INCREASED DELIVERY TIME (PLUS) 1.46
Notwithstanding the seemingly liberal interpretation of the Sec. 167(a) placed-in-service provision in Regs. Sec. 1.167(a)-(11)(e)(1)(i), the Service has often interpreted this provision narrowly, requiring full actual operational use, not merely availability for use, of an asset before it is deemed placed in service. FSA 199916040, for example, dealt with a taxpayer that purchased, sold, and transported natural gas. The taxpayer owned and operated an integrated pipeline system, which connected gas supply sources from several states to gas markets in other states. Because compressors were required to maintain gas pressure in the pipelines, the taxpayer bought both new and used compressors. These compressors were repaired if necessary and were placed into warehouses for storage until needed. On their delivery to storage, the taxpayer treated the compressor as having been placed in service for depreciation purposes, presumably on the ground that the machines were ready and available for their assigned function. In advising against depreciation until the time the compressors were installed in the pipelines, the Chief Counsel noted that the Service has applied Regs. Sec. 1.167(a)(11)(e)(1)(i) generally to require actual operational use in the trade or business, citing Consumers Power Co., 89 TC 710 (1987), and Oglethorpe Power Corp., TC Memo 1990-505, to support this conclusion. In Consumers, the Tax Court implicitly adopted the argument that an asset or facility is not placed in service until it is operating at rated capacity. Relying on Consumers, the court in Oglethorpe stated that an electricity-generating unit should not be deemed placed in service because it was not available for its specifically assigned function, which the court defined as consistently sustaining generation levels near its rated capacity.
INCREASED DELIVERY TIME (PLUS) 1.46
Several recent studies have documented the effects of massage and acupressure in reducing labor pain and labor time and in satisfaction with the delivery. However, few studies have investigated the comparative effects of these two therapies.
In the latent phase of labor, the mean VAS scores of the massage-only group and massage + acupressure group were lower (4.56 1.36 and 4.63 1.52, respectively) than that of the control group (6.16 1.46; p .05). The three intervention groups reported relatively more positive feelings than the control group, and all three of the interventions were found to be effective in improving satisfaction.
We'd like to take this opportunity to thank everyone who participated, provided their feedback, and made bug reports during the 1.46 Open Beta. Your valuable input helped us make tweaks, changes and smash some bugs we may have missed the first time around. We hope you can now begin to fully enjoy the fruit of your work.
Companies have adopted cloud to enhance their operating-model agility, which accelerates the implementation of use cases while lowering R&D investment. Companies can more easily configure solutions on cloud than they can on-premise, enabling them to keep pace with the speed of business change and creating a flywheel for responsiveness. In addition, migrating to the public cloud provides organizations with access to innovative tools and capabilities offered by CSPs, such as containers, microservices, DevOps functions, continuous integration and continuous delivery (CI/CD), and advanced serverless architecture. This enhances product development from the outset and dramatically speeds design, build, and ramp-up, helping companies to dramatically reduce time to market.
A subscription lasts up to four years. If the car is new, this period starts on the retail delivery date. The subscription is linked to the car, so in the event of the car being sold, any remaining subscription time is passed on to the next owner/user. 041b061a72