic 9
Estate & Trust
Income Taxation:
A Broad View
61
9A Estates & Trusts as
Taxable Entities



Fiduciary – In general, is taxed only on
income not distributed to beneficiaries
(deduction allowed for distributions)
Estate – A taxable entity (income tax) until
all estate assets are finally distributed to
beneficiaries
Trust – Grantor creates (testamentary or
inter vivos), and trustee manages property
for beneficiaries; taxable entity also
62
9B Form 1041 Filing
Requirements for E&T





Estates & Trusts (E&T) – Must file annual Form
1041, with Sch. K-1 allocations to beneficiaries
E&T Tax Rate Schedule – Progressive rates
Form 1041 – Required if (1) estate has gross
income => $600, (2) trust has gross or taxable
income =>$600, or (3) a nonresident alien
beneficiary (Note – gross income similar to ind.)
Estate – Personal representative or authorized
officer must sign the return
Question 35
63
9C Simple Trusts


Trusts – Classified as simple or complex
Simple Trust Defined – One that:




Is required to distribute all trust acct’g income
Distributes no corpus
Has no charitable beneficiaries
Required – File return if gross income is
$600 or more ($300 exemption allowed)
64
9D Complex Trusts


Complex Trust – Any trust other than a
simple one (i.e., one that distributes
corpus, accumulates some income, and/or
has a charitable beneficiary)
Determination – Made on an annual basis;
designation may change year to year
Question 36
65
9E Acct’g. vs. Taxable
Income of Fiduciary

Broad Overview of E&T Taxation:



Distribution Deduction – Allocates taxable
income between E&T and beneficiaries
Distributable Net Income – The “common
denominator” for determining the distribution
deduction (economic acct’g income of entity)
Trust “Accounting Income” – Determined
by governing instrument; if silent, then
state law governs
66
9F Fiduciary Deductions –
Allocating Expenses

Deductions – Same as individuals, but:



Gen. & Adm. Expense - Allocate between
taxable & nontaxable income, instrument
doesn’t override (if on 1041, can’t be on 706);
contributions also unless specified differently
2% Miscellaneous Itemized Floor – Does not
apply to expense that would not have been
incurred outside trust (trustee fee, tax prep.)
Unused NOLs – CAN be used by beneficiary
67
9G Fiduciary Exemption
Deduction





Estate - $600 exemption
Trust Must Distribute All Income - $300
All Other Trusts - $100
$300 – Can apply to simple or complex
Charitable Beneficiary – Must be a
complex trust ($100 or $300)
68
9H Fiduciary Taxable
Income Computation





Beware! – Read each question carefully
Focus – On key differences for E&T, and be
SURE to use correct exemption
Distribution Deduction – Generally for any
distributions to beneficiaries; however, it can
NEVER exceed DNI
Grantor of Trust – Taxed on trust income if he or
she retains beneficial enjoyment or substantial
control over corpus or income
Question 37
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Topic 10
Business
Retirement
Plans
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10A Qualified Retirement Plans
– Basic Requirements
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Qualified Plans – Deductible contributions, taxfree accumulation of earnings, tax deferral
Participation – Age 21 with 1 year of service
(1,000 hrs), or 2 years with immediate vesting;
must cover lesser of 50 employees or 40% of all
Coverage – 70% non-highly compensated (or
70% of the highly-compensated coverage)
Vesting – 100% (5 yrs), or 20% (3 years),
increasing 20% per year to 100% at 7 years
Figure 9 (Deduction/Contribution Limits)
Question 38
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10B Keogh Plans – Basic
Requirements
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Keogh – Establish by year end, cont. to due date
Keogh – S/E own employer, partner is employee
Profit-Sharing Plan – Need definite formula
Small Employer – 50% credit ($500 max.) for
certain startup costs
Net S/E Earnings – Sch. C bus. income (services
involved), less ½ SE tax and less the Keogh
contribution itself
General Partners – Usually have S/E earnings
Key Question 39
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10C Keoghs – Contribution &
Deduction Limits
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Max. Keogh Limits (SE person & employee) –
subject to limitations (see Figure 10)
Excess Contributions – Carryover to next year
Participant – May make nondeductible
contributions up to 10%
Form 5500 or 5500-EZ – If required, is due the
last day of the 7th month after plan yr., but
neither required if plan assets < $100,000 (note
– must file in the final year of plan)
Figure 10
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10D SEP-IRAs

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SEP – Employer makes contribution direct to
IRAs set up for employees (S/E may be only
employee) – establish & contribute by due date
Employer Contributions – Must be nondiscriminatory, not in favor of “highly comp” (5% own,
>$90,000)
Max. Contribution – Lesser of (1) 25% comp or
$45,000 for each participant
S/E Person – Uses S/E income – ½ S/E tax –
SEP contribution (nets to 20% deduction)
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10E SIMPLE Pension Plans

SIMPLE – Employer with <=100 employees ($5,000
salary); use either SIMPLE IRA or SIMPLE 401(k)
Employee – Elective contributions up to $10,500 per
year ($13,000 if age => 50)
Employer – Must match employee contributions up to
3% of comp; if employer makes nonelective
contribution, 2%
10% Penalty – Premature distribution, 25% if first 2 yrs.

Question 40
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10F Pension Plans – Prohibited
Transactions

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Prohibited Transactions – Include:
 Transfer income/assets to “disqualified”
person (e.g., employee, family member, etc.)
 Fiduciary acting in its own self-interest
 Consideration to fiduciary from plan party
 Any acts between plan/disqualified Person
(sell, lending, etc.)
Tax on Transaction – 15%, increased to 100% if
not corrected within one year
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Summaries – Key Factors in Choice
of Business Entity
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Figures 11 through 14 – Provide
summaries of the key nontax and tax
factors related to four types of entities
(sole proprietorship, partnership, S
corporation, and C corporation)
Figure 15 – Provides a brief summary of
other factors to consider in entity choice
Topic – May appear in planning questions
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Questions?
As Time Permits
Contact:
John Everett
Professor of Accounting
Virginia Commonwealth University
jeverett@vcu.edu
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